US and UK Crypto Rules in 2026: What the SEC Proposal and FCA Regime Mean for Investors

Two of the biggest financial markets in the world are rewriting their crypto rules at the same time, and they are not doing it the same way. In the United States, the Securities and Exchange Commission (SEC) has put out a proposal about how crypto projects can raise money. In the United Kingdom, the Financial Conduct Authority (FCA) has finished its rulebook and is now waiting for firms to apply.

If you hold crypto, trade it, or just follow the news, these two moves are worth understanding. Here is what each one actually says.

The US: the SEC’s “Regulation Crypto Assets” proposal

On 18 August 2026 the SEC proposed a new set of rules it calls Regulation Crypto Assets. The rules cover certain investment contracts that involve crypto assets, which is the area where founders and lawyers have argued for years about what counts as a security.

SEC Chairman Paul Atkins said the goal is to give crypto entrepreneurs a clear path to raise capital under federal securities law, and to keep that work inside the United States. He also pointed out that Congress is still working on a lasting framework, so this is not the final word.

The main pieces of the proposal:

• Two exemptions from registration. One is a one-time exemption for offerings of up to $5 million over four years. The other covers offerings of up to $75 million in any 12-month period.
• Disclosure to investors. Both exemptions require plain narrative disclosures. The larger one also needs financial statements and ongoing reports.
• A conditional safe harbor. If the conditions are met, the crypto asset itself would not be treated as an investment contract, and so would not count as a security under US law.
• State rules set aside. The proposal would override state registration requirements for offers made under these exemptions, and for some later trading.

It is only a proposal. The public gets 60 days to comment after it is published in the Federal Register, and nothing changes for ordinary users until a final rule is adopted.

The UK: the FCA’s final rules

The UK is further along. Parliament passed the Cryptoassets Regulations on 4 February 2026, and in late June the FCA published its final policy statements to go with them.

The rules touch most of the things a crypto user comes across:

• Stablecoins. Rules on what backs them and how quickly holders can redeem.
• Custody. Client crypto held by a firm falls under the FCA’s client asset rules.
• Staking. Firms must explain the terms and get client consent.
• Lending and borrowing. Retail customers keep extra protections, such as clearer disclosure and over-collateralisation.
• Market abuse. A regime aimed at insider dealing and manipulation in crypto markets.
• Token disclosure. Admission documents for tokens traded on UK platforms.

For DeFi, the FCA says the rules apply where there is an identifiable entity in control, and it will look at each case on its merits. More guidance on DeFi is planned.

The dates to remember:

• 30 September 2026: the window opens for firms to apply under the transitional route.
• 28 February 2027: that window closes. Firms that apply inside it can keep operating while the FCA reviews them. Firms that apply later may have to stop until they are authorised.
• 25 October 2027: the full set of regulated activities comes into force.

How the two approaches differ

Our reading is that the two regulators are answering different questions. The SEC proposal is mostly about how a token is sold: what a project has to say, and when a token stops being treated as a security. The FCA regime is mostly about who is allowed to run a crypto business: exchanges, custodians, stablecoin issuers and lenders all need to be authorised and follow conduct rules.

That is a simplification, and both regimes will grow as they are finalised. But it is a useful way to keep them apart when reading headlines.

What it means in practice

If you are in the UK, check whether a platform is authorised before you deposit money with it. The FCA keeps a public register for this. Over the next year you will probably see more firms announcing applications or changing their services.

If you are in the US, nothing changes today. The proposal is open for comment, and the final version could look different. Watch for the final rule and for what Congress does.

If you are mainly watching prices, regulation is one factor among many. Interest rates matter too. On 16 September the Federal Reserve raised its target range by a quarter point to 3.75% to 4%, with a unanimous 12-0 vote, citing inflation that is still above its 2% goal. Higher rates have often weighed on risk assets such as bitcoin, though the link is not constant.

The live chart below shows where bitcoin is trading right now.

Sources

We built this piece from the regulators’ own announcements:

• SEC press release 2026-76: SEC proposes new Regulation Crypto Assets
• FCA: overview of the cryptoassets regime policy statements
• Federal Reserve: FOMC statement, 16 September 2026

Rules and dates can change, so check the official pages before you make decisions. This article is general information, not legal or investment advice.