On 30 September 2026, the FCA opens the application gateway for firms seeking permission to conduct the UK’s new regulated cryptoasset activities. The new regime itself starts on 25 October 2027. The more useful question for a business is therefore not simply “when can we apply?” but “what operating decisions must be settled before a credible application can be made?”
1. Map the product to regulated activities before mapping the legal entity
The first task is to describe what the product actually does. The FCA’s final perimeter guidance covers activities including issuing qualifying stablecoins, operating cryptoasset trading platforms, dealing or arranging deals, safeguarding cryptoassets and arranging cryptoasset staking.
For a cross-border firm, a useful internal map starts with user-facing functionality and follows the chain into the regulated activity. “We are a wallet” or “we are an exchange” is rarely precise enough for a permission strategy. Custody, execution, routing, staking and issuance can sit in different parts of the same customer journey.
2. Treat existing registrations and permissions as inputs, not substitutes
Existing status does not automatically convert into the new permissions. The FCA explicitly notes that firms already registered under the Money Laundering Regulations, authorised under the Payment Services Regulations or Electronic Money Regulations, or already authorised under FSMA may still need authorisation or a variation of permission for new regulated cryptoasset activities.
The practical implication is that a group should map existing permissions against the future activity model, rather than assuming a current licence creates a bridge into the new regime.
3. Build the application around the operating model, not around the form
The FCA has signalled that the application form will contain crypto-specific sections driven by the applicant’s business model. It also points firms toward the broader FSMA authorisation framework and minimum standards.
That means the evidence work is operational: governance, senior leadership, systems and controls, customer treatment, market conduct, financial resources and the suitability of the business model. A high-quality application should therefore be the output of a coherent operating model, not a substitute for one.
4. Decide whether the application window is strategically material
Timing matters most for firms that need to preserve continuity. The FCA says firms applying during the application period may, subject to the relevant conditions, be able to rely on saving or transitional provisions if their application is still being determined when the regime commences.
That makes the 30 September 2026 to 28 February 2027 window more than an administrative milestone. It can affect whether an incumbent business has a continuity path into the new regime.
5. Convert regulatory readiness into a product workplan now
The useful final output is not a legal memo saying that authorisation may be required. It is a workplan that identifies what has to change across product, governance and operations before the application is credible.
For example: which entity owns the regulated activity; where customer assets sit; what customer disclosures need to change; who holds senior responsibility; what controls evidence the desired customer outcomes; and which product features depend on permissions that the group does not currently have.
The authorisation question becomes much clearer when the business is described as a set of activities, dependencies and controls rather than as a brand or product category.
Takeaway
The UK gateway creates a useful forcing function. Firms considering the UK should work backwards from the intended product and customer journey, identify the regulated activities, map existing permissions, design the operating model and only then treat the application as a filing exercise.
This is particularly important for cross-border firms, because the same customer experience may be split across different legal entities, licences and operational owners in different jurisdictions.
Primary sources
- FCA — Cryptoassets: How the gateway will operate, updated 22 September 2026.
- FCA — PS26/18: Cryptoasset perimeter guidance, 16 September 2026.
- FCA — What you need to do when preparing for the new cryptoasset regulatory regime.
- FCA — Cryptoassets: Our standards.