MARC readiness: the UK Market Abuse Regime for Cryptoassets

MARC is the UK's Market Abuse Regime for Cryptoassets. It works in three layers.

The law: the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, made by HM Treasury. The rules: the Cryptoassets (Market Abuse) Instrument 2026, which inserts Chapter 4 into the FCA's Cryptoassets Sourcebook (CRYPTO 4). The explanation: FCA Policy Statement PS26/9.

MARC goes live on 25 October 2027.

The FCA published final rules in PS26/9 on 30 June 2026. The FCA authorisation gateway opened on 30 September 2026 and closes on 28 February 2027.

28 February 2027. Applying by then is the way to be authorised in time for go-live on 25 October 2027. Firms that apply later take the risk of not being authorised in time, and won't be able to onboard new customers from 25 October 2027 until they are approved.

Anyone trading UK-listed cryptoassets or related instruments. The prohibitions cover qualifying cryptoassets admitted to trading, or subject to an application for admission, on a UK qualifying cryptoasset trading platform, and related instruments whose prices depend on or affect those cryptoassets. For market manipulation, it is immaterial where the activities are carried out. The systems duty applies to authorised firms that operate a qualifying cryptoasset trading platform, and to firms that deal as principal, deal as agent or arrange deals in qualifying cryptoassets or related instruments (regulation 30(1)).

A UK QCATP averaging £10m or more in annual revenue over the previous three years. The FCA has clarified that the threshold applies to total group revenue across all activities and jurisdictions, so a global exchange with a small UK book can still be large. Large UK QCATPs carry extra obligations: onchain monitoring of relevant wallets (CRYPTO 4.7.20 to 4.7.22) and information sharing with other large UK QCATPs (CRYPTO 4.9.3 to 4.9.15).

In two tiers. Every UK QCATP, large or small, must detect material and persistent price dislocations against markets that matter for price formation, which for many tokens can include DEX pools (CRYPTO 4.7.11 (5)). Large UK QCATPs go further: they must monitor onchain the wallets their controls flag, and the wallets linked to them (CRYPTO 4.7.20 to 4.7.22).

CRYPTO 4.7.11 and 4.8.11 require analysis of each and every transaction executed and order placed, modified, cancelled or rejected. Firms must also replay the order book, produce alerts in line with predefined parameters, and monitor internal and external communications, such as social media. UK QCATPs must also detect material and persistent price dislocations against other markets. Systems must be appropriate and proportionate to the firm's business (CRYPTO 4.7.9 and 4.8.9).

No. KYT and blockchain analytics tools tell you who controls a wallet and whether it touched an illicit party. CRYPTO 4.7.22 asks a different question: did that wallet's trading move a price, fake volume, or trade ahead of inside information? That takes market surveillance built for onchain market structure: the AMM pool and the DEX behind each swap.

HALO is a multidimensional trade surveillance and transaction monitoring platform. It maps MARC's prohibited behaviours to HALO typologies, delivers cross on- and offchain trade surveillance, and keeps a full audit trail with seven-year data retention, ready for FCA review and your accountable Senior Managers. Solidus Professional Services support implementation, tuning, training and your annual review.

The UK QCATP, not the FCA. Under regulation 30(3), firms dealing as principal, dealing as agent or arranging deals must notify the platform operator without unnecessary delay. UK QCATPs must then receive and assess those notifications promptly and effectively (CRYPTO 4.7.5 (4)).

Insider dealing (reg 22), unlawful disclosure of inside information (reg 24) and market manipulation (regs 19 and 28). CRYPTO 4.4 to 4.6 describes these behaviours, including spoofing, layering, wash trading, front-running, pump-and-dump and cornering the market.

No. MARC is a civil regime only, and the Cryptoassets Regulations do not require the person to have intended to commit market abuse. FCA guidance indicates that firms which take all reasonable measures to prevent market abuse should not be deemed to have committed it when their employees do. Effective surveillance is how you evidence those measures.

MARC draws on UK MAR but is deliberately not a copy-out. It is adapted for crypto-specific features, including cryptoassets with no traditional issuer, decentralised assets and onchain activity. It also gives UK QCATPs, particularly large ones, greater responsibility for preventing, detecting and disrupting market abuse than UK MAR does.

No. The FCA narrowed the onchain duty after consultation (PS26/9). Large UK QCATPs must monitor wallets used for trading that their controls identify as a market abuse risk, plus any wallets reasonably identifiable as controlled by the same person or group of persons.

At least five years: CRYPTO 4.7.32 for UK QCATPs and CRYPTO 4.8.38 for intermediaries.

From 30 September 2026, when the gateway opens, through the FCA's online system. The gateway closes on 28 February 2027.

Yes, through a variation of permission (VoP), which asks for the same crypto-specific information as a new application.

A market abuse detection and prevention framework: a framework overview, a detailed systems and controls document, and a description of the surveillance systems and the rules they apply. Large platforms must also show how they will meet their transparency duties and detect and report suspected market abuse.

A market abuse prevention attestation: intermediaries must have effective policies, arrangements, systems and procedures to prevent, detect and disrupt market abuse.

Seven. For trading platforms: the market making policy, the algorithmic trading policy, the matched principal trading policy, the conflicts of interest policy, and, for platforms that trade on their own account, the policies that keep that trading outside the platform. For intermediaries dealing as principal: managing conflicts between own-account trading and client orders. For most firms: the personal account dealing attestation, in line with CRYPTO 5.8.

Orders and transactions on- and offchain, real-time and post-event (T+1) alerts, order book replay, alerts in line with predefined parameters, price dislocation detection, case management and record keeping. HALO supplies the evidence for disruption, notifications, governance and training.

HALO ingests onchain activity at the level of each swap and liquidity event across 30+ chains, including Ethereum, Solana, Base, Arbitrum, Optimism, Polygon, Avalanche, BNB Chain, Robinhood Chain, HyperCore and HyperEVM, and delivers it daily into your environment. The data is in place before any wallet is flagged, so a lookback is possible when one is. Onchain swaps and platform trades sit on one timeline, in one case.

HALO exports the case evidence a disclosure needs, including the CRYPTO 4.9.10 items, whether the abuse happened on your platform, onchain, or both. Every finding states whether the behaviour took place on- or offchain, and onchain findings carry the transaction hash, block and wallet, so the receiving platform can check each transaction itself. Making and receiving disclosures is your process.

CRYPTO 4.7.23 says onchain monitoring may cover wallet interactions, token flows and transaction patterns, using blockchain analytics, wallet clustering and anomaly detection. HALO detects transaction patterns today, at the level of each swap and liquidity event.

Yes. Market abuse and financial crime rarely arrive alone. HALO covers misuse of information, price and market manipulation, and financial crime through markets, within a single cross on- and offchain platform.

Within weeks, so you're live and tested before the gateway closes on 28 February 2027.

Book your MARC readiness assessment at soliduslabs.com/demo.