The Payment Expert Podcast is joined by Shaanil Senarath-Dassanayake, Associate at Charles Russell Speechlys, to discuss how firms should be preparing for a wave of overlapping regulatory change across crypto assets, deferred payment credit, and payments supervision
The UK’s financial services regulatory calendar is as busy as it has ever been. New crypto asset frameworks, the incoming deferred payment credit regime, and structural changes to payments supervision are all converging at once.
For firms tracking multiple regimes simultaneously, the prioritisation challenge is becoming as consequential as compliance itself.
Shaanil Senarath-Dassanayake, Associate in the financial services regulation space at Charles Russell Speechlys, warns that while the volume of change is broadly understood across the industry, the depth of what it demands internally is still being underestimated in places.
On the transition from MLR registration to full FSMA authorisation under the forthcoming crypto asset regime – expected to come into force in October 2027, with the application gateway opening in September 2026 – her advice is clear: start now.
Firms waiting on final rules risk falling behind, and the Financial Conduct Authority (FCA) has been clear there will be no automatic conversion for currently registered businesses. The one area where hesitancy is more justified, she acknowledges, is stablecoins, where conflicting signals from the FCA, Bank of England, and Treasury have created genuine ambiguity.
UK regulation: Accountability all the way down
The extension of the Senior Managers and Certification Regime (SMCR) to crypto firms is where the sharpest culture shock will land, particularly for founder-led businesses accustomed to informal governance. SMCR means named individuals, clearly allocated responsibilities, and personal accountability if something goes wrong.
Senarath-Dassanayake argues that readiness cannot sit with legal and compliance alone – it needs to be a firm-wide conversation. “Everyone needs to know that they’re all responsible for the licence.”
On deferred payment credit, the 15 July authorisation deadline is approaching fast, with firms needing to file for temporary permission before 1 July.
Mandatory creditworthiness assessments on every transaction – including those under £50 – will see a change from the frictionless checkout model the sector has relied on, and Financial Ombudsman Service access for consumers for the first time means complaints infrastructure needs to be in place.
Closing on the PSR’s absorption into the FCA, she expects the shift to be felt most in supervisory tone, with the FCA’s consumer protection focus and broader enforcement powers bearing more heavily than the PSR’s lighter regime.
Her final word is a call for industry engagement, echoing Lord Holmes‘s warning that without consistent regulatory direction the UK risks becoming a “flyover jurisdiction”. Firms, she argues, have both an interest and a responsibility in shaping what comes next.
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