UK Crypto Regulation Lags Behind EU MiCA and US GENIUS Act
UK crypto regulation is stalling as the FCA’s Crypto Asset Roadmap still lacks a confirmed go-live date beyond 2026. While the EU’s MiCA framework is now fully operational and the US Senate has passed the GENIUS Act to establish federal stablecoin rules, the UK has yet to clarify its approach. The treatment of stablecoins as investment assets has confused markets. The Bank of England’s initial proposal for fully central bank-backed stablecoins was deemed commercially unviable and later softened, but no definitive model has emerged. Meanwhile, Hong Kong’s Project Ensemble and the UAE’s VARA regulator are moving ahead with stablecoin legislation and tokenization initiatives. Traders should watch for shifts in stablecoin demand and cross-border flows as regulatory clarity remains pending. Clear, pragmatic rules on stablecoins and on-chain finance are critical if the UK is to maintain its competitive edge.
Bearish
This regulatory delay creates uncertainty around stablecoin use and digital asset projects in the UK. In the short term, lack of clear rules will likely discourage issuers and traders from launching or adopting new stablecoin solutions, reducing liquidity and trading volumes. Long term, if the UK fails to match the clarity of MiCA and the GENIUS Act, capital and innovation may shift to more decisive jurisdictions like the EU, US, Hong Kong and the UAE. This could weaken the UK’s market position and investor confidence, resulting in a bearish outlook for UK-focused crypto trading activity.