Every crypto licensing deadline you need to hit in 2026
Three of the crypto licensing regimes we track most closely — Kenya, the United Kingdom and Brazil — all turn on dates falling inside the next few months. They are not the same kind of date. One is a licensing deadline with an offence behind it, one is an application window that closes more than a year before the rules it leads to take effect, and one is the first of two filing phases. Confusing them is the most common planning error we see. Here is each, with the instrument that sets it.
Brazil: 30 October 2026
Brazil's virtual asset framework — Resolutions BCB 519, 520 and 521, published in November 2025 — came into force on 2 February 2026. Resolution BCB 519 gives providers already operating on that date 270 days to file an authorisation request, which lands on 30 October 2026.
The filing itself is governed by Normative Instruction BCB 704 of 29 January 2026. Incumbents file in two phases: article 9 requires the Phase 1 submission, including evidence that the firm was already operating when Resolutions 519 and 520 took effect, by 30 October 2026; article 10 then allows 60 days from a favourable determination by the Banco Central do Brasil to file Phase 2. Phase 2 therefore has no fixed calendar date — it is driven by the regulator's own timetable. Firms that were not already operating do not use the two-phase route at all: under article 5 they make a single complete submission, and 30 October does not apply to them.
If an application is refused or shelved, the provider must cease activities within 30 days, notify clients and return custodied assets. That is why 30 October functions in practice as a shutdown date rather than a paperwork date.
Kenya: 4 November 2026
The Virtual Asset Service Providers Act, 2025 (Act No. 20 of 2025) commenced on 4 November 2025. Section 47 gives providers already operating one year to comply, so existing firms must be licensed by 4 November 2026.
The implementing rules arrived late. The Virtual Asset Service Providers Regulations, 2026 (Legal Notice No. 134 of 2026, Kenya Gazette Supplement No. 185) were published in the second half of July 2026, leaving roughly three months of runway. Supervision is split: the Central Bank of Kenya takes custodial wallet providers, virtual asset payment processors and stablecoin issuers, while the Capital Markets Authority takes exchanges, brokers, advisers, virtual asset managers, ICO providers, tokenisation providers and token issuance platforms.
Two practical points. First, as at early August 2026 neither regulator had licensed any provider under the Act, so no applicant has yet been through the process end to end. Second, no published source sets out what happens to a firm that files in good time but is not licensed on 4 November 2026. Do not plan on trading pending determination unless your Kenyan counsel can point to the provision that permits it.
United Kingdom: 30 September 2026 to 28 February 2027
The UK date is an application window, not a compliance deadline. The FCA expects the cryptoasset authorisation gateway to open on 30 September 2026 and close on 28 February 2027. The regime itself applies to firms granted permission under FSMA on or after 25 October 2027, the date of full commencement of the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102).
The trap is registration under the Money Laundering Regulations. The FCA has been explicit that there will be no automatic conversion: an MLR-registered cryptoasset business must secure FSMA authorisation through the same gateway as everyone else. The FCA published its core rules on 30 June 2026 in PS26/9 to PS26/13, so the substance a firm is applying against is now known.
How the three differ
- Consequence of missing it. Kenya and Brazil attach the deadline to the right to operate. The UK date attaches to a queue — miss the window and you are waiting for whatever the FCA decides to do next, which it has not committed to.
- What you file. Brazil splits the burden across two phases. Kenya and the UK expect a complete pack up front.
- What drives scope. In Kenya your regulator follows from your activity category. In Brazil your category under Resolution BCB 520 drives your minimum capital, reported in a range of roughly R$10.8m to R$37.2m deriving from Resolução Conjunta 14 and Resolution BCB 517. In the UK the perimeter question comes first and is genuinely contestable.
What is still moving
None of these regimes is finished. HM Treasury published a draft amending SI on 21 April 2026 that would adjust the UK perimeter, and the FCA's perimeter guidance is still at consultation stage — CP26/13 closed on 3 June 2026, with final guidance expected in autumn 2026. In Brazil, Resolutions BCB 552 and 553 of March 2026 extend governance, ombudsman and accounting requirements to virtual asset providers; the timing of the accounting obligations is reported inconsistently, so check it against the resolutions before building a reporting calendar. In Kenya, Legal Notice 134 has drawn scrutiny from the National Assembly committee responsible for delegated legislation, a reminder that a legal notice can still change.
Where a figure, article number or date matters to a decision, confirm it against the gazetted text or the regulator's own publication rather than a summary — including this one.
The three checklists
I keep one working document per regime, each 11 pages, each with the source class marked behind every figure so you can see what is instrument text and what is reporting of it.
- Kenya — VASP Act 2025 and Legal Notice 134 — USD 79
- Brazil — Res. BCB 519/520/521 and IN BCB 704 — USD 79
- UK — FCA cryptoasset authorisation gateway — USD 149
If you span more than one, the 48-hour gap check reads what you have and returns a written list of what is missing, in the order it should be fixed.