By CRYPTOVERSE Legal Consultancy
A strong response to an FCA crypto information request answers the question directly, supports material statements with evidence and explains any changes to the application. Where the request exposes a genuine weakness, the firm must address the underlying arrangement as well as the wording of its response.
Receiving questions does not, by itself, mean an application will be refused. The FCA’s general authorisation guidance explains that it commonly seeks clarification and expects applicants to respond proactively, openly and honestly. FCA
For founders and compliance teams, the challenge is coordinating accurate answers across legal, finance, operations and technology without creating contradictions.
This guide sets out a practical method for managing FCA crypto application questions.
What Is an FCA Information Request?
During assessment, the FCA may request explanations, documents or evidence concerning the applicant and its proposed business.
“Request for information” or “RFI” is a convenient project-management description. The actual correspondence determines what is required, the deadline and the relevant procedural context.
Requests may concern the business model, permissions, ownership, personnel, resources, controls or activity-specific arrangements. These subjects also appear in the FCA’s published cryptoasset application information. www.fca.org.uk
First identify whether the request relates to MLR registration, new FSMA authorisation or a variation of permission. Do not import assumptions about one route into another.
1. Preserve the Request and Establish Its Scope
Retain the original correspondence, attachments, reference number and deadline.
Read each question carefully. Identify whether it asks the firm to:
- Explain an arrangement;
- Supply a missing document;
- Demonstrate implementation;
- Reconcile inconsistent information;
- Amend the application; or
- Address a stated regulatory concern.
Separate multi-part questions into individual tasks while retaining the FCA’s original numbering.
Practical output: A response tracker that allows every request to be traced to its answer and evidence.
| FCA reference | Information requested | Owner | Evidence needed | Deadline | Status |
| Q1(a) | [Request] | [Name] | [Records] | [Date] | [Status] |
| Q1(b) | [Request] | [Name] | [Records] | [Date] | [Status] |
2. Identify the Question Behind the Question
A request for a policy may reflect uncertainty about how the control operates.
For example, “Explain your transaction monitoring arrangements” may require information about risk coverage, system settings, investigation responsibility, escalation and oversight.
Do not assume an underlying concern that the FCA has not expressed. Use the wording and application context to identify what needs clarification.
Where the request is genuinely ambiguous, seek a focused clarification through the agreed channel. Explain precisely which point needs interpretation.
3. Assign Answers to People Who Know the Facts
Legal advisers can organise and review responses, but factual input should come from the relevant subject owners.
| Subject | Input typically needed |
| Permissions and classification | Regulatory counsel and product leads |
| Governance and ownership | Management and corporate records owners |
| Forecasts and funding | Finance lead and relevant advisers |
| Financial crime controls | Compliance and MLRO |
| Wallet and technology controls | Technology and operations |
| Supplier arrangements | Contract owner and oversight lead |
Nominate one coordinator to maintain versions and consolidate the pack.
Management should retain responsibility for business decisions and factual confirmations.
4. Use a Direct Answer Structure
A practical response format is:
- Answer: State the position clearly.
- Explanation: Describe how the arrangement works.
- Evidence: Identify the supporting document and location.
- Changes: Explain relevant corrections or amendments.
- Outstanding work: State limitations, owners and completion dates.
Illustrative Example
Question: Who can authorise transfers from customer wallets?
A weak answer would be:
“We use secure institutional custody technology.”
A more useful answer would explain which entity controls the relevant credentials, who initiates and approves transfers, the applicable threshold, and how access changes are authorised. It would identify the supporting procedure and testing evidence.
The answer must reflect the actual architecture. Do not supply credentials or private keys.
5. Match the Evidence to the Statement
A policy demonstrates a documented procedure. It does not necessarily prove implementation.
| Statement | Supporting evidence to consider |
| Monitoring is configured | Settings, rationale and testing |
| Alerts are investigated | Anonymised case records |
| Funding is available | Financial records and executed commitments |
| Oversight operates | Reports, decisions and escalation records |
| Recovery arrangements are tested | Exercise results and remediation |
| Asset records reconcile | Reconciliation records and exception handling |
For MLR registration, the FCA expects a framework tailored to the cryptoasset business and relevant operational information. www.fca.org.uk
Provide evidence relevant to the request. Avoid overwhelming the response with unrelated attachments.
6. Explain Financial Information Precisely
Where questions concern forecasts, distinguish assumptions, historical results and committed funding.
Explain the calculation, its source and the relevant entity.
The FCA states that financial information must align with the legal entity seeking authorisation and include supporting assumptions. www.fca.org.uk
If a forecast changes, explain why and identify affected application materials.
A revised staffing budget, for example, may require corresponding changes to the business plan and resource assessment.
7. Correct Inconsistencies Openly
If earlier information was inaccurate, identify the correction and its consequences.
A clear correction should state:
- What the previous submission said;
- What the accurate position is;
- Why the discrepancy arose;
- Which documents are affected; and
- What has been done to prevent recurrence.
Distinguish correcting an error from changing the proposed business model.
Do not silently replace a document while leaving the explanation inconsistent with the submission history.
8. Address Genuine Gaps With Verified Remediation
Some requests reveal more than missing information.
Examples include an untested control, unclear supplier responsibility or unresolved financial commitment.
In those cases:
- Define the deficiency;
- Assign an accountable owner;
- Implement the required change;
- Verify completion; and
- Explain the result with evidence.
Where work remains incomplete, say so. Explain its effect on readiness and propose a credible timetable.
The FCA warns that applicants cannot rely on willingness to improve a poor application later as a substitute for adequate preparation. FCA
9. Keep Every Affected Document Consistent
An answer can resolve one question while creating another inconsistency.
Before sending, compare the response with:
- Application forms;
- Regulatory business plan;
- Financial forecasts;
- Customer terms;
- Policies;
- Supplier agreements; and
- Technical descriptions.
For example, changing the custody model may affect the permission analysis, customer disclosures, transaction diagrams and operating costs.
The FCA’s perimeter guidance should inform reassessment where the activities or arrangements change. www.fca.org.uk
Use a change log identifying the document, version, amendment and reason.
10. Manage Deadlines and Extensions Early
Record external deadlines and set earlier internal review dates.
Where a response cannot be completed on time, raise the issue promptly. Explain:
- What can be delivered;
- What remains outstanding;
- Why additional time is needed;
- The proposed delivery date; and
- The steps being taken.
An extension request should not assume agreement. Preserve the FCA’s response and update the tracker.
The FCA expects proactive provision of information and staff availability during assessment. FCA
What Should the Final Response Pack Contain?
A practical pack usually consists of:
| Component | Purpose |
| Cover correspondence | Identify the application, request and response scope |
| Numbered response schedule | Answer each question in the original sequence |
| Evidence index | Link answers to attachments |
| Revised documents | Provide updated materials where required |
| Change log | Explain amendments |
| Outstanding-items schedule | Record any agreed follow-up |
Follow the requested format and submission channel.
Use clear filenames, searchable documents and precise section references. Sensitive records should be handled through the agreed secure process, with proportionate redaction explained where relevant.
Review and Approval Before Sending
The coordinator should confirm that:
- Every question and sub-question is answered;
- Factual owners have verified their input;
- Evidence supports the statements;
- Changes are explained;
- Versions are consistent;
- Required management approvals are obtained; and
- The sender has authority to communicate for the applicant.
Retain the exact response and attachments sent.
Protect the Application’s Wider Position
A request may affect readiness, application strategy or business continuity.
If management considers withdrawal or a major restructuring, assess the consequences before acting. The FCA’s saving and transitional guidance distinguishes different application circumstances and operating restrictions. www.fca.org.uk
An information request is not itself a reason to withdraw. Equally, changing wording cannot resolve a model that requires substantive redesign.
How CRYPTOVERSE Can Help
CRYPTOVERSE provides specialist legal and regulatory support for UK FCA cryptoasset authorisation.
Our support can include analysing requests, coordinating subject-owner input, reviewing evidence, preparing agreed responses and checking consistency across the application.
Received FCA questions about your crypto application? Request a response and evidence review from CRYPTOVERSE.
FAQs
1. What is an FCA crypto application request for information?
An FCA crypto application request for information is a request for clarification, documents or supporting evidence during the regulatory assessment process. It may cover the applicant’s business model, permissions, ownership, financial resources, governance or compliance controls. The applicant should follow the specific questions, deadlines and submission instructions provided by the FCA.
2. Does receiving an FCA information request mean my crypto application will be rejected?
No. Receiving questions does not automatically mean an application will be rejected. The FCA may need additional information to understand the proposed business or assess whether the applicant meets the relevant requirements. Responding accurately, addressing identified concerns and providing appropriate evidence can help clarify the application.
3. How should a crypto company respond to an FCA information request?
A crypto company should answer each question directly, explain the relevant arrangements, reference supporting evidence and identify any necessary changes to the application. Factual responses should be verified by the responsible teams, such as legal, finance, compliance, operations or technology. The final response should be consistent with the submitted application documents.
4. What evidence should be provided in an FCA crypto application response?
The evidence depends on the FCA’s request. It may include policies, financial forecasts, funding records, governance documents, transaction diagrams, supplier agreements, system testing results and control records. Each attachment should support a specific statement, with clear filenames and references to the relevant sections.
5. What should a crypto company do if it cannot fully answer an FCA request by the deadline?
The company should assess the outstanding information promptly and contact the FCA through the appropriate channel before the deadline where possible. It should explain what remains incomplete, why additional time is needed, what work is underway and when it expects to respond. Any extension must not be treated as approved unless the FCA confirms it.