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UK crypto application timing determines access to transitional business

The gateway opened on 30 September 2026. The 28 February 2027 application-window deadline affects the transition available before the full regime starts on 25 October 2027.

The FCA opened applications for the new UK cryptoasset regime on 30 September 2026. The main window closes on 28 February 2027, before the full regime begins on 25 October 2027. Application timing affects the conditions under which an undecided firm can continue operating after commencement.[1][3]

Each in-scope activity requires FSMA authorisation or the appropriate variation of permission. The application assesses governance, resources and activity-specific obligations; existing AML, payments, e-money or other financial-services status provides no automatic conversion.[2][1]

Key numbers01

The gateway timetable

The gateway timetable
MeasureValueContext
Applications opened30 September 2026Firms can submit authorisation or variation-of-permission applications.Source 1Source 3
Application-window deadline28 February 2027Applying within this window is necessary to rely on the main saving provisions, subject to conditions.Source 1Source 3
Full regime begins25 October 2027The expanded regulatory perimeter and rules commence.Source 1Source 2
Entities & regulation02

What changes under the full regime

What changes under the full regime
Earlier or existing statusWhat it establishesWhat the new regime additionally requires
Money Laundering Regulations registrationThe firm met the applicable registration and AML frameworkFSMA authorisation for each in-scope regulated cryptoasset activitySource 2
Financial-promotions complianceThe firm can communicate promotions under the applicable routePermission to conduct the underlying regulated serviceSource 2
Existing FSMA, payments or e-money authorisationThe firm has permission for existing regulated activitiesA variation or new permission where crypto activities fall inside the new perimeterSource 2

In-window and late applications have different transition rules

A qualifying in-window applicant may continue specified services, including new business where the saving provision permits, while its application is finally determined. The firm remains under assessment and may ultimately be refused.[1][3]

The FCA can also direct an in-window applicant into the narrower transitional provision in specified circumstances. Firms relying on the saving provision must notify the FCA as soon as reasonably practicable after commencement and again when reliance ends; notification directions will follow.[3]

A late applicant enters a narrower position if it is not authorised by commencement. The FCA describes a transitional provision in which the firm can perform regulated activities only as necessary for pre-existing contracts and cannot enter new contracts with existing or new UK customers. A firm that does not apply must run off its UK business before commencement.[3]

Event timeline03

Application timing and the operating consequence

Application timing and the operating consequence
Position at commencementBusiness consequencePractical preparation
Applied within the window; decision pendingPotential saving provision permits continued specified services, subject to conditionsComplete governance, financial and activity-specific evidence earlySource 1Source 3
Applied late; decision pendingTransitional provision can restrict activity to pre-existing contractsPlan to service pre-existing contracts only; no new UK contracts and no expedited application review.Source 3
Did not applyMust run off in-scope UK businessStop new activity and execute an orderly exit before commencementSource 3
Application refusedCannot operate the refused regulated service after applicable transition or appeal outcomePrepare for remediation, tribunal route or controlled exitSource 1Source 3

The perimeter is activity-based

The FCA’s September guidance names activities including issuing qualifying stablecoins, operating cryptoasset trading platforms, dealing or arranging deals, safeguarding cryptoassets and arranging staking. A brand that offers several services may need to map each function separately instead of treating “crypto firm” as one permission.[4]

For a brokerage using a crypto counterparty, the useful due-diligence record maps the contracting company to each service, its application timing and the permission or transition relied on. That service-level map shows which activities can continue and which customer relationships may be restricted at commencement.[4][3]

Follow the evidence

Sources & further reading

  1. FCA opens the gateway to regulated crypto Financial Conduct Authority · 30 Sep 2026 · Accessed 15 Oct 2026
  2. Overview of the cryptoassets regime policy statements Financial Conduct Authority · 30 Jun 2026 · Accessed 10 Oct 2026
  3. Cryptoassets: how the authorisation gateway will operate Financial Conduct Authority · Accessed 15 Oct 2026
  4. Crypto firms get guidance on how the new regime applies Financial Conduct Authority · 16 Sep 2026 · Accessed 10 Oct 2026

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