Crypto licence in the UK (FCA gateway)

The UK application window opens on 30 September 2026 and closes on 28 February 2027. After it, carrying on cryptoasset activities in or to the UK without FCA permission under FSMA will not be lawful — the new regime bites by 25 October 2027. Firms that file inside the window may benefit from transitional provisions while the FCA decides.

Why the date matters more than the fee

Most licensing decisions can wait a quarter. This one cannot. The FCA has set a fixed gateway: applications are accepted from 30 September 2026 until 28 February 2027, and firms already operating are expected to be inside it. Miss the window and you are not simply late — you are applying from outside the transitional shelter, with your UK activity in question while the file is assessed.

Five months sounds generous until you price the preparation. A full-scope application asks for senior management accountability, prudential resources, custody and safeguarding controls, market abuse surveillance where relevant, operational resilience and a credible wind-down plan. That is a documentation project.

What becomes a regulated activity

• dealing in cryptoassets as principal or as agent;
• arranging deals in cryptoassets;
• operating a cryptoasset trading platform;
• safeguarding — cryptoasset custody;
• issuing a qualifying stablecoin;
• arranging staking.

The perimeter is territorial in both directions: activity in the UK and activity to UK clients from abroad are both caught. An overseas exchange onboarding UK retail customers falls inside the regime.

MLR registration first, FSMA second

The anti-money-laundering registration with the FCA has existed since January 2020 and is not replaced on day one. In practice the FCA expects a firm to have its MLR position sorted before a FSMA application, and expects most applicants to operate through a UK legal entity. If you have neither, budget the first two months of the project for building them.

What the FCA actually assesses

• threshold conditions: legal form, location of offices, effective supervision, adequate resources, suitability, business model;
• senior managers and certification regime — named individuals with allocated responsibilities and statements of responsibility;
• prudential resources appropriate to the permissions sought;
• safeguarding of client cryptoassets and money: segregation, reconciliation, custody arrangements, key management;
• financial crime systems: onboarding, monitoring, sanctions, Travel Rule;
• operational resilience, outsourcing and incident reporting;
• consumer duty, financial promotions compliance, complaints and redress;
• an orderly wind-down plan that works without shareholder money.

Financial promotions are already regulated

Since October 2023, marketing cryptoassets to UK consumers has required an authorised person's approval, a risk warning and a cooling-off period for new customers. Firms often discover this only when a campaign is pulled. If you advertise to UK users today, that exposure exists today — independently of the FSMA gateway.

How we work on it

1. Perimeter review

We establish whether your activity is caught, which permissions you need and whether you must be a UK entity. Some models are better served from an EU MiCA authorisation — if that is your case, we will say so rather than sell you a UK file.

2. Entity, governance, people

UK company, board, senior managers with allocated responsibilities, fitness and propriety evidence, resourcing plan.

3. The application pack

Regulatory business plan, financial projections, safeguarding and custody policy, financial crime framework, operational resilience, consumer duty implementation, wind-down plan.

4. Filing inside the window

We file before 28 February 2027 and handle the FCA's questions through to determination.

5. After authorisation

Reporting, senior manager changes, permission variations, ongoing financial crime support.

Frequently asked questions

Is there a UK «crypto licence» I can buy today?

No. Until the gateway opens on 30 September 2026 there is no FSMA cryptoasset authorisation to hold. What exists today is MLR registration under the Money Laundering Regulations — an anti-money-laundering registration. The FSMA permission is a separate regime and opens with the window above.

What happens if we apply after 28 February 2027?

You may still apply, but outside the window the transitional provisions that protect firms awaiting a decision do not apply in the same way. For an operating business that is a materially worse position.

Do we need a UK company?

The FCA expects most applicants to operate through a UK legal entity, and the threshold conditions on location of offices and effective supervision point the same way.

We are an EU CASP — does MiCA cover the UK?

No. The UK is outside MiCA. A CASP authorisation passports across the European Economic Area and stops there; UK activity needs UK permission.

How much does it cost?

FCA application fees depend on the permissions sought and are set by the FCA's fee schedule. Our fee is quoted in writing after the perimeter review, because a custody and trading platform file is several times the work of an arranging-only file.

Reviewed: August 2026, against the FCA's final rules of 30 June 2026 and its published gateway timetable.