The Financial Conduct Authority's cryptoasset authorisation gateway opened at 7am on 30 September 2026 and closes on 28 February 2027. Firms that apply inside that window can keep serving UK customers after the regime starts on 25 October 2027 while the FCA finishes its assessment. Firms that apply later can still file, but the FCA will not speed up their review, and if they are not authorised by commencement they may only perform contracts they already have. Registration under the Money Laundering Regulations does not convert into the new authorisation, so every firm applies from the beginning. 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. Applications go through the FCA's Connect system. The regulator published an information document on the application form in July 2026, expanded it on 22 September, and issued an updated financial data template that every applicant completes.
Firms that apply inside the window benefit from the saving provision. The FCA expects to decide in-window applications before 25 October 2027. Where it has not, the firm can continue providing its cryptoasset services until the application is finally determined, including while a refusal is under appeal at the Upper Tribunal. In certain circumstances the FCA can instead direct the firm into the transitional provision. A firm relying on the saving provision notifies the FCA once the regime starts and again when it stops relying on it.
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.
Applying After 28 February 2027
A firm can still apply after the window closes. The FCA has said it will not expedite a late application to make up for the delay. If the firm is not authorised by 25 October 2027, it enters the transitional provision by operation of law while its application is determined. Inside the transitional provision the firm may carry on the new regulated activities only to the extent needed to perform contracts made before it entered. It cannot sign new contracts with new UK customers or with existing ones.
For a business that depends on onboarding, that status works as a run-off, so the February date carries more weight in planning than the October one.
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 FCA set out how the perimeter applies in Policy Statement PS26/18, published on 16 September 2026, which explains which activities require authorisation and where fact-specific exclusions apply, including to referral and introduction models. The guidance does not yet reflect the Government's latest changes: on 15 September draft amending regulations were laid before Parliament to add targeted exclusions and clarifications to the perimeter. Until they are made, firms near the edge of the perimeter should document their analysis against both texts.
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 Now the Window Is Open
The window is open, and five months is less time than it looks once incorporation, senior manager appointments and a full application pack sit on the same critical path.
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 opened at 7am on 30 September 2026 and closes on 28 February 2027. Applications go through the FCA's Connect system. 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?
Yes, on worse terms. The FCA will not expedite a late application, and a late applicant that is not authorised by 25 October 2027 enters the transitional provision. There it can only perform contracts it entered into beforehand and cannot take on new UK customers or sign new contracts with existing ones until the FCA decides.
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.
