UK Trails EU, US in Crypto Regulation, Think Tank Warns

The UK’s unclear regulatory stance on digital assets is drawing sharp criticism from market participants, with some citing “policy procrastination” as a key reason the country is falling behind both the European Union and the US in the race to define digital finance.

In a Friday blog post, John Orchard, chairman, and Lewis McLellan, editor of the Digital Monetary Institute at the Official Monetary and Financial Institutions Forum (OMFIF), an independent think tank, argued that the UK has wasted its early-mover advantage in distributed ledger finance.

The post, titled “The UK keeps missing the boat on DLT finance,”  said that the UK, once expected to set a post-Brexit gold standard for crypto regulation, continues to “talk un-specifically about regulation in the future.”

“As it stands, there is a date conspicuously missing for the ‘Regime go-live’ portion of the Financial Conduct Authority’s ‘Crypto Roadmap,’ though it suggests some time after 2026,” Orchard and McLellan wrote.

Related: UK to become ‘safe harbor’ for crypto with new draft rules

EU and US introduce crypto regulations

The European Union’s Markets in Crypto-Assets (MiCA) framework is already in effect, while the US Senate recently passed the Guiding and Establishing National Innovation for US Stablecoins, or GENIUS Act, a landmark bill establishing federal guardrails for stablecoins.

However, the UK’s Financial Conduct Authority still lacks a confirmed go-live date for its crypto regime. “This absence of a workable framework retards the UK’s ability to adapt to the possibility that… all of finance is going onchain,” the authors wrote.

The criticism also focuses on the UK’s approach to stablecoins. Unlike the US, which treats them as distinct payment tools under the Genius Act, UK regulators have lumped them in with crypto investment assets, a move that has “mystified” the market.

The Bank of England’s initial stance only deepened concerns. Its draft framework required systemic stablecoins to be backed entirely by central bank money — a condition industry players argued would make issuance commercially unviable. While the Bank has since begun to ease this position, it hasn’t yet offered a workable model.

Related: The crypto fund domicile decision: EU or the UK?

Jurisdictions move forward with crypto regulations

Meanwhile, other jurisdictions are making strides. In May, Hong Kong passed a stablecoin bill and is rapidly developing a tokenization ecosystem through its Project Ensemble initiative.

The authors also praised the United Arab Emirates’ Virtual Assets Regulatory Authority (VARA) for being a dedicated digital asset regulator, unlike the UK’s attempt to adapt legacy institutions to new financial models.

The blog concluded that while the UK led fintech innovation in the 2010s and still benefits from advantages like its time zone, language, and legal system, its position is far from secure. “Financial centers come and go,” the authors warned, urging swift action from regulators.

Magazine: New York’s PubKey Bitcoin bar will orange-pill Washington DC next