The UK Financial Conduct Authority’s CP26/36 consultation, according to the supplied materials, examines when crypto trading apps go beyond simply forwarding orders and begin making execution-related decisions that may require authorization. The reported perimeter includes tools that influence venue selection, routing or timing. The FCA gateway states that firms can apply from 30 September 2026 to 28 February 2027.

Which crypto trading apps fall within CP26/36’s scope

The supplied reporting identifies execution discretion as the central trigger. An app may fall within the authorization perimeter discussed in CP26/36 if it does more than transmit a user’s order and instead helps determine where, when or how a trade is executed.

The Flash says relevant indicators include selecting trading venues or execution routes based on price, liquidity, cost, speed, counterparty risk or expected outcomes. It adds that changing trade instructions or determining execution timing may signal discretionary involvement, and that automated decision-making does not in itself remove the requirement.

A dated extract from Global Regulation Tomorrow describes CP26/36 as FCA cryptoasset perimeter guidance published on 21 October 2026. This is significant because the consultation sets a regulatory boundary rather than creating a new, named category of app. In practice, the key functional question is whether a product influences execution for the client or merely transmits instructions.

What discretionary participation and the technical-services exclusion mean

A purely interface-based product may remain outside that boundary, but the carve-out cited in the supplied materials is narrow. The Flash says interfaces that only forward orders without affecting execution may qualify for a technical-services exemption. Any feature that alters execution outcomes, however, risks bringing the product back into regulated territory.

The supplied extract from legislation.gov.uk links that exclusion to Article 9Y on arranging deals in qualifying cryptoassets. Under the wording shown, the exclusion applies where an unauthorised person that is not a payment service provider merely provides a technical service enabling another person to access services offered by a third party or a decentralized protocol.

Even without the full statutory text, this draws a clear practical distinction: passive access is not the same as active execution logic. The safest interpretation is therefore not that all wallets, front ends or aggregators are exempt, but that reliance on a technical-services exclusion becomes more difficult as a product exerts greater influence over routing, timing or trade terms.

Consultation deadline and application window firms need to monitor

The supplied materials point to separate consultation and licensing timelines. Global Regulation Tomorrow’s dated CP26/36 extract says consultation responses are due by 18 November 2026, while an FCA gateway-page extract says the authorization application period opened on 30 September 2026 and closes on 28 February 2027.

The FCA gateway extract also says firms can apply for authorization, or vary existing permissions, through Connect. The Flash states that the broader regime takes effect on 25 October 2027. The timelines should therefore be distinguished: consultation first, an application window that is already open, and the regime taking effect later.

One timing detail is less certain than the headline version of the story suggests. The Flash says the FCA plans to publish a final version in January 2027, whereas the dated CP26/36 commentary says final guidance is planned for spring 2027. Based on the supplied materials, spring 2027 is the firmer timeframe.

The key dates from those materials are: