By CRYPTOVERSE Legal Consultancy
The cost of FCA cryptoasset authorisation extends beyond the application fee. A realistic budget must cover legal and regulatory preparation, implementation, staffing, technology, ongoing compliance and the financial resources required to operate the business.
There is no single total that applies to every crypto company. The amount depends on the applicant’s activities, permissions, existing controls, group structure and readiness.
For a founder or finance director, the practical question is:
What must our company spend, implement and fund to become—and remain—ready for the permissions we are seeking?
This article explains how to build that budget and assess professional fee proposals.
1. Separate the Main Cost Categories
Begin with five distinct categories.
| Category | What it covers | Budget treatment |
| Regulatory fees | Application fees and applicable ongoing fees or levies | Payments to the regulator or relevant scheme |
| Professional support | Legal analysis, application preparation and specialist advice | Project costs and any continuing retainers |
| Implementation | Systems, configuration, recruitment, testing and remediation | Initial expenditure, sometimes followed by recurring costs |
| Operating resources | Staff, technology, premises, providers and assurance | Recurring expenditure |
| Prudential resources | Eligible own funds and liquidity required by applicable rules | Financial resources maintained by the firm |
Regulatory capital is not an application fee. It supports the firm’s financial resilience and must be assessed separately from expenditure.
Keeping these categories distinct makes it easier to compare proposals and identify the funding actually required.
2. What Is the FCA Crypto Application Fee?
First identify the application route:
- Registration under the Money Laundering Regulations.
- A new FSMA authorisation application.
- A variation of permission by an existing FSMA-authorised firm.
The FCA’s current application fee page identifies cryptoasset MLR registration as Category 6, currently £11,260. That figure should not be presented as a universal fee for the expanded crypto FSMA authorisation regime. The relevant FSMA or variation fee needs to be established for the particular application. The FCA also states that application fees are non-refundable. FCA
For budgeting, obtain a fee assessment that records:
- The application route.
- The activities and permissions requested.
- The applicable fee provisions.
- Any relevant reduction or combined-application treatment.
- The tariff in force when submitting.
Avoid using historical MLR registration figures or consultation proposals as though they were the current payable fee.
Does requesting several permissions mean paying several full fees?
FEES 3.2.2G, effective from 30 September 2026, provides that where a Part 4A permission application falls within more than one relevant category, generally only the highest applicable fee is payable, subject to the provision’s qualifications. It also addresses simultaneous cryptoasset MLR registration applications. handbook.fca.org.uk
The calculation should therefore follow the applicable fee provisions rather than simply multiply a fee by the number of permissions.
3. Can MLR Registration and FSMA Authorisation Involve One Fee?
Some new firms may seek MLR registration to begin relevant business before the expanded regime starts, while also applying for FSMA authorisation.
The FCA explains that, where appropriate and with the firm’s confirmation, information submitted for FSMA authorisation can also be used for the MLR registration assessment. In that case, a single application fee applies: the higher of the MLR registration fee and the FSMA authorisation fee. The regulatory outcomes remain separate. FCA
This arrangement should be confirmed for the applicant’s circumstances.
It does not mean that:
- MLR registration automatically grants FSMA authorisation.
- An MLR application form becomes a FSMA application.
- Every firm pursuing the two routes at different times receives the same fee treatment.
4. What Determines Legal and Regulatory Support Costs?
Professional fees should reflect the work required to prepare and support the application.
The principal cost drivers commonly include:
Business complexity
More products, customer types, transaction structures and entities create more facts to assess and document.
Permission analysis
Uncertain token classifications, territorial questions or complex custody and execution arrangements may require substantial legal analysis.
Existing readiness
A firm with approved procedures, configured systems and reliable evidence may need a different scope from a business still selecting providers and allocating responsibilities.
Group arrangements
Shared technology, overseas management and intra-group services require a clear account of what the applicant controls and how it obtains necessary resources.
Assessment support
The engagement may include information requests, revised documents, management preparation and regulatory meetings—or may end at submission.
There is no reliable professional fee estimate without understanding these factors. An early scoping exercise can establish the required work and the assumptions behind a quotation.
5. Compare Professional Fees Against Defined Deliverables
A low headline fee may cover only a limited portion of the project.
Ask advisers to identify whether their quotation includes:
- Regulatory perimeter and permission analysis.
- A readiness and gap review.
- The regulatory business plan.
- Governance and responsibility documents.
- Policies and operational procedures.
- Financial information review.
- Application forms and supporting evidence.
- Consistency checks and submission support.
- Management interview preparation.
- FCA information requests and revisions.
Also clarify exclusions, third-party costs, taxes, revision limits and additional charges.
For example, “application preparation” may cover drafting documents while leaving system configuration, testing, forecasts and customer contracts to the applicant or other specialists.
A useful comparison asks:
What usable deliverables and support will we receive, and what work must we separately fund?
6. Budget for Implementation
Documents can describe arrangements that still need to be built, configured or tested.
Depending on the business model, implementation expenditure may include:
- Customer verification and screening systems.
- Blockchain analytics and transaction monitoring.
- Wallet security and signing controls.
- Reconciliation processes.
- Complaint handling and record keeping.
- Cybersecurity testing.
- Business continuity and recovery arrangements.
- Recruitment and staff training.
- Provider due diligence and contractual changes.
Supplier pricing may involve setup fees, minimum commitments, usage charges and additional charges for data or functionality.
For budgeting purposes, distinguish purchased, configured, tested and operational. A licence to use software does not establish that the applicant has implemented the controls it describes.
7. Budget for the People Who Will Operate the Business
A crypto authorisation budget should include the staffing needed to deliver the proposed services and maintain oversight.
Relevant functions may include:
- Executive management.
- Compliance and financial crime.
- Risk.
- Finance.
- Operations.
- Technology and security.
- Customer support.
- Assurance.
The appropriate structure depends on the business. Avoid assuming that every function requires a separate full-time employee, or that outsourcing automatically removes the need for internal expertise.
Calculate salary or service fees alongside recruitment, onboarding, training, cover and management time. Where staff support several group entities, document the allocation of costs and available capacity.
8. How Much Regulatory Capital Is Required?
The expanded regime’s final prudential rules use activity-dependent requirements.
Under CRYPTOPRU 4.2.1R, the permanent minimum capital requirement is the highest applicable amount in the activity table. Examples include:
| Permission | Permanent minimum capital requirement |
| Dealing in qualifying cryptoassets as principal | £750,000 |
| Issuing a qualifying stablecoin | £350,000 |
| Safeguarding cryptoassets | £150,000 |
| Arranging qualifying cryptoasset staking | £150,000 |
| Operating a qualifying cryptoasset trading platform | £150,000 |
| Dealing in qualifying cryptoassets as agent | £75,000 |
| Arranging deals in qualifying cryptoassets | £75,000 |
These are permanent minimum amounts, rather than a complete capital calculation. Under COREPRU 4.1.2R, the own funds requirement is the highest of the permanent minimum capital requirement, fixed overheads requirement and K-factor requirement. The final regime also addresses overall financial adequacy and liquidity. These rules are being prepared for the expanded regime commencing on 25 October 2027. fca.org.uk
A firm-specific calculation should assess the permissions, eligible capital instruments, applicable calculations and forecast position.
Do not assume that depositing the permanent minimum amount settles every financial resource requirement.
9. Avoid Double Counting Capital and Operating Cash
Capital, cash and expenditure interact, but they measure different things.
An equity injection may initially increase both cash and eligible own funds. Spending that cash can reduce resources, while operating losses can erode own funds.
A useful financial model should therefore track:
- Cash receipts and payments.
- Profit and loss.
- Eligible own funds.
- Required own funds.
- Applicable liquid assets.
- Headroom under adverse scenarios.
Adding “regulatory capital” and “working capital” together without examining the balance sheet can overstate or understate the funding need.
The objective is to fund operations while maintaining the resources required under the applicable framework.
10. Allow for Assessment Delays and Changes
Application-related expenditure can continue while the FCA assesses the submission.
A practical budget should consider:
- Staff and provider costs before launch.
- Further evidence requests.
- Revised legal analysis following business changes.
- Additional testing or remediation.
- Delayed revenue.
- Changes to launch sequencing.
- Contingency measures if the expected outcome is delayed.
Model alternative scenarios rather than relying on one assumed authorisation date.
Each scenario should identify the impact on cash, own funds and management decisions. Commercial contingencies should be realistic and documented, including who can approve them.
11. Include Ongoing Regulatory and Compliance Costs
The application fee is a one-off cost. The FCA’s general fee guidance explains that authorised firms also pay periodic fees. The applicable fee structure, tariffs and other levies should be checked for the relevant regime and fee year. FCA
The broader operating budget should also consider:
- Continuing compliance support.
- Monitoring and screening subscriptions.
- Training.
- Financial reporting.
- Control testing and assurance.
- Contract and policy updates.
- Cybersecurity and resilience work.
- Relevant insurance.
- Future permission changes.
These costs should appear in forecasts rather than be treated as expenses to address after authorisation.
12. Prepare an Applicant-Specific Cost and Funding Plan
The FCA expects financial information aligned with the whole legal entity seeking authorisation, rather than a portion of it. Its guidance also calls for supporting assumptions and financial forecasts; three years of forecasts is identified as best practice. FCA
A useful planning schedule is:
| Budget item | Amount or calculation | Timing | Supporting evidence |
| Application fee | Confirmed applicable tariff | Submission | Fee assessment |
| Professional support | Agreed scope and quotation | Project milestones | Engagement terms |
| Implementation | Setup, configuration and testing costs | Before relevant service begins | Supplier quotes and plans |
| Staffing | Salary and service commitments | Recruitment and operations | Staffing plan |
| Operating expenditure | Fixed and variable costs | Monthly | Contracts and assumptions |
| Own funds and liquidity | Applicable regulatory calculations | Required dates and ongoing | Prudential model |
| Contingency funding | Scenario-based requirement | If triggered | Funding arrangements |
Update the plan when products, permissions, providers, staffing or launch assumptions change.
How CRYPTOVERSE Can Support Your Budgeting
CRYPTOVERSE is a specialist legal and regulatory firm for UK FCA cryptoasset authorisation support.
We can help assess the application route, identify the required legal and regulatory work, review readiness gaps and develop a defined scope of application support.
This enables professional fees and implementation responsibilities to be assessed alongside the firm’s wider operating and funding plan.
Contact CRYPTOVERSE to discuss your proposed UK crypto activities and obtain a scoped proposal for FCA authorisation support.
FAQs
1. Is there a fixed total cost for an FCA crypto licence?
There is no universal total. The budget depends on the application route, activities, readiness, professional scope and operating requirements.
2.Is the £11,260 MLR registration fee the FSMA crypto authorisation fee?
No. It is the current Category 6 amount identified for cryptoasset MLR registration. The relevant FSMA or variation fee must be established separately. FCA
3.Are professional fees included in the FCA application fee?
No. Professional support is separately agreed with the adviser and should have a defined scope.
4.Is regulatory capital paid to the FCA?
It is a financial resource requirement maintained by the firm, subject to the applicable rules. It is distinct from the regulatory application fee.
5.What should we do before requesting a full quotation?
Provide the proposed business model, entities, customer types, existing permissions and current readiness. Where the route is uncertain, begin with a defined regulatory assessment.