Get in Touch
T: +44 20 3695 9251
E: info@grtconsult.com
71-75 Shelton Street Covent Garden, London, WC2H 9JQ
Get in Touch
T: +44 20 3695 9251
E: info@grtconsult.com
71-75 Shelton Street Covent Garden, London, WC2H 9JQ
On 4 February 2026 The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 were made by Parliament. They bring cryptoassets within the FCA’s regulatory remit and start the FSMA clock for UK cryptoasset firms (including MLR-registered CASPs) that will need a new permission, already-authorised FSMA firms that will need a variation of permission, and payments/e-money firms, s.21 approvers and overseas firms serving UK customers. Full commencement is 25 October 2027; specified FCA rule-making, guidance, direction and application-handling powers come into force at the end of the 21-day period in regulation 1(3).
The SI is SI 2026/102. Regulation 1 is the date lock:
Do not invent a calendar day for that 21-day clause; quote regulation 1(3). The King’s Printer PDF header records “Made – – – – 4th February 2026”. The FCA hub: “On 4 February 2026, The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 were made by Parliament and will bring cryptoassets within our regulatory remit.”
MLR registration is not a FSMA permission. The gateway page says firms registered under the MLRs “should note that there will be no automatic conversion and that they will need to secure authorisation by us under FSMA.” Already-authorised FSMA firms need a variation of permission.
Later official dates:
The gateway HTML says the FCA expects the application period will open on 30 September 2026 “as set out in our direction.” The direction PDF is the lock for the clock times. Do not treat “expect” as a second independent source.
| Business type | What is in scope | What to do now |
|---|---|---|
| UK cryptoasset firms, including MLR-registered CASPs | New FSMA permission; no automatic conversion from MLR registration | Map activities to the SI perimeter. Open a Part 4A workstream. Diary 30 September 2026–28 February 2027. |
| Already-authorised FSMA firms | Variation of permission if they will carry on the new activities | Scope the VOP. Do not assume existing MiFID, banking or EMI permissions cover them. |
| Payments and e-money firms | In the gateway population where activities become regulated cryptoasset activities | Same mapping. Decide authorisation vs run-off before 25 October 2027. |
| Firms using a s.21 approver | Financial-promotions overlay now; FSMA permission later if they carry on the new activities | An approver relationship is not a substitute for authorisation. |
| Overseas firms serving UK customers | SI perimeter if they carry on the new activities by way of business in the UK | Decide UK authorisation, run-off, or a documented out-of-scope analysis. |
| Firms that will not apply | Must run off UK cryptoasset business before full commencement; no saving or transitional provision | Named run-off owner and a hard stop before 25 October 2027. |
Operational tip: Apply during the window if you want the SI saving provision. Apply late and you are looking at the transitional provision (pre-existing contracts only). Do not apply and you risk s.19 FSMA (general prohibition) or s.20 FSMA (acting without permission).
| Step | Action | What operational staff must deliver | Official reference |
|---|---|---|---|
| 1 | Lock the statutory dates | Diary: SI made 4 February 2026; 21-day early powers under reg. 1(3); full commencement 25 October 2027 | SI 2026/102 reg. 1; King’s Printer PDF |
| 2 | Map activities to the new perimeter | Service-by-service list: what you do, which activity it will be, which UK customers you serve | FCA hub; SI 2026/102 contents |
| 3 | Choose the authorisation route | New Part 4A, VOP, or documented run-off. Record that MLR registration does not convert | Gateway: no automatic conversion; VOP for already-authorised firms |
| 4 | Stand up the application file | Owners for business model, regulated-activity analysis, financial data, SM&CR candidates, IT/ops | Gateway: PASS needs meaningful supporting information; form from 30 September 2026 |
| 5 | Diary the application period | Window 09:00 30 September 2026 – 23:59 28 February 2027. File inside it | Direction PDF dated 20 February 2026. Gateway “expect … as set out in our direction” |
| 6 | Saving vs transitional vs run-off | In-window: FCA expects to determine before commencement; saving if not. Late: transitional. No application: run off | Gateway sections on apply during / outside / not at all |
| 7 | Use the later official calendar | 30 June 2026 final rules (overview page). September 2026 webinars | FCA hub 30 June sentence; webinars 7–29 September 2026 |
The FCA will not expedite a late submission to compensate. Start the evidence pack now.
ps26-9 to ps26-13 HTML slugs. Those 404. Name the PSs via the overview page (and, for prudential, the PS26/12 PDF).GRT Consulting supports operational teams with perimeter mapping against SI 2026/102, Part 4A / VOP application files and PASS evidence packs, and saving, transitional or run-off decision papers with named owners and dates.
Contact us for a focused readiness review: T: +44 20 3695 9251 E: info@grtconsult.com Web: grtconsult.com
Sources
