Marketing cryptoassets to UK consumers through an s21 approver
Unregistered and overseas cryptoasset firms can market to UK consumers if an FCA-authorised firm approves their promotions under section 21 FSMA. This route closes when the new cryptoasset regime starts on 25 October 2027, except for firms that applied for authorisation in the window ending 28 February 2027, which can keep using it until their application is decided.
Facts under review · last checked 2026-10-08 · confirm figures with the regulator before relying on them
Regulator · Financial Conduct Authority (FCA) ↗
Key facts
- Financial promotion regime
- Cryptoasset financial promotion rules in force since 8 October 2023as of 2026-10-08Source ↗
- Penalty for unlawful promotion
- Criminal offence under s21 FSMA: up to 2 years' imprisonment, an unlimited fine, or bothas of 2026-10-08Source ↗
- Approver gateway
- Since 7 February 2024, authorised firms must pass an FCA gateway before approving promotions for unauthorised personsas of 2026-10-08Source ↗
- After 25 October 2027
- Firms that did not apply in the window must run off UK cryptoasset business; approvers should not approve promotions for firms conducting regulated activity without permissionas of 2026-10-08Source ↗
- Firms that applied in the window
- May keep using their s21 approver until their application is determinedas of 2026-10-08Source ↗
Realistic timeline
Who does what, and how long each phase usually takes once work starts. The regulator’s share is outside anyone’s control.
- HartsizMarketing and onboarding review against FCA rules1–3 weeks
- YouApprover selection, promotion redrafting and journey changes2–8 weeksHartsiz drafts; the client builds the journey and signs off
- RegulatorApprover review and sign-off2–8 weeksOutside our control; the approver is a third party and can refuse or withdraw approval
Estimated end to end: 5–19 weeks. Not a guarantee.
What the regulator expects to see
- Relationship with an FCA-authorised approver that has passed the approver gateway
- Promotions with the required risk warnings and a 24-hour cooling-off period for new clients
- Client onboarding with appropriateness checks under FCA promotion rules
Questions we get
Can an overseas firm keep marketing to UK consumers after October 2027 with an approver?
Only if it applied for FCA authorisation in the window ending 28 February 2027 and the application has not yet been decided. Otherwise it must run off its UK business before the regime starts.
Is approval a one-off sign-off?
Approvers must follow FCA rules and guidance on cryptoasset promotions, and they should not approve promotions for firms conducting regulated activity without permission. Expect ongoing scrutiny, not a single stamp.