The FCA crypto authorisation gateway opens at 7am on 30 September 2026 and closes on 28 February 2027. If you serve UK customers and have been filing the new regime under 2027 problems, that framing is now wrong. The question in front of you is not whether to apply. It is whether you can assemble a credible application inside a five-month window that starts next week.
The window matters more than the commencement date because of what sits on the other side of it. The regime is expected to come into force on 25 October 2027, and a firm that has not applied before then does not get a grace period. It runs off its UK book and leaves the market.
Does an existing licence carry you into the new regime?
No. The FCA states that firms already registered under the Money Laundering Regulations will still need authorisation under FSMA, and that "being registered under the MLRs does not guarantee authorisation under FSMA". There is no conversion route and no grandfathering.
Firms already authorised under FSMA apply to vary their permissions rather than submit a fresh application, but a variation is still an application and still has to clear the same standards. A permission you hold for an adjacent activity does not stretch to cover the new cryptoasset regulated activities. If your UK entity sits on an e-money or payments licence and has been bolting crypto services onto it, you are in the queue with everyone else.
What the transitional provision actually gives you
It gives you an exit, not a runway. Firms that applied before commencement but were refused or left undetermined get an exemption from the general prohibition, and that exemption reaches only as far as performing contracts entered into before the firm entered the provision. The FCA is blunt about the limit: firms in the transitional provision "will not be able to enter into new contracts with existing UK customers, or enter into new contracts with new UK customers". The maximum period is two years.
Read that against your revenue model rather than your compliance calendar. A book you cannot add to, cannot renew and cannot grow is a book you are managing towards zero. Firms that never apply at all are in a worse position again: the FCA expects an orderly run-off and exit from the UK market before the regime goes live, with unauthorised business risk for anyone who misses that.
Why the September publications close the argument
Perimeter guidance landed on 16 September 2026 as PS26/18, and it is the piece most firms were waiting on before deciding whether they are in scope. The rules themselves were finalised on 30 June 2026. The statutory instrument was made on 4 February 2026. Scope, rules and application route are now all published, and the form goes live in a week, so the sequencing has closed the last substantive reason to wait.
What to do this week
Settle scope against PS26/18 rather than against your own reading of the activity list, because the perimeter is where most firms will be wrong. If you already hold FSMA permissions, scope the variation now, since it competes for the same assessment capacity as every fresh application. Then file early. The FCA's own advice is to "apply as soon as possible within the application period to avoid disruption to your business", which is regulator phrasing for a queue that will lengthen.
Before committing, weigh the UK against the alternatives. Our UK crypto licensing profile tracks the regime field by field, the crypto licensing comparison sets it against other jurisdictions, and the UK e-money profile covers the adjacent payments permissions that will not carry you across.
Sources
- FCA, A new regime for cryptoasset regulation, last updated 22 September 2026
- FCA, Cryptoassets: The transitional provision
- FCA, What you need to do when preparing for the new cryptoasset regulatory regime
- FCA, PS26/18: Cryptoasset perimeter guidance, published 16 September 2026
This article is informational only and is not legal advice.