Insights / UK and EU · part 2

A UK and EU timeline: the rules that make on-chain evidence matter

MiCA, DAC8, CARF, the FCA's new cryptoasset regime and the EU's single AML rulebook - the dates, who each affects, and what kind of evidence each one creates a need for.

Between 2024 and 2027, crypto in the UK and the EU moves from lightly supervised to fully inside the financial-services perimeter. Each step increases the number of people who must be able to evidence something about a wallet, an account or a customer. This is a plain summary of what applies when. It is not legal advice, and firms should take their own.

European Union

MiCA - the Markets in Crypto-Assets Regulation

MiCA is the EU's single rulebook for crypto-asset issuers and service providers. Its stablecoin provisions applied from mid-2024 and the rest from 30 December 2024. Member states could allow existing providers a transitional period, which ended no later than 1 July 2026. From that point a crypto-asset service provider (CASP) operating in the EU needs MiCA authorisation.

Why it matters for evidence: authorised firms carry conduct and governance obligations that unregulated ones did not, including how they assess the crypto-assets they admit to trading. Decisions that used to be informal now need a file.

DAC8 - tax reporting

DAC8 brings crypto into the EU's framework for automatic exchange of tax information, implementing the OECD's Cryptoasset Reporting Framework. It applies from 1 January 2026. Providers collect user and transaction data for 2026, and the first reports are made during 2027.

Why it matters for evidence: tax authorities will hold platform data on individuals. Anyone whose returns do not match will need a reconstructed history, and most of what happens off-platform is only visible on-chain.

The AML package

The EU has replaced its anti-money-laundering directives with a directly applicable regulation and a new authority, AMLA, based in Frankfurt. The single rulebook is due to apply from July 2027. Crypto-asset service providers are obliged entities, and the rules on customer due diligence and source of funds apply to them in the same way as to banks.

Why it matters for evidence: source-of-funds and source-of-wealth checks on crypto-derived money become routine across the EU, on a harmonised basis.

United Kingdom

Money Laundering Regulations 2017

Already in force. Solicitors, accountants, estate agents, banks and cryptoasset businesses must carry out customer due diligence, including understanding the source of funds in higher-risk situations. Cryptoasset exchange and custodian wallet providers have had to register with the FCA for AML purposes since 2020.

Why it matters for evidence: this is the reason a conveyancing solicitor asks a buyer to explain how their crypto wealth arose.

CARF - tax reporting

The UK applied the Cryptoasset Reporting Framework from 1 January 2026. UK platforms report users' 2026 transactions to HMRC by 31 May 2027.

Why it matters for evidence: the same as DAC8. Expect more individuals needing their history put in order, and more accountants asked to do it.

The FCA's cryptoasset regime

The UK is bringing crypto activities - operating a trading platform, dealing, arranging, custody, staking services and stablecoin issuance - inside the Financial Services and Markets Act perimeter. The FCA has published its final core rules. The application gateway for authorisation is open from 30 September 2026 to 28 February 2027, and the regime goes live on 25 October 2027. Firms that want to keep operating in the UK need to apply within the window.

Why it matters for evidence: UK platforms will need documented processes for the assets they admit and the customers they serve, to a standard a supervisor will examine.

The dates in one place

Date Jurisdiction What happens
30 Dec 2024 EU MiCA fully applicable
1 Jan 2026 UK and EU CARF and DAC8 data collection begins
1 Jul 2026 EU Latest end of MiCA transitional period
30 Sep 2026 UK FCA authorisation gateway opens
28 Feb 2027 UK FCA authorisation gateway closes
31 May 2027 UK First CARF reports due to HMRC
2027 EU First DAC8 reports; single AML rulebook applies from July
25 Oct 2027 UK FCA cryptoasset regime goes live

What this means in practice

None of these rules says "commission a wallet analysis". What they do is create a steady stream of moments where someone regulated has to be satisfied about something that is recorded on a blockchain and nowhere else: where a client's money came from, what a client did in a tax year, what an estate held at the date of death, where misapplied funds went.

Blockchains are unusual in that the underlying evidence is public, permanent and independently checkable. The work is turning it into a document that a solicitor, an accountant, a compliance officer or a supervisor can read and rely on.

Find out what the wallets say.

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