[email protected]
WhatsApp +44 7563 115980
Telegram @buckinghamcapital
The UK is replacing the anti-money laundering registration that crypto firms hold today with full authorisation under the Financial Services and Markets Act 2000 (FSMA). The FCA opened its application period on 30 September 2026 and it closes on 28 February 2027. Because 28 February 2027 is a Sunday, the practical last day to file through FCA Connect is Friday 26 February.
| Date | What happens |
|---|---|
| 30 June 2026 | FCA final rules and guidance published |
| 30 September 2026 | Application period opens |
| 26 February 2027 | Last working day to file inside the window |
| 28 February 2027 | Application period closes |
| 31 July 2027 | FCA says firms should not apply for MLR registration after this date |
| 25 October 2027 | New regime starts under SI 2026/102 |
On 8 November 2026 that leaves about 16 weeks. A complete application usually takes a well-organised firm three to four months to prepare, so a firm that has not started is already working to the deadline.
The legislation treats firms differently depending on when they applied. This is the single most important commercial reason to file by February.
| When you file | Position from 25 October 2027 if still undecided |
|---|---|
| Inside the window, by 28 February 2027 | Saving provision: continue the business, including new customers, until the FCA decides |
| After the window, before 25 October 2027 | Transitional provision: service existing UK customers only, no new UK business |
| No application | Wind down UK cryptoasset business before 25 October 2027 |
A firm relying on the saving provision must notify the FCA in the way the FCA specifies. The FCA has said it will try to decide window applications before the regime starts, but the saving provision protects firms whose decisions run beyond that date. Our guide to UK cryptoasset authorisation covers the regime itself in detail.
Any firm that will carry on a regulated cryptoasset activity in or into the UK from 25 October 2027 needs FCA authorisation. That includes firms already registered with the FCA under the Money Laundering Regulations (MLRs), firms that are not registered today, and overseas firms serving UK customers.
The FCA's information document lists modules by activity: trading platforms, custody, stablecoin issuance and firms dealing with retail clients each answer additional questions on top of the core application.
The Cryptoassets Regulations create new regulated activities, each a separate permission on the FCA register. A firm applies for each one it carries on, and the FCA assesses the controls for each.
| Activity | Typical firm |
|---|---|
| Operating a cryptoasset trading platform | Exchanges matching buyers and sellers |
| Dealing in cryptoassets as principal | Brokers and market makers trading on their own account |
| Dealing in cryptoassets as agent | Brokers executing customer orders with third parties |
| Arranging deals in cryptoassets | Apps and introducers bringing customers to trades |
| Safeguarding cryptoassets | Custodians and wallet providers holding customer assets |
| Issuing a qualifying stablecoin in the UK | UK stablecoin issuers |
| Arranging cryptoasset staking | Firms offering staking to customers |
Most retail-facing firms carry on more than one activity. An exchange with an app that holds customer coins usually needs the platform, dealing, arranging and safeguarding permissions together, and the business plan must show how each fits. Applying for too few permissions creates a gap; applying for too many brings controls the firm does not need.
The FCA published an information document on 17 September 2026 setting out every question in the application form. The core components apply to most applicants.
| Component | What the FCA looks for |
|---|---|
| Regulatory business plan | What the firm does, for whom and how each activity maps to a permission |
| Financial forecasts | Income statement, balance sheet and cash flow, with assumptions, usually three years |
| Capital | The permanent minimum requirement in place, not promised |
| Senior managers | Approval applications, statements of responsibilities and a responsibilities map |
| Controllers and close links | Ownership chain, controller forms and an organisational chart |
| Financial crime framework | Risk assessment, customer due diligence, monitoring, travel rule and sanctions controls |
| Compliance and complaints | Compliance monitoring plan and complaints policy |
| Records and IT | Records management policy and the FCA IT self-assessment |
| Wind-down plan | How the firm would close in an orderly way and return client assets |
Custody firms add their records, reconciliation and trust arrangements; stablecoin issuers add redemption and backing asset policies; platforms add their rulebook and market abuse framework. The regulatory business plan is read first and everything else must agree with it.
Capital is a threshold condition, which means the FCA must be satisfied it is in place when it authorises the firm. The permanent minimum requirement under the new prudential rules ranges from GBP 75,000 to GBP 750,000 depending on the activities, and firms also hold capital against their ongoing risks and their wind-down costs. A clear plan for sourcing the capital is acceptable at the start; the funds must be there before authorisation.
The Senior Managers and Certification Regime applies to authorised crypto firms. Each senior manager needs FCA approval, a statement of responsibilities and a place on the management responsibilities map. Candidates should be confirmed early, because a change of senior manager during the assessment restarts parts of it. Our explainer on SM&CR sets out the roles.
Under section 55V of FSMA, the FCA must decide a complete application within six months of receiving it, and any application within 12 months. The six month clock starts only when the application is complete, which is why the content of the first submission sets the timetable. The FCA has said it will reject applications that lack its minimum information and that poor-quality files face delay.
For a firm filing in February 2027, a complete application gives a statutory decision date around August 2027, before the regime starts. An incomplete one may run into 2028, protected by the saving provision but with the uncertainty that brings for banking partners and investors.
After filing, the case officer's questions usually arrive in rounds. They tend to focus on the same areas: whether the forecasts reconcile to the business plan and the capital calculation, how customer assets are segregated and reconciled each day, who in the firm is accountable for each control, and how outsourced services such as wallet technology or blockchain analytics are overseen. Answers that are complete and consistent with the original file keep the assessment moving. Building a question log and a single owner for responses before filing saves weeks later.
| Weeks | Work |
|---|---|
| 1 to 2 | Confirm permissions and modules; agree senior managers and controllers; engage the FCA's pre-application support service if useful |
| 3 to 6 | Regulatory business plan and three year forecasts; capital calculation and funding plan |
| 5 to 9 | Financial crime framework, compliance monitoring plan, complaints and records policies |
| 8 to 11 | Custody, stablecoin or platform modules where relevant; IT self-assessment; wind-down plan |
| 10 to 13 | Senior manager and controller forms; customer documents |
| 13 to 15 | Consistency review across every document; board approval |
| 16 | File through FCA Connect by Friday 26 February 2027 |
Firms that also need EU access should plan the MiCA side in parallel; our guide to MiCA CASP authorisation covers the EU process.
The window also matters to the firms a crypto business depends on. Banks providing operating and client accounts, card issuers, payment partners and liquidity providers will ask for evidence of the application and its status, and many will set their own cut-off for partners that have not applied. Investors will treat a filed, complete application as a milestone in their own due diligence.
Three pieces of evidence answer most partner questions: the FCA's acknowledgement of the application with its date, a summary of the permissions applied for, and the firm's plan for the saving provision notification. Firms should also expect partners to ask how customer assets are held during the transition, so the custody and reconciliation arrangements in the application should already be running in the business.
Where a firm cannot be ready by February, the better course is usually a narrower application filed on time, covering the activities that matter most, with further permissions added later by variation. A complete application for fewer activities is worth more than a late one for all of them. Our banking and payment processing team arranges operating and client accounts for crypto firms alongside the application.
Some groups will consider buying a firm that has already applied inside the window, or that is already authorised, rather than starting their own application. A change of control under FSMA needs the FCA's prior approval, and the target's position under the saving provision becomes part of the due diligence. Our guide to FCA change of control applications explains that process.
On 28 February 2027. That is a Sunday, so file through FCA Connect by Friday 26 February 2027.
If your application is still undecided on 25 October 2027, you may only service existing UK customers until the FCA decides. You cannot take on new UK business.
No. Registered firms must apply for authorisation like any other firm, and registration does not guarantee approval.
On 25 October 2027, under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102).
Section 55V of FSMA requires a decision within six months of a complete application and within 12 months of any application.
The permanent minimum requirement ranges from GBP 75,000 to GBP 750,000 depending on activities, alongside capital for ongoing risks and wind-down costs.
Yes, by variation of permission, filed in the same application period to benefit from the saving provision.
Get in touch: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or [email protected].
This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.
Tell us where you are and where you want to be.
[email protected]
WhatsApp +44 7563 115980
Telegram @buckinghamcapital