The FCA cryptoasset authorisation application period opened on 30 September 2026 and closes on 28 February 2027. The expanded regime commences on 25 October 2027.
These dates affect more than application scheduling. For existing crypto businesses, the timing and validity of an application can influence the legal arrangements available to continue services or run off UK business after commencement.
The FCA’s direction, issued under regulation 52 of the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, specifies an opening time of 9:00am on 30 September 2026 and a closing time of 11:59pm on 28 February 2027. fca.org.uk
Companies should plan for a reviewed, approved submission well before the closing date. They should also document what happens if their application remains pending, is withdrawn or is unsuccessful.
Is 28 February 2027 the Final Date Anyone Can Apply?
No. It is the closing date of the relevant application period, rather than an absolute prohibition on later applications.
The FCA permits applications outside that period. However, it will not accelerate assessment to compensate for late submission. Eligible existing firms applying later but before commencement may face restricted run-off arrangements if the necessary permissions have not been secured by commencement. FCA
For management, the distinction is commercially significant. An application may still be possible while the business’s continuity position changes materially.
Do not build a launch or growth forecast on the assumption that a late application preserves unrestricted operations.
Which Companies Should Assess the Application Window?
The window is relevant to businesses requiring permissions for the new cryptoasset regulated activities.
The FCA identifies trading platforms, intermediaries, custodians, qualifying stablecoin issuers and firms arranging staking among the affected models. The actual permission analysis depends on activities, assets, territorial scope and exclusions. www.fca.org.uk
The first task is therefore to establish the regulatory route.
| Existing position | Question requiring assessment |
| MLR-registered cryptoasset business | Which FSMA permissions will the operating model require? |
| Existing Part 4A-authorised firm | What variation of permission is needed? |
| Payment or electronic money institution | What is the entity’s precise status and required application route? |
| Overseas crypto company | Which activities in or to the UK fall within scope? |
| New entrant | What permissions are needed before the proposed launch? |
MLR registration does not automatically convert into FSMA authorisation. www.fca.org.uk
Saving Provisions and Transitional Run-Off Are Different
The terms “saving provision” and “transitional provision” should not be used interchangeably.
The saving arrangements concern qualifying circumstances in which services may continue while an application is finally determined. Transitional run-off provides a restricted basis for eligible businesses to perform existing contractual obligations and exit the market.
| Arrangement | Principal purpose |
| Saving provision | Continuation while an eligible application remains subject to determination |
| Transitional provision | Restricted performance of pre-existing contracts during orderly run-off |
| Authorisation or varied permission | Operating within the granted permission scope and conditions |
A company-specific assessment must establish eligibility, covered activities, restrictions and notification obligations.
What If an In-Window Application Is Still Pending at Commencement?
The FCA explains that the saving provision can allow qualifying continuation where an application submitted during the period has not been finally determined. Certain refusal-review circumstances are also addressed, and the FCA has powers to direct a firm into the transitional provision. FCA
Management should retain evidence of the submission and obtain a written assessment of its post-commencement position. It should not assume that every group entity, product or later expansion is covered.
What Does Transitional Run-Off Permit?
The transitional exemption covers the new regulated cryptoasset activities only to the extent necessary to perform qualifying pre-existing contracts.
It does not permit new contracts with existing UK customers or new UK customers. FCA
That restriction should be translated into operational controls. Account-opening screens, sales teams, transaction workflows and customer communications may all need changes.
What If the Company Does Not Apply?
The FCA states that firms which do not apply before commencement cannot rely on the saving or transitional arrangements described in its gateway guidance. They must complete the relevant UK run-off before commencement. Continuing without the required legal basis can engage FSMA section 19, or section 20 for an authorised firm acting without permission. FCA
A decision not to apply is therefore a business exit decision requiring its own timetable.
Management should identify:
- Customers and contracts affected;
- Assets requiring return or transfer;
- Outstanding trades and settlement obligations;
- Withdrawal and redemption constraints;
- Supplier dependencies;
- Communications and complaints arrangements; and
- Funding needed to complete the exit.
Can a Poor-Quality Application Protect Continuity?
Submitting something before a deadline is insufficient.
The FCA explains that an application rejected for failing to contain the minimum information, without a subsequent valid application, is treated as no application for these purposes. FCA
This creates a practical reason to prioritise submission quality.
An application should explain the business coherently, answer the applicable questions and support material claims. Missing information should be identified accurately rather than concealed behind generic policies.
Before submission, management should be able to explain:
- What the applicant does;
- Why the requested permissions match its functions;
- Who controls the business and customer assets;
- How it is funded;
- Which controls operate; and
- What remains dependent on future implementation.
How Should Companies Plan Backwards From the Deadline?
The strongest timetable starts with dependencies rather than a writing schedule.
For example, financial forecasts may depend on a settled product scope. Policies may depend on selecting monitoring tools. Custody documentation may depend on finalising wallet architecture and supplier contracts.
A useful preparation programme has five stages.
1. Confirm the Scope
Complete the activity, token and territorial assessment. Identify the applicant and requested permissions.
The FCA’s final perimeter guidance in PS26/18 supports the analysis of when cryptoasset activities require authorisation. www.fca.org.uk
2. Identify Submission Blockers
Review personnel, financial resources, contracts, technology and implementation evidence.
Distinguish a missing document from an unresolved operating arrangement. Drafting cannot substitute for appointing a responsible person or implementing a control.
3. Approve Resources and Responsibilities
The FCA encourages a board-agreed implementation plan with accountable owners, delivery dates and an assessment of preparation and ongoing compliance costs. www.fca.org.uk
Give each material task one accountable owner and measurable completion evidence.
4. Review the Exact Submission Pack
Check consistency across forms, forecasts, business plans, policies and customer terms.
Obtain management approval of the final versions and confirm portal access, submission authority and fee arrangements.
5. Prepare the Continuity Contingency
Plan for delayed determination, withdrawal, refusal and any required run-off.
The contingency should be funded, assigned and operationally credible before it is needed.
What Should a Business Continuity Assessment Cover?
A continuity assessment should connect the legal position to specific business actions.
| Area | Decision to document |
| Customer onboarding | Whether and when new accounts or contracts may be accepted |
| Existing services | Which functions may continue and on what basis |
| Product changes | Whether proposed launches or expansions are covered |
| Customer assets | How withdrawals, transfers and returns will be handled |
| Communications | What customers and counterparties need to be told |
| Suppliers | Which services must remain available during continuation or exit |
| Funding | Resources available for each scenario |
| Escalation | Who decides when the operating position must change |
The assessment should distinguish assumptions from confirmed conclusions and identify events requiring reassessment.
Notifications and Communications Also Matter
Eligible firms using transitional run-off have notification responsibilities to the FCA and parties to pre-existing contracts. Relevant customer information includes the firm’s status and material changes to asset protection, dispute mechanisms or compensation arrangements.
The FCA describes a maximum two-year run-off period, alongside restrictions on promotions and powers to alter or cancel the exemption. FCA
The maximum period should not be treated as a business-as-usual extension. Management should plan for prompt, orderly completion and check the applicable notification directions.
Current Compliance Remains Essential
The application window does not suspend existing requirements.
Businesses commencing current in-scope UK services must address MLR registration. Firms considering an MLR application after the FSMA gateway opened should review the FCA’s specific guidance and explain their plans through the appropriate pre-application channel. www.fca.org.uk
Financial promotions must also remain compliant throughout preparation. The existing regime reaches overseas firms marketing to UK consumers. www.fca.org.uk
Application readiness, current compliance and continuity planning should be managed together.
How CRYPTOVERSE Can Help
CRYPTOVERSE provides specialist legal and regulatory support for UK FCA cryptoasset authorisation.
Our support can include:
- Application route and permissions assessments;
- Readiness reviews and submission planning;
- Agreed business plans and compliance documentation;
- Evidence and consistency reviews;
- Saving and transitional eligibility assessments;
- Business continuity and run-off planning; and
- Regulatory correspondence support within the agreed engagement.
Assess your deadline and continuity position early. Request an FCA cryptoasset application planning consultation with CRYPTOVERSE.
FAQs
1. What is the FCA cryptoasset authorisation application deadline?
The relevant FCA cryptoasset authorisation application period runs from 30 September 2026 to 28 February 2027. Businesses should assess their permissions, prepare supporting documentation and submit a complete application within the applicable period.
2. Can a crypto business apply for FCA authorisation after 28 February 2027?
Yes. Applications may be submitted outside the relevant application period, but late submission can affect assessment timing and eligibility for transitional arrangements. Businesses should evaluate the implications before relying on a later application.
3. What is the difference between a saving provision and transitional run-off?
A saving provision can allow eligible firms with qualifying applications to continue certain activities while their applications are determined. Transitional run-off allows eligible firms to perform qualifying pre-existing contractual obligations on a restricted basis while exiting the relevant UK activities.
4. Can a crypto exchange accept new UK customers during transitional run-off?
No. The transitional exemption does not permit firms to enter into new contracts with existing UK customers or new UK customers for the relevant regulated cryptoasset activities. Firms should implement appropriate controls to manage onboarding and new contractual relationships.
5. Does submitting an FCA application guarantee permission to continue operating?
No. Submission does not guarantee authorisation or unrestricted continuation. The firm’s eligibility, application validity, regulatory status and applicable transitional conditions must be assessed before determining which activities may continue.