Crypto Law Profile

Financial Services and Markets Act 2023 (Digital Securities Sandbox) (Amendment) Regulations 2025

UK regulations effective 3 March 2025 that amend the Digital Securities Sandbox, temporarily modify cryptoasset-specific Money Laundering Regulations treatment, and adjust supervision, whistleblowing and FSMA permissions.

United Kingdom Effective Act Mar 3, 2025

At a glance

Status In force across the United Kingdom from 3 March 2025.
Instrument United Kingdom Statutory Instrument 2025 No. 93.
Core change Temporarily modifies cryptoasset-specific MLR treatment for in-scope DSS activity.
Supervision Clarifies regulator roles and adds DSD whistleblowing and FSMA permissions adjustments.

Overview

The Financial Services and Markets Act 2023 (Digital Securities Sandbox) (Amendment) Regulations 2025 are a United Kingdom statutory instrument amending the legal framework for the Digital Securities Sandbox (DSS). Identified as UKSI 2025/93, the regulations were made on 28 January 2025, laid before Parliament on 30 January 2025 and entered into force across the United Kingdom on 3 March 2025. They amend the 2023 DSS Regulations rather than creating a separate sandbox.

What the Digital Securities Sandbox amendment does

The DSS is the United Kingdom’s first financial market infrastructure sandbox under the Financial Services and Markets Act 2023. It permits firms to test developing technologies, including distributed ledger technology, in the issuance, trading and settlement of securities under a temporarily modified framework. Entrants may undertake activities associated with a central securities depository and, where authorised, combine them with operating a trading venue.

The 2025 amendment addresses how existing requirements apply inside that framework. Its principal change concerns the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, or MLRs. HM Treasury’s explanatory memorandum states that DLT-related DSS activity could otherwise be treated as a cryptoasset service. A firm already authorised or registered for other financial services activity might therefore need separate FCA registration as a cryptoasset business. The government regarded that result as disproportionate for regulated securities-market activity in the sandbox.

Key provisions of UKSI 2025/93

Temporary cryptoasset-specific MLR modification

Regulations 4 and 7 add the MLRs to the legislation modified for the DSS and insert a new Part 6 into the Schedule to the 2023 regulations. The amendment temporarily disapplies selected MLR provisions that depend on concepts such as a cryptoasset exchange provider or custodian wallet provider when the relevant activity occurs within the DSS. It is not a general exemption from United Kingdom anti-money laundering law. Other applicable AML and counter-terrorist financing requirements continue, and the modification does not extend outside the sandbox.

Regulator allocation and whistleblowing

Regulation 3 clarifies the “appropriate regulator” for specified ancillary financial market infrastructure activities, allocating responsibility between the Financial Conduct Authority and the Bank of England according to the activity. Regulation 5 modifies the sandbox version of the United Kingdom Central Securities Depositories Regulation. It requires a digital securities depository to operate a scheme through which employees can report actual or potential DSS infringements.

FSMA permissions adjustment

Regulation 6 modifies Part 3 of the Schedule to the 2023 regulations. In specified DSS circumstances, it disapplies section 20 of the Financial Services and Markets Act 2000 for an authorised person carrying on financial market infrastructure activities as a digital securities depository or ancillary FMI activities. It also corrects the existing modification of paragraph 21 of Schedule 17A to that Act.

Who the regulations affect

The amendments are principally relevant to DSS entrants, prospective digital securities depositories, authorised firms undertaking in-scope FMI activity, and the FCA and Bank of England as supervisors. They may also affect issuers, trading venues, settlement participants and service providers interacting with a sandbox entrant. The instrument does not establish a general regime for cryptoasset exchanges, wallet providers or retail token markets; its operation is tied to activity within the DSS.

Status, duration and related framework

UKSI 2025/93 is in force as of 19 June 2026. It should be read with the 2023 DSS Regulations, applicable Bank of England rules and guidance, and FCA requirements for separately regulated activity. The underlying 2023 DSS Regulations are scheduled to cease to have effect on 8 January 2029 unless the framework changes beforehand. That date concerns the statutory duration of the underlying sandbox regulations, not a separate repeal date in the 2025 amendment.

The amendment is therefore a targeted adjustment to the DSS. It reduces potential duplication arising from cryptoasset-specific MLR classification while preserving the broader supervisory structure and adding reporting and permissions changes. Its practical effect depends on the activities, permissions and sandbox status of the entity concerned.

Key provisions

Cryptoasset-specific MLR modification

Inserts a new Schedule Part 6 that disapplies selected MLR 2017 provisions tied to cryptoasset exchange and custodian-wallet concepts for activity within the DSS.

AML/CFT Mar 3, 2025 Source

Other AML obligations preserved

The modification is limited to cryptoasset-specific treatment. Other applicable AML/CFT obligations continue, and the MLRs continue to apply outside the DSS.

AML/CFT Mar 3, 2025 Source

Regulator allocation

Clarifies FCA and Bank of England responsibility as the appropriate regulator for specified ancillary financial market infrastructure activities.

Regulatory perimeter Mar 3, 2025 Source

Digital securities depository whistleblowing

Requires a digital securities depository to operate a scheme enabling employees to report actual or potential infringements connected with the DSS.

Market integrity Mar 3, 2025 Source

FSMA section 20 adjustment

Disapplies FSMA 2000 section 20 in specified DSS circumstances for authorised persons carrying on DSD FMI or ancillary FMI activities, and corrects a Schedule 17A modification.

Permissions Mar 3, 2025 Source

Timeline

  1. Regulations made

    HM Treasury made UKSI 2025/93 under the financial market infrastructure sandbox powers in the Financial Services and Markets Act 2023.

    Enacted Source
  2. Laid before Parliament

    The statutory instrument was laid before Parliament and published with an explanatory memorandum.

    Enacted Source
  3. Amendments entered into force

    All provisions of UKSI 2025/93 came into force across the United Kingdom.

    In force Source

Who it affects

Actors

Bank of England, Financial Conduct Authority, HM Treasury

Asset classes

Digital securities

Official sources

Editorial note

This profile covers UKSI 2025/93, the 2025 amending instrument, rather than the complete Digital Securities Sandbox regime. Read it with UKSI 2023/1398 and applicable Bank of England and FCA rules and guidance.