The years in which cryptocurrency operated in a largely unregulated space are drawing to a close. Regulatory frameworks have been enacted or implemented across the UK, EU, UAE, and United States, and the global infrastructure for automatic exchange of cryptocurrency account information — the Crypto Asset Reporting Framework (CARF) — is now operational in a growing number of jurisdictions. For internationally mobile investors, understanding these changes is increasingly important.
This article provides an update on the key regulatory developments as of mid-2026.
United Kingdom: the FCA's evolving crypto framework
The UK's Financial Conduct Authority (FCA) has moved decisively to regulate the cryptocurrency sector. Key elements of the UK regulatory position include:
Registration requirement. Crypto asset businesses operating in the UK (including exchanges, custodians, and brokers) must be registered with the FCA under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations. The FCA has granted registration to a relatively small proportion of applicants and has rejected or returned a larger number, citing inadequate anti-money laundering controls.
Financial promotions regime. Since late 2023, marketing of crypto assets to UK consumers has been subject to the same regulatory standards that apply to traditional financial promotions. Crypto businesses must either be FCA-authorised or work with an authorised firm to approve their promotions. Promotions must be fair, clear, and not misleading. The FCA has taken enforcement action against numerous firms that failed to comply.
Consumer protection. The FCA is developing broader consumer protection rules for crypto, including requirements around custody, segregation of client assets, and disclosure. The direction of travel is clear: crypto businesses that wish to serve UK customers will face standards broadly comparable with those facing regulated financial services firms.
The FCA register. If you are using a crypto platform to buy, sell, or hold assets, check that it appears on the FCA's crypto register. Using an unregistered platform carries increased risk — there is no recourse through the Financial Ombudsman Service or the Financial Services Compensation Scheme for crypto assets held on unregistered platforms.
EU: MiCA — the first comprehensive framework
The Markets in Crypto-Assets Regulation (MiCA) represents the most comprehensive regulatory framework for crypto globally. After years of development, MiCA reached full implementation by late 2024.
Key provisions include:
Licensing for crypto asset service providers. Exchanges, brokers, custodians, and other crypto service providers operating in the EU must obtain a MiCA licence. A licence in one EU country is passportable across the bloc — a significant administrative simplification.
Stablecoin rules. MiCA imposes specific requirements on issuers of "e-money tokens" (stablecoins pegged to a single fiat currency) and "asset-referenced tokens." Reserve requirements, redemption rights, and volume limits apply. The largest stablecoins (including some that previously had substantial EU market share) faced restrictions if they did not comply.
Consumer disclosure. Issuers of crypto assets must publish a "crypto-asset white paper" containing prescribed information about the asset and its risks.
Market abuse rules. MiCA includes provisions against insider trading and market manipulation in crypto markets — applying equivalent standards to those in traditional financial markets.
For UK-based firms, MiCA does not directly apply — the UK is no longer in the EU — but it affects access to EU customers and creates a benchmark for regulatory standards.
UAE: VARA and a crypto-friendly framework
Dubai has positioned itself as a global hub for the crypto industry, with the Virtual Assets Regulatory Authority (VARA) providing a clear licensing framework for crypto businesses operating in the emirate.
VARA has issued licences to a growing number of exchanges and service providers, subject to ongoing compliance requirements including AML/CFT controls, capital requirements, and consumer protection standards. Several major international exchanges have established regulated operations in Dubai.
The UAE's approach is notably more accommodating to innovation than the EU's or UK's, while still providing a regulatory framework that serious institutional participants consider credible. For individuals investing in crypto from the UAE, using VARA-regulated exchanges provides a degree of regulatory protection.
It is worth noting that even in the UAE, crypto profits are not taxed at the individual level — consistent with the UAE's general zero income tax position on individuals. Corporate entities involved in crypto may be subject to UAE corporate tax.
United States: an evolving picture
The US regulatory landscape for crypto has been more volatile than other major jurisdictions, owing to ongoing disputes about jurisdiction between the SEC (Securities and Exchange Commission) and CFTC (Commodity Futures Trading Commission), and to shifts in regulatory philosophy with each administration.
The approval of spot Bitcoin ETFs by the SEC in January 2024 was a significant development, opening up a large new pool of regulated institutional capital. Spot Ethereum ETFs followed later in 2024. These products allow investors to gain Bitcoin or Ethereum exposure through standard brokerage accounts without holding the underlying assets directly.
The approach of the current US administration has been broadly more accommodating to the crypto industry than its predecessor, with less aggressive enforcement action and signals of willingness to engage in formal regulatory rulemaking. However, the regulatory framework for crypto in the US remains incomplete and subject to change.
For non-US investors, the approval of spot Bitcoin ETFs is primarily relevant as a signal of growing institutional legitimacy — and as a potential channel through which global institutional capital continues to flow into the asset class.
OECD CARF: automatic exchange of crypto information
Perhaps the most practically important regulatory development for international investors is the Crypto Asset Reporting Framework (CARF), developed by the OECD and modelled on the Common Reporting Standard (CRS) that already governs automatic exchange of bank account information.
Under CARF, crypto asset service providers in participating jurisdictions are required to collect information about their customers' identities and transactions, and to report that information to the relevant tax authority, which then exchanges it automatically with the tax authorities of the customer's country of tax residence.
More than 67 jurisdictions have committed to CARF implementation. The framework requires crypto asset service providers to begin collecting and reporting data from 1 January 2026; the first actual exchanges of data between tax authorities will take place in 2027, with the UK requiring the first reports to be submitted to HMRC by 31 May 2027. Participating jurisdictions include the UK, EU member states, the UAE (which joined the CRS framework), and others.
The practical implication is clear: the idea that cryptocurrency holdings are invisible to tax authorities is no longer accurate and has not been for some time. Anyone who has received crypto income, realised crypto gains, or holds significant crypto assets without declaring them to the relevant tax authority faces growing risk of detection as CARF data begins to flow.
UK tax treatment reminder: in the UK, cryptocurrency is treated as a capital asset. Disposal (including exchange of one crypto for another) is a taxable event giving rise to CGT. Crypto received as income (from mining, staking, or as payment for services) is subject to income tax. Self-assessment returns must include crypto gains and income. HMRC has been actively requesting information from UK-based exchanges and using blockchain analytics to identify non-compliance.
Practical implications for international investors
Use regulated platforms. Whether in the UK, EU, or UAE, using a regulated crypto exchange reduces counterparty risk and provides at minimum the protection of regulatory oversight.
Keep records. The CGT and income tax implications of crypto require detailed records of every acquisition, disposal, and income event — date, price, amount, and the sterling value at the date of each transaction. Maintaining these records is your responsibility.
Declare crypto assets. CARF means there is no sustainable strategy based on non-disclosure. If you have crypto gains or income that have not been declared, taking voluntary steps to regularise your position is far less costly than waiting for HMRC or another authority to find it.
Take advice on structuring. For investors with substantial crypto holdings, the structuring of holdings — timing of disposals relative to tax years and residency changes, use of annual CGT exemptions, spousal transfers — can make a meaningful difference to the tax outcome. This is an area where advice pays.
This article is for general information purposes only. Cryptocurrency regulation and tax treatment change rapidly across jurisdictions. Nothing in this article constitutes personal investment, legal, or tax advice. Please seek qualified independent advice appropriate to your circumstances. Global Investments can connect you with relevant specialists — contact us.
This article is for general information only and does not constitute financial, legal or tax advice. Rules, prices and regulations change; verify current requirements with a qualified adviser before acting.