UK Crypto Authorisation Opens on 30 September. Is Your Business Ready?

Three dates to build your plan around

Sources: FCA regime overview and application gateway.

For a founder planning a product launch, fundraising round or UK expansion, these dates belong in the operating plan. Hiring, systems implementation and changes to partner arrangements all need time before an application can accurately describe them.

What your existing registration actually covers

The FCA makes an important distinction: registration under the Money Laundering Regulations does not automatically convert into authorisation under the Financial Services and Markets Act.

An existing FSMA-authorised firm seeking to undertake the new regulated activities will need the relevant variation of permission. Payment and e-money firms should also assess which crypto permissions their model requires.

Current MLR registration obligations continue before the new regime starts. Submitting a new application does not, by itself, authorise a business to launch activities it cannot currently perform.

Sources: FCA gateway guidance and MLR registration ahead of the new regime.

A useful starting exercise is to list each service beside the entity delivering it and its current regulatory basis. Any unexplained gap deserves attention before the application.

Start with what the product does

Labels such as “crypto payments”, “wallet” or “infrastructure” leave important questions unanswered.

Does the business control customer assets? Execute or arrange transactions? Operate a trading platform? Issue a qualifying stablecoin? Arrange staking?

The FCA's guidance published on 16 September addresses these areas. The answer for a particular business depends on its activities and the applicable definitions and exclusions.

Consider a hypothetical app that lets customers hold tokens, exchange them and send funds to a bank account. Its permissions analysis should explain who performs each step, which entity contracts with the customer and where third-party providers take responsibility.

That map also helps identify mismatches between the website, customer terms, business plan and actual transaction flows.

The application date can affect your ability to grow

The designated window matters beyond administrative convenience.

The FCA explains that qualifying firms applying during it may benefit from a saving provision if their applications remain undetermined when the regime begins. Conditions and FCA powers still apply.

A firm applying after the window, without the required permissions at commencement, may instead enter the restricted transitional arrangement while its application is assessed. Eligible firms can perform pre-existing contracts, but cannot enter new contracts with existing or new UK customers. The arrangement also provides for orderly runoff where authorisation is not secured.

Applications rejected for missing the minimum required information, without a subsequent valid submission, are treated as no application.

Sources: FCA gateway and transitional provision.

A growth forecast built on new UK customers needs a regulatory timetable that supports it.

Five questions to answer before submitting

The FCA asks firms to assess their intended permissions, identify gaps and prepare a board-agreed implementation plan. Its standards also address the suitability of the business model, effective supervision, resources and the fitness of relevant people.

Sources: FCA preparation guidance and minimum standards.

Use the following as a practical founder's checklist:

• Can we explain every step of a customer transaction? Map the contracting entity, asset movements, decision-making and provider responsibilities.
• Can we justify the permissions we intend to request? Connect each permission to a real service and identify assumptions requiring specialist advice.
• Who owns each operational responsibility? Name accountable people for compliance, customer issues, technology and oversight of outsourced services.
• Does the budget match the operating model? Include preparation, staffing, systems and ongoing obligations—not just an application fee.
• Does our evidence agree? Reconcile the business plan, ownership records, policies, contracts and public descriptions of the service.

These questions help turn preparation into specific decisions, documents and assigned responsibilities.

Bring banking partners into the preparation

As a practical planning step, discuss your intended activities with relevant banking and payment providers early.

Ask which entity they would onboard, which customer types and flows they can support, and what regulatory evidence they will require at each stage.

Keep the answers separate from the authorisation analysis: a provider's willingness to assess an application is its own decision, and regulatory approval should never be presented as a promise of banking access.

For example, an account discussed for the company's own operating expenses should not be assumed suitable for handling customer funds. Describe the intended use explicitly.

What founders should do this week

Start with a short activity map and a gap register. Give every unresolved item an owner, an evidence requirement and a completion date. Use those findings to set a realistic submission target within the application period.

Continue monitoring the FCA's updates: it has also announced an October consultation on targeted changes to its perimeter guidance.

The strongest preparation starts with a business model the whole team can explain consistently. The application should describe that business clearly, with evidence behind its claims.