Who must apply
From 25 October 2027, when the regime is due to come into force, a firm that carries on any of the nine cryptoasset regulated activities in the UK requires permission under Part 4A of the Financial Services and Markets Act 2000. The activities cover stablecoin issuance, safeguarding, operating a trading platform, dealing, arranging and staking. The full list is on our page on FCA cryptoasset authorisation.
The position differs for three groups of firms. A firm registered under the Money Laundering Regulations must apply, because registration does not convert into authorisation. A firm that already holds a Part 4A permission for other business applies to vary that permission within the same window. A firm established outside the UK is within the regime if it provides cryptoasset services in or to the UK, and it should settle which entity will carry on the activities before it applies.
What to settle before applying
The FCA expects each firm to have a clear and credible plan for meeting the new requirements, and its published guidance describes the preparation it looks for. The firm should first establish which of the new regulated activities its business involves, using the perimeter guidance published on 16 September 2026, and then align the permissions it will seek with its business model and risk profile. A gap analysis against the requirements of the Act follows, covering market conduct, the treatment of customers and the standards expected of senior management. The FCA expects the resulting changes to be set out in an implementation plan agreed at board level, stating who is accountable, what needs to change, how the changes will be delivered and when they will be completed, together with an assessment of the resources and cost of preparation, authorisation and ongoing compliance.
The applicant entity, its ownership and the individuals who will hold senior management functions should be settled at this stage. Changes to any of them after submission are likely to delay the assessment.
What the application contains
The application is made through the FCA's Connect system. The FCA has published an information document, covering the standard sections of an application under the Act and the sections specific to cryptoasset firms, and a financial data template that every applicant completes. Firms that are already authorised use the FCA's cryptoasset form for variation of permission applications. The application must describe the firm's business model, its products and services and its customer types, with an analysis of each regulated activity it intends to carry on.
An application for Part 4A permission is supported by a set of documents that the FCA reads together: a regulatory business plan; financial projections and the capital calculation under the prudential rules for cryptoasset firms; the governance arrangements and the applications for the individuals who will hold senior management functions; information on the firm's controllers and close links; the policies and procedures, including custody and the safeguarding of client assets, conflicts of interest, financial crime, operational resilience and outsourcing; and a wind-down plan. Each permission sought must be supported consistently across them. The activities described in the business plan, the revenue in the projections and the controls in the policies should match.
Pre-application meetings
The FCA's pre-application support service offers optional meetings free of charge. A request must include information on the firm's business model, products and services and customer types, with an analysis of the regulated activities it intends to apply for. The FCA will reject a request that is not accompanied by meaningful supporting information, and a commitment to provide information later is not sufficient. The FCA does not give advice in these meetings, and a meeting does not guarantee a successful application.
After submission
Under section 55V of the Act, the FCA must determine a complete application within six months of receiving it, and an incomplete application within twelve months. During the assessment the case officer raises questions, and the firm's answers form part of the application. The FCA has stated that it expects to determine applications made within the window before the regime comes into force.
Timing
The FCA encourages firms to apply as early in the window as possible. A firm that applies by 28 February 2027 and has not been authorised when the regime comes into force may rely on the saving provision and continue its activities until the application is finally determined. The FCA has stated that it will not expedite the assessment of an application to compensate for its late submission.
A firm that applies after 28 February 2027 but before the regime comes into force, and is not authorised by then, enters the transitional provision while its application is determined. It may carry on the activities only as necessary to perform contracts entered into beforehand, and may not enter into new contracts with UK customers. A firm that does not apply must run off its UK cryptoasset business before the regime comes into force.
Why applications are delayed or refused
The FCA has set out the consequences of an application that is late or of poor quality: rejection where the minimum information is missing, delays in assessment, refusal of authorisation and, for existing cryptoasset firms, the inability to continue their activities once the regime is in force. An application that is complete and consistent on submission is assessed without the delay of repeated information requests.
How we can help
We prepare applications under the UK cryptoasset regime, including variations of permission for authorised firms and the supporting documents described above. See FCA cryptoasset authorisation, or speak to us. For the EU, see MiCA CASP authorisation.
Sources
- Financial Conduct Authority, Cryptoassets: how the gateway will operate
- Financial Conduct Authority, What you need to do when preparing for the new cryptoasset regulatory regime
- Financial Conduct Authority, Cryptoasset regulated activities: FSMA and the FCA Handbook
- Financial Conduct Authority, Registration under the MLRs ahead of the new FSMA regime
- Financial Conduct Authority, A new regime for cryptoasset regulation
Checked 13 October 2026.