We help crypto businesses prepare for authorisation under the UK’s new cryptoasset regime. The process starts with identifying which regulated cryptoasset activities apply to the business model and continues through preparation of the application pack, submission planning, and support during FCA follow-up.
In the UK, the correct regulatory approach depends on the activities the firm plans to carry on.
The new regime captures a range of cryptoasset activities, including stablecoin issuance, safeguarding and custody, arranging safeguarding, operating a cryptoasset trading platform, dealing as principal, dealing as agent, arranging deals, and staking.
We help clients determine the correct regulatory perimeter, structure the application correctly, and prepare a submission that is complete, tailored, and aligned with FCA expectations.
The first step is to determine which regulated cryptoasset activities are in scope and whether the firm will apply as a new applicant or as an existing authorised firm seeking a variation of permission. The application should clearly describe the business model, target customers, use of custody, trading, staking, stablecoin issuance, principal dealing, outsourcing, branches, agents, and third parties.
Applicants need a clear legal and operational setup, genuine UK substance, appropriate governance, fit and proper controllers and senior managers, and a structure that allows effective FCA supervision. The FCA also expects clear reporting lines, accountability, oversight, and governance proportionate to the business model.
Applications need to address AML, CTF, sanctions, and Travel Rule compliance, as well as prudential, liquidity, operational resilience, cyber, incident management, business continuity, and wind-down arrangements. Depending on the model, the application may also need to cover safeguarding or custody, customer disclosures, financial promotions, complaints handling, market abuse controls, and activity-specific frameworks for trading, stablecoins, staking, or principal dealing.
The FCA expects a complete and internally consistent submission. The application should explain what the firm wants to do, who will manage it, and how the business will operate in practice, with appropriate governance, controls, risk management, and customer protection frameworks.
Advapay supports UK crypto authorisation projects from start to finish. We analyse the regulatory perimeter, help structure the business model, prepare the application documents, provide legal and compliance support, manage the project, and assist with FCA questions after submission.
We help clients prepare the core documentation required for a complete and consistent application, including governance, financial crime, prudential and operational materials.
Depending on the project, the application pack may include a regulatory perimeter memo, programme of operations, regulatory business plan, financial model and forecasts, prudential and liquidity materials, governance map, senior individuals and controllers pack, close links and qualifying holdings materials, AML/CTF/PF/sanctions and Travel Rule framework, security and incident documentation, outsourcing and third-party oversight materials, compliance monitoring programme, complaints and redress materials, financial promotions framework, and wind-down plan.
Where relevant, we also prepare activity-specific packs for custody and safeguarding, stablecoin issuance, trading venue operations, market abuse, staking, and principal dealing.
The FCA’s pre-application support for cryptoasset firms opens in July 2026. The application window is expected to run from 30 September 2026 to 28 February 2027, and the new regime is expected to come into force on 25 October 2027.
Existing MLR registration will not automatically convert into the new FSMA authorisation, so firms already operating in the UK crypto sector will still need to apply under the new regime.
We help you define the regulatory scope, prepare the documents, and manage the authorisation process from start to finish.
