UK Cryptoasset Regime: More Application Details Announced

(2 minute read)

Key takeaways:

• FCA announces more detailed application information
• The application window is 30 September 2026 – 28 February 2027
• Key FCA messaging:
  • Start preparing now
  • Apply as soon as you can
  • Applications will be considered "pragmatically", whilst maintaining high regulatory standards
  • Firms will need to demonstrate they are "ready, willing and organised"
• See www.ashurst.com/digitalassets for Ashurst's previous updates

25 October 2027 is the expected go-live date for the UK's cryptoasset regime (announced in December 2025). Since then, the FCA has been busy with its continuing preparations (e.g. CP25/40, CP25/41, CP25/42, A new regime for cryptoasset regulation, CP26/4 and GC26/2). The FCA has now filled in important missing detail on the application process.

The application gateway window will run from 30 September 2026 until 28 February 2027. This information was keenly awaited. It now gives intending applicants concrete dates to work towards. It is also important because of the saving and transitional provisions (see below).

Some key messaging from the FCA is for intending applicants to start their preparations now, and to apply as soon as they can once the gateway window opens. The FCA has confirmed that it is onboarding additional resource to ensure that it has sufficient bandwidth for cryptoasset applications, and that all relevant FCA staff will have appropriate training. The regulator is also encouraging early engagement, for example through the FCA's pre-application support service (PASS). PASS will be available to cryptoasset applicants from July 2026. Around the same time, the FCA will also publish the relevant application forms.

The FCA expects to determine applications made during the gateway window before the new regime goes live. If the FCA does not meet this timeline, the applicant firm will be able to provide cryptoasset services after go-live until its application is determined (the saving provision). In contrast transitional arrangements will apply to certain cryptoasset firms, such as firms which apply and are unsuccessful or withdraw their application before the new regime goes live. The transitional provision will permit them only to run-off existing business (for up to a maximum of 2 years) but not to conduct new business. The transitional provision will also be applicable to firms which apply outside the gateway window and their application is still pending at the go-live date - they will only be able to continue to service existing UK customers and cannot take on new business unless and until their application is successful. The transitional arrangements will not be available to firms which do not apply or are deemed to have not applied. Non-transition firms will need to complete an orderly run-off before the new regime is live.

The starting pistol for the UK's cryptoasset regulatory regime has been officially fired. Although the regime is still under consultation, intending applicants which have not already started preparations would be well-advised now to make this a priority.

For Ashurst's further updates and thought leadership visit www.ashurst.com/digitalassets.

Other author: Aleksandra Szram, Trainee Solicitor