UK FCA: Crypto Apps Routing Trades by Price, Liquidity May Need Authorization

The FCA is drawing a functional line between neutral infrastructure and discretionary trade execution, which matters for crypto apps whose value proposition rests on smart order routing. The test hinges on material influence over trading decisions rather than algorithmic automation, so interfaces that merely execute preset user rules may retain the exemption while those optimizing price or liquidity face authorization. This affects wallet and aggregator providers operating in the UK, and the long runway to the new regime gives the industry time to adapt. Whether the final guidance narrows or widens that material-participation test is the open question.