FCA cryptoasset authorisation

The new regime

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, made on 4 February 2026, bring cryptoasset activities within the FCA's remit. The regime is due to come into force on 25 October 2027. From that date a firm that carries on a cryptoasset regulated activity in the UK must hold a Part 4A permission covering it, in the same way as an investment firm or a payment institution. The FCA published its final rules and guidance on 30 June 2026 and its perimeter guidance, which explains when a given business model needs authorisation, on 16 September 2026.

Nine activities are regulated: issuing qualifying stablecoin in the United Kingdom; safeguarding qualifying cryptoassets and relevant specified investment cryptoassets; arranging for another person to safeguard them; operating a qualifying cryptoasset trading platform; dealing in qualifying cryptoassets as principal and as agent; arranging deals in qualifying cryptoassets; making arrangements with a view to transactions in them; and qualifying cryptoasset staking. A firm applies for a permission for each activity it carries on, and each permission has to be borne out by the business plan, the financial projections and the firm's systems and controls.

Who must apply

Registration under the Money Laundering Regulations does not convert into authorisation. A registered firm that intends to continue after October 2027 must apply for a Part 4A permission like any other applicant, and since the application window opened the FCA has encouraged firms to concentrate on authorisation rather than on registration. It has advised that applications for registration should not be made after 31 July 2027, as they are unlikely to be determined before the regime starts.

A firm that already holds a Part 4A permission for other business adds the cryptoasset activities by applying to vary its permission, within the same window and using the FCA's cryptoasset form for variation of permission applications. The saving and transitional provisions described below apply to a variation in the same way as to a new authorisation.

The regime applies to cryptoasset services provided in or to the UK, so it reaches firms established abroad that serve UK customers. For such a firm the first question is which entity will carry on the regulated activities and where it is established, and that should be settled before the application is prepared.

The application window

The FCA's application window opened on 30 September 2026 and closes on 28 February 2027. Applications are made through the FCA's Connect system. The FCA expects to determine applications made within the window before the regime comes into force; where it has not, a saving provision allows the firm to continue its cryptoasset 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. In that position it may carry on the activities only as necessary to perform contracts entered into beforehand, and it may not enter into new contracts with UK customers. A firm that does not apply at all must run off its UK cryptoasset business before the regime comes into force.

What the FCA assesses

The assessment follows the same threshold conditions as any Part 4A application, applied to a cryptoasset business. The FCA will want a clear account of the products, services and customer types, and an analysis showing which regulated activities each part of the business involves, so that the permissions sought match what the firm does. Where a firm safeguards client cryptoassets, the arrangements for key management and control, for keeping client assets separate from the firm's own, and for returning them if the firm fails are examined closely. Trading platforms are assessed on their order handling, their management of conflicts of interest, their admission and disclosure arrangements and their controls against market abuse.

Financial resources are tested against the prudential rules for cryptoasset firms, and the projections must show that the capital will be maintained as the business grows. The board and senior management must have the experience, the time and the oversight the business requires, and the individuals who will hold senior management functions apply alongside the firm. Financial crime controls, including transaction monitoring, sanctions screening and compliance with the travel rule for cryptoasset transfers, are reviewed in the same way as for a payment institution.

How we can help

We prepare the application as a whole, so that the business plan, the financial projections and the policies describe the same business and support the same permissions. The work comprises the analysis of the activities carried on and the permissions required; the regulatory business plan and the FCA's information document; the financial projections, the capital calculation and the FCA's financial data template; the policies and procedures covering conduct, custody, financial crime, operational resilience and wind-down; the applications for the individuals who will hold senior management functions; and the material for pre-application meetings with the FCA.

Our guide to what the application needs describes the process in more detail, and our note on the application window sets out the dates and the firms affected. For authorisation as a crypto-asset service provider in the EU, see MiCA CASP authorisation, or speak to us.