Why 'MiCA-approved' and 'FCA approved' fail: MiCA Article 7(1)(e)'s mandatory statement against the UK's GEN 1.2 pointer and the limits on registered firms.
Both regimes push the opposite way from the most common trust claim in crypto marketing. MiCA requires marketing to state that no competent authority reviewed or approved it. In the UK, a cryptoasset firm registered for anti-money-laundering purposes is pointed to the Handbook's rules on referring to FCA approval, and cannot itself approve anyone else's promotion.
| Question | European Union | United Kingdom |
|---|---|---|
| What the marketing must say about approval EU: a mandatory not-reviewed-or-approved statement. UK: GEN 1.2 (referring to approval by the FCA) and GEN 4.5 apply to registered persons. | Article 7(1)(e) No authority approved this. Say so. | COBS 4.1.7DG Registered is not 'FCA approved'. |
| Who can sign off a promotion EU: authorities may not require prior approval of ART or EMT marketing (Articles 29(4), 53(4)). UK: a registered person cannot approve a financial promotion; its own promotions travel on Article 73ZA. | Article 29(1) Marketing an asset-referenced token. | COBS 4.10.3G(8) · 4.10.9AR(4) A registered firm cannot approve anyone's promotion. FPO Article 73ZA The fourth route through Section 21. |
Every cell is a rule record with its primary source and the date it was read (4 November 2026). All records: MiCA rule records · FCA rule records.
General, sourced information for marketing teams — not legal advice. Where a campaign runs in both markets, check it against both columns.
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