The UK’s new cryptoasset regime is approaching. Here’s how to work out whether your business needs FCA authorisation and prepare an application that stands up to scrutiny.

The FCA’s application window for the new cryptoasset regime opens on 30th September 2026 and closes on 28th February 2027. The regime is expected to take effect on 25th October 2027.

If your business provides cryptoasset services in or to the UK, now is the time to pin down which activities are in scope, which permissions you need and what needs to change before you apply.

The FCA encourages firms to apply as soon as they’re ready within the window. That makes preparation important: an early application still needs to be complete, credible and supported by a business that understands its risks. Here’s what to work through.

Do you need FCA authorisation for your crypto activities?

Start with your business model. What does your firm actually do, where does it do it, and who are its customers?

The new regime brings a range of cryptoasset activities within the FCA’s regulatory perimeter. Whether you need authorisation depends on the activities you carry out and how the rules apply to your particular arrangements. If your firm is based outside the UK but serves UK customers, you’ll need to assess your position too.

Map each product and service against the FCA’s cryptoasset perimeter guidance. If the answer isn’t clear, it’s worth getting advice before you build an application around an assumption. This assessment shapes both the permissions you apply for and the requirements you’ll need to meet.

For a broader look at the activities and rules covered, read our guide to the UK’s new cryptoasset regime.

Does MLR registration carry over to FSMA authorisation?

No. If your firm is already registered with the FCA under the Money Laundering Regulations (MLRs), that registration doesn’t automatically give you permission to carry out the new regulated cryptoasset activities under the Financial Services and Markets Act (FSMA).

Your existing systems and controls may give you a useful starting point. You’ll still need to assess the additional requirements that apply to your business, including areas such as customer treatment, market conduct and senior leadership. If your firm is already authorised under FSMA, you may need a variation of permission to add cryptoasset activities to your existing permissions.

The practical question is: does your current regulatory position cover the business you plan to run when the new regime starts?

What should go into an FCA crypto authorisation application?

A strong FCA cryptoasset application should give the regulator a clear, consistent picture of your business. It needs to explain your proposed activities and permissions, how your business model works, the risks it creates, and the people and controls responsible for managing them.

The FCA’s preparation guidance recommends checking that your proposed permissions match your business model and risk profile, carrying out a gap analysis against the expected FSMA requirements, and developing an implementation plan agreed at board level. That plan should explain who is accountable, what needs to change, how you’ll make those changes and when the work will be complete.

As you prepare, ask yourselves:

• Can we explain each cryptoasset activity we carry out and why we need the permissions we’re seeking?
• Do our policies and procedures reflect how the business actually operates?
• Have we identified the main risks to customers and the business, and can we show how we manage them?
• Are the right people involved, with clear responsibilities and relevant experience?
• Can our leadership team answer questions about the application and the decisions behind it?
• Where work remains, do we have a realistic, funded plan to complete it?

Legal and compliance advisers can help you prepare and test the application. The people running the firm need to understand it too.

Who needs to be in place before you apply?

People are part of your authorisation plan. It’s worth addressing senior roles and accountability early, while there’s still time to fill gaps.

Identify who owns the application, who can explain each part of the business model, and where you need more legal, compliance or operational expertise. If some roles or changes will be completed later, set out when and how that will happen. The FCA asks firms to assess the resources and costs involved in authorisation and ongoing compliance, and to agree an implementation plan at board level.

When should you submit your application?

Aim to apply as soon as your application is ready within the window. The FCA encourages firms to apply promptly, but warns that a poor-quality application could be rejected for missing minimum information, delayed during assessment or ultimately refused.

The 30th September 2026 to 28th February 2027 application period is particularly important for firms with existing UK business. Depending on their circumstances, firms that apply during it may be able to continue providing services under a saving provision if their application hasn’t been finally determined when the regime begins. Firms that apply later face different restrictions, including limits on entering into new contracts while in the transitional provision. The FCA explains how the application gateway and these provisions work.

The detail matters here, and the position will depend on your firm’s circumstances. In particular, a new business shouldn’t assume that submitting an application gives it permission to start regulated activities while it waits for a decision.

Should you request an FCA pre-application meeting?

If you have questions about your proposed application, consider the FCA’s Pre-Application Support Service (PASS). Cryptoasset firms in the UK and overseas can request a free meeting to discuss their plans and ask questions before applying.

You’ll get more from the meeting if you arrive with a clear description of your activities, the permissions you think you need and specific questions for the FCA. PASS can help you understand the application process and the regulator’s expectations, although the FCA won’t give legal advice on your business.

Your FCA crypto authorisation checklist

If your firm intends to carry out regulated cryptoasset activities in or to the UK, these are the steps to take now:

1. Map your activities. Document what you offer, how each service works and whether you serve UK customers.
2. Assess the regulatory perimeter. Identify which activities may require FCA authorisation and which permissions fit your business model.
3. Confirm your application route. Work out whether you need a new FSMA authorisation or a variation of permission.
4. Carry out a gap analysis. Review your governance, people, policies, controls and customer arrangements against the relevant requirements.
5. Agree an implementation plan. Set owners, costs and realistic dates for the work needed before the regime begins.
6. Prepare a consistent application. Make sure the forms, regulatory business plan and supporting documents accurately describe the same business.
7. Leave time for questions and changes. Consider whether a pre-application meeting would help you resolve uncertainties before submitting.

How can a crypto regulatory lawyer help?

The new regime raises questions that can affect both your application and your wider business plans. A crypto regulatory lawyer can help you assess whether your activities fall within the FCA’s perimeter, identify the permissions you need, review gaps in your existing arrangements and prepare for engagement with the FCA.

It’s easier to act on that advice when you seek it early. If a product, customer journey or proposed activity needs changing, you want to know while there’s still time to make the change.

The application window is nearly here. Get clear on what your firm does and what the FCA will expect of it. From there, you can build an application that your team can explain and your business is ready to support.

Our fintech lawyers advise on cryptoasset permissions, regulatory mapping, governance and preparation for FCA engagement. If you’re getting ready for the UK’s new cryptoasset regime, get in touch with Founders Law.

‍