UK Crypto License in 2026: How the FCA Authorisation Gateway Works
The Financial Conduct Authority opens its cryptoasset authorisation gateway on 30 September 2026 and closes it on 28 February 2027. After that window, firms cannot apply again until the new regime starts on 25 October 2027. Registration under the Money Laundering Regulations carries no weight in the new framework, so firms holding one apply from the beginning. Companies that skip the window face a choice between running off their UK cryptoasset business and operating without permission. Equilex advises on crypto licensing across jurisdictions and on where a business should hold its authorisations.
What Changes on 25 October 2027
Parliament made the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 in February 2026, bringing cryptoasset activities inside the FSMA perimeter. The FCA published its final rules and guidance on 30 June 2026 and confirmed the framework that will govern trading platforms, intermediaries, custodians, stablecoin issuers and firms arranging staking.
Since 2020 the UK has run a registration regime focused on anti-money-laundering compliance. That regime tested whether a firm could manage financial crime risk. The new framework tests the whole business: capital and financial resilience, custody and safeguarding controls, market abuse surveillance, operational resilience, senior management accountability, complaints handling and a credible wind-down plan.
From 25 October 2027, carrying on an in-scope cryptoasset activity in or to the UK without the right FSMA permission breaches the general prohibition in section 19 of the Act.
The Gateway Runs for Five Months
Part 7 of the Treasury's statutory instrument lets the FCA open an application period ahead of the regime. The FCA set that period to run from 30 September 2026 to 28 February 2027, and it published the application form content in July 2026 so firms could prepare.
Firms that apply inside the window may benefit from savings and transitional provisions, which allow them to keep serving customers while the FCA determines the application. Those provisions come with conditions attached. A firm keeps the benefit by meeting the conditions in the instrument, keeping its controls live and answering FCA queries while the assessment runs.
Many firms expected the FCA to open applications closer to the 2027 commencement date. The regulator moved the window forward instead, which compresses preparation time for anyone starting now.
MLR Registration Does Not Convert
The FCA has stated the position plainly: firms registered under the Money Laundering Regulations get no automatic conversion and must secure authorisation under FSMA. The same applies to firms already authorised under FSMA for payment services or electronic money, which apply for a variation of permission to add cryptoasset activities.
The MLR gateway continues to operate alongside the new one. A firm that wants to start trading in the UK before October 2027 still registers under the MLRs first. After 30 September 2026 the FCA expects firms to focus on the FSMA application, and it asks anyone who still needs an MLR registration to explain why through its Pre-Application Support Service.
Where a firm needs both, the FCA can treat the FSMA application as covering the MLR registration and charge a single fee, set at the higher of the two.
Which Activities Need Authorisation
The new regulated activities cover the core of the market: operating a cryptoasset trading platform, dealing and arranging deals in cryptoassets, safeguarding cryptoassets for others, issuing qualifying stablecoins and arranging staking.
The perimeter question decides everything else in the application, and firms that mapped their activities under the AML regime should test those conclusions again. A model that sat outside the MLR perimeter can sit inside the FSMA one, and the reverse also happens.
Two features of the framework catch firms that have only dealt with the AML regime. The first is the market abuse regime built for cryptoassets, which brings insider dealing and manipulation into scope and requires trading venues and intermediaries to run surveillance. The second is the prudential layer: firms hold regulatory capital calibrated to what they do, and they evidence financial resilience in the application itself.
The FCA also expects most applicants to operate through a UK legal entity, which affects group structure as much as licensing. Overseas groups serving UK customers from an offshore entity therefore face a structural decision before they face an application form.
What the FCA Expects in an Application
The regulator has set out what a complete application contains, and the volume of material tells firms how long preparation takes. Alongside the standard authorisation content, applicants provide their regulatory business plan, financial projections, governance and senior management arrangements, custody and safeguarding arrangements, financial crime controls, operational resilience and a wind-down plan.
The FCA runs a Pre-Application Support Service for firms that want to discuss their plans first, and it has said that firms must arrive with substance: the business model, the products, the customer types and the applicant's own analysis of which regulated activities it intends to apply for. A promise to supply detail later does not secure a meeting.
If you are working out whether your business needs UK authorisation, or where else it should hold licences, schedule a call with the Equilex licensing team to map your activities against the perimeter and compare the routes available to you.
What to Do Before the Window Opens
Five weeks remain before the gateway opens, and the work that decides the outcome happens now.
Start with the perimeter assessment and write it down. The FCA asks applicants for their own analysis of which regulated activities they intend to apply for, so the assessment becomes part of the submission itself.
Settle the entity question next, because incorporation, governance and senior management arrangements all follow from it. A group that decides in November to incorporate in the UK loses weeks it cannot recover inside a five-month window.
Then work through the gaps the AML regime never tested. Capital, custody and safeguarding, surveillance, operational resilience and the wind-down plan each need documentation that most firms do not have on hand. Firms that treat the application as a form-filling exercise discover these gaps in January, with six weeks left.
What Happens If You Do Not Apply
The FCA has been direct about the alternative. Firms that do not intend to apply run off their UK cryptoasset business before the regime commences. Continuing past commencement without permission puts an unauthorised firm in breach of section 19, and an authorised firm in breach of its permissions.
Running off a book takes planning. Customer communications, redemption of holdings, transfer arrangements and contractual notice periods all take time, and each of them lands on the same compliance team preparing everything else.
A third route exists for firms whose UK volumes do not justify the authorisation cost. They can move UK-facing activity to a group entity licensed elsewhere and serve other markets from there, accepting that the UK customer base goes with the wind-down. That decision belongs in the same analysis as the application, because the cost of authorisation only makes sense against the revenue it protects.
If the UK Is Not Your Only Market
A UK authorisation covers the UK. It carries no rights in the European Union, where serving clients requires a MiCA CASP authorisation from a member state after the transitional regime closed on 1 July 2026. Firms serving both markets hold both, and each application runs on its own timetable. The UK gateway closes in February 2027, while a CASP application in an EU member state follows that state's own review periods, so groups planning for both build two schedules and staff them separately.
For businesses reassessing their footprint, our guide to the best countries to get a crypto license in 2026 compares the main jurisdictions on cost, timeline and market access, and our analysis of the end of MiCA grandfathering covers the European position in detail.
FAQ
When does the FCA crypto application window open and close?
The gateway opens on 30 September 2026 and closes on 28 February 2027. The FCA set the period under Part 7 of the Treasury's statutory instrument, which requires the window to run for at least 28 days and to close at least 28 days before the regime commences on 25 October 2027.
Does my MLR registration convert into FSMA authorisation?
No. The FCA has confirmed there is no automatic conversion. Firms registered under the Money Laundering Regulations apply for authorisation under FSMA in the same way as new entrants. Firms already authorised for payment services or e-money apply for a variation of permission instead.
Can I still apply after February 2027?
Applications submitted after the window closes fall outside the transitional and savings provisions, and the FCA will determine them under the new regime once it starts. A firm in that position cannot rely on continuing to serve UK customers while its application is pending.
What happens if I decide not to apply?
You wind down your UK cryptoasset business before 25 October 2027. Carrying on regulated activity after that date without permission breaches the general prohibition in section 19 of FSMA. Run-off takes months in practice, because customer notice, redemptions and transfers all need lead time.
Do I need a UK company to apply?
The FCA expects most applicants to operate through a UK legal entity, so overseas groups usually incorporate locally before applying. The structure affects governance, senior management arrangements and financial resources, so groups settle it early in the process. Incorporation, appointing senior managers and opening operational accounts all take time that the five-month window does not leave spare.
