The window, and what sits behind the closing date.

Four dates

None of them are ours.

The FCA published its final rules and guidance for the cryptoasset regime on 30 June 2026. Its press release of that date states that “Firms can apply for authorisation between 30 September 2026 and 28 February 2027”, ahead of a “mandatory regime which will come into force on 25 October 2027”. The FCA’s gateway page puts the same window slightly more carefully: “We expect the application period will open on 30 September 2026 and will close on 28 February 2027”.

The 25 October 2027 date is not only a page statement. It is in the legal text. Regulation 1 of SI 2026/102 sets full commencement at 25 October 2027, with earlier commencement for preparatory purposes including applications for permissions and approvals.

Every date on this page is published by the FCA or set out in the instrument, and linked where it is stated. None is a date we have promised anyone.

The window in law

The FCA had to set a window. It did not have to set this one.

The window is not an FCA convention. It is a duty in Part 7 of SI 2026/102. Regulation 52(1) requires that, not later than one year before full commencement day, the FCA must by direction specify an application period. Regulation 52(2) sets two boundaries on what that period may be. It must run for at least 28 days. Its last day must fall at least 28 days before full commencement.

Read against 25 October 2027, the statutory minimum is a 28-day window ending on 27 September 2027. What the FCA has scheduled instead is a period of about five months, closing just under eight months before commencement. That is considerably more generous than the instrument obliges, and it is worth knowing which part of the timetable is law and which part is the regulator’s choice.

Two further provisions are easy to miss. Regulation 52(3) lets the FCA amend or replace the direction for the purpose of extending the period. And regulation 52(5) states plainly that a direction “does not prevent applications for a relevant cryptoasset permission being made outside the relevant application period”.

Inside the window

The saving provision: carry on while the FCA decides.

Regulation 53 of the instrument applies to a firm that applied during the application period where the application has either not been determined, or has been refused but is still open to review. For the activity that application relates to, that firm “is to be treated as if Parts 3 to 6 of these Regulations had not come into force”.

There is a third condition, and it is easy to read past because it is drafted as a negative. Regulation 53(1)(c) applies the saving provision only where the firm is not subject to a direction by the FCA under regulation 55(3) putting it into the transitional chapter instead. The saving provision is therefore the default for a firm that applied in time, not a guarantee it cannot be moved out of.

In practice that is the difference between trading and not trading on 25 October 2027. The firm carries on its cryptoasset business while the FCA works through its file. The FCA describes the same effect from its own side: where a firm applies during the application period, “we will expect to determine its application before the new regime commences”. The saving provision is the safety net for the cases where that expectation is not met.

Regulation 51 defines “open to review” tightly. It covers a refusal where the period for a reference to the Tribunal is still running, a reference not yet dealt with, an appeal period still running, or an appeal brought and not yet determined. Regulation 53(3) closes the chapter two years after full commencement.

Outside the window

The transitional provision is a wind-down, not a licence.

Miss the window and the fallback is regulation 56. It is a narrower thing than its name suggests. The exemption from the general prohibition applies “solely to the extent necessary for the performance of a pre-existing contract”, and a pre-existing contract is “a contract entered into before the relevant day”. The FCA states the commercial consequence without softening it:

Everything else follows from that. The FCA states that the transitional provision “will allow firms to wind down their remaining UK business over a maximum two-year period”, which matches regulation 55(9). Financial promotions are cut back to the same perimeter: regulation 60 rewrites section 21 of FSMA so that only a communication necessary for the performance of a pre-existing contract is permitted.

There are notifications, and they run in two directions. Regulation 57 requires the firm to tell the FCA it is relying on the exemption as soon as reasonably practicable, and to tell the FCA again when it has stopped. Regulation 58 requires the firm to notify every counterparty to a pre-existing contract that it is an exempt person and “is not authorised by the FCA in relation to the carrying on of that activity”, and to notify them of any material change in the protection afforded to assets, the mechanisms for resolving disputes, or compensation schemes.

The exemption is also revocable. Regulation 59 lets the FCA cancel it or attach conditions, including an earlier final day. Regulation 61 applies the FSMA information-gathering powers, including skilled persons reports, as though the firm were authorised. Regulation 62 lets the FCA publish the fact that a firm is relying on it. Regulation 63 lets the FCA publicly censure a firm that fails to comply with the notification requirements in regulation 54 or regulation 57.

One point is genuinely useful and is easy to read past. A firm that applies after the window closes but before commencement still lands in the transitional provision. The FCA puts it this way: such a firm “will at the point the new regime goes live, enter the transitional provision (by operation of law) while their application is determined”. A firm that does not apply at all gets nothing. In the FCA’s words, firms that do not apply before commencement “will not be eligible for the transitional provision” and must run off their UK cryptoasset business before the regime starts.

The difference, stated once

Three outcomes, and only one of them is a business.

1. Applied in the window

   Regulation 53. Treated as if Parts 3 to 6 had not commenced, for the activity applied for. New customers, new contracts, ordinary trading, while the FCA determines the application.

2. Applied outside it

   Regulation 56. Exempt only to the extent necessary to perform contracts entered before the relevant day. No new contracts with new or existing UK customers. Promotions limited to the same purpose. Two years, maximum.

3. Did not apply

   Neither. The FCA states that a firm in this position is not eligible for the transitional provision and must run off its UK cryptoasset business before the new regime commences.

There is a fourth case, and it is the one worth dwelling on, because it turns a quality problem into a date problem. The FCA states that firms which submit an application that is rejected — and it defines rejected as “it does not include the minimum information we ask for” — and which do not subsequently submit a valid application “will be considered as not having applied”. An incomplete application filed on the last day of the window is not, on that wording, an application. This is why the component map in the next section is a scheduling document as much as a compliance one.

Regulation 55 also catches two cases inside the window that fall out of the saving provision: an application refused and no longer open to review, and an application withdrawn. Both drop to regulation 56. On the face of the instrument, then, withdrawing an application in this regime is not a neutral act.

What an application contains

The FCA has published the component map. Most firms have not read it.

On 8 July 2026 the FCA published Information about the authorisation application form for cryptoasset firms. It runs to 68 pages and sets out, section by section, what an applicant supplies. Page 2 carries the full component map. The FCA states that the form itself will be available through its online system from 30 September 2026, that the document is provided on a best-endeavours basis and is not guidance, and that while the structure and content are not expected to change, question wording may.

The map splits in two. There are sections every applicant completes. Then there are blocks driven by the activities applied for.

1. Every applicant

   Application Details. Firm Details. Trading Arrangements. Senior Managers. Controllers. Close Links. Organisational Structure. Permissions. Regulatory Business Plan. Fees. Financial Promotions. Financial Forecasts. IT Self-Assessment and IT Controls. Disclosure of Significant Events. Compliance, Financial Crime. Compliance Monitoring Plan. Complaints Policy. And, marked for cryptoasset firms only, a Cryptoasset Records Management Policy.

2. Stablecoin

   Seven sections, covering the firm’s stablecoins, redemption policy, disclosures, backing asset policy, use of third parties for backing assets and for issuing, and expanded backing assets.

3. Safeguarding

   Four sections: records and reconciliations, proof of safeguarding trust, third-party custodian policy, and means of access.

4. Staking

   Two sections: staked qualifying cryptoassets, and retail client understanding.

5. Lending, borrowing

   Two sections: borrowing and collateral management, and consumer understanding.

6. Intermediaries

   Four sections: admission and execution policy, order handling and execution, dealing as principal, and personal account dealing.

7. Trading platforms

   Eleven sections, from market making policy and platform access through market abuse detection, algorithmic trading, admissions criteria and post-trade transparency.

The worked example at page 11 of that document shows one permission combination resolving to 12 question sets and 18 supporting documents. The FCA marks that screen as illustrative, and says the questions included depend on the answers given earlier, so treat the two numbers as the shape of the thing rather than as a quota. It is also relevant to firms already authorised under FSMA, because a variation of permission runs through the same map.

What the FCA asks for now

Six things, in the regulator’s own words.

The FCA’s page on preparing for the regime sets out what it expects firms to be doing at this point. It is short enough to quote rather than summarise.

There is also free help on offer, and a condition attached to it. The FCA describes a pre-application meeting as “optional and free of charge”, offering “an opportunity for firms to introduce and explain their business model, discuss the authorisation process and understand our expectations”. It then says it will “reject requests for pre-application meetings that aren’t accompanied by meaningful supporting information”.

Six FCA webinars sit between now and the opening. The regime page lists them: admissions, disclosures and the market abuse regime on 7 September 2026; UK stablecoin issuance on 11 September; regulated cryptoasset activities on 15 September; applying the FCA Handbook on 18 September; getting authorised on 22 September; and the prudential regime on 29 September. That page was last updated on 24 July 2026.

What this is not

This is not advice.