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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 30 June 2026 the FCA published its final rules and guidance for the UK cryptoasset FSMA regime, which will apply to cryptoasset firms granted permission to operate under FSMA on or after 25 October 2027. The package is for MLR-registered cryptoasset firms that need a new FSMA permission, already-authorised FSMA firms that need a variation of permission, payments and e-money firms, firms using s.21 approvers, and overseas firms serving UK customers. The relevant application period in the FCA’s direction of 20 February 2026 runs from 09:00 on 30 September 2026 to 23:59 on 28 February 2027.
MLR registration does not convert. If you carry on a new regulated cryptoasset activity by way of business in the UK you will need Part 4A permission (or a variation). Firms that apply inside the direction window can use the SI saving provision if the FCA has not determined the file by 25 October 2027. Firms that apply after 28 February 2027, and are not authorised by full commencement, fall into the transitional provision by operation of law: pre-existing contracts only, no new UK customers. Firms that do not apply must run off before 25 October 2027 or they risk the general prohibition.
Operational consequences:
Read the statements from the overview page. Do not use guessed HTML slugs for the individual PSs.
All firms carrying on regulated cryptoasset activities should read the Handbook-application and prudential statements; activity packs sit on top.
| Firm type | What to read (via the overview) | Prudential floor to model first | Official references |
|---|---|---|---|
| All CRYPTOPRU firms | Handbook application, Consumer Duty, operational resilience, international-firms guidance, aggregate CBA | Higher of PMR, FOR and K-factor requirement. Own funds under COREPRU | Overview; PS26/12 PDF |
| UK stablecoin issuers | Plus stablecoin issuance (backing assets, statutory trust, redemption, CASS 16) | PMR £350,000. K-SII now 1% of average qualifying stablecoins in issuance (was 2% at consultation) | Overview “Who needs to read what”; PS26/12 PDF Chapter 3 |
| Cryptoasset custodians | Plus safeguarding (CASS 17); CASS 7 for related client money. RSIC custody uses CASS 6 for now | PMR £150,000. K-RCS 0.04% of average cryptoassets safeguarded (includes third-party delegates) | Overview; PS26/12 PDF |
| Trading platforms (UK QCATPs) | Plus regulated activities and A&D / MARC | PMR £150,000. K-CCO / K-CTF at 0.1% of the relevant flow | Overview table |
| Dealing as principal | Plus regulated activities; K-NCP / K-CCD on the trading book | PMR £750,000. K-NCP 40% of net position in prudently valued, UK-QCATP-admitted cryptoassets; others deducted from CET1 | PS26/12 PDF Chapter 3 |
| Dealing as agent / arranging | Plus regulated activities | PMR £75,000 | PS26/12 PDF §3.4 |
| Staking | Plus staking disclosures, consent, record-keeping | PMR £150,000. K-CCS 0.04%; if safeguarding and staking apply to the same assets, apply the safeguarding K-factor only | Overview; PS26/12 PDF |
| Already-authorised FSMA / PSR / EMI firms | Variation of permission | Dual COREPRU + MIFIDPRU: highest PMR, COREPRU FOR, sum of K-factors. PRA-authorised persons sit outside the CRYPTOPRU firm definition | Overview “What you need to do”; PS26/12 PDF Chapter 2 |
| MLR-registered CASPs | New FSMA application. No automatic conversion | Same PMR / FOR / K-factor stack | Gateway page |
Operational tip: Own funds requirement is the highest of PMR, FOR and KFR, not the sum of those three. K-factors do add across activities.
| Step | Action | What operational staff must deliver | Official reference |
|---|---|---|---|
| 1 | Lock the three dates | SI made 4 February 2026; final rules 30 June 2026; full commencement 25 October 2027 | New-regime hub; milestones |
| 2 | Lock the gateway from the direction | 09:00 on 30 September 2026 to 23:59 on 28 February 2027. Direction dated 20 February 2026, regulation 52 | Direction PDF |
| 3 | Map regulated activities | One row per product and legal entity. That row drives which overview columns you read and which PMR applies | Overview “Who needs to read what” |
| 4 | Stand up COREPRU / CRYPTOPRU | CET1-heavy own funds; deductions (intangibles; own-issued tokens; non-QCATP / non-prudent positions). PMR by activity. FOR on whole-firm expenditure (gas fees: 100% if passed on, 80% otherwise). K-SII at 1%; K-NCP 40% where the tests are met | PS26/12 PDF |
| 5 | Decide saving vs transitional vs run-off | Apply inside the window if you need the saving provision. Late files are not expedited. No application means run-off before 25 October 2027 | How the gateway will operate |
| 6 | PASS, form, webinars | Optional PASS meeting — take a real business-model note or the request is rejected. Form live from 30 September 2026. Milestones page: PASS in July 2026. Webinars 7 / 11 / 15 / 18 / 22 / 29 September 2026 | Gateway page; framework one-pager; new-regime hub |
| 7 | Track still-open guidance | GC26/4 (COREPRU) and GC26/5 (CRYPTOPRU) sit alongside PS26/12. Resolution, financial-crime guide updates and reporting packs are later work on the overview page — do not invent close dates | Overview “Prudential” and “What we will do” |
Run a first pass on capital: FCA Crypto Prudential Readiness Diagnostic.
ps26-9 … ps26-13 HTML slugs. Those 404. Use the overview page and the PS26/12 PDF.GRT Consulting supports operational teams with:
Start with the FCA Crypto Prudential Readiness Diagnostic. The regulatory agenda tracks the same 30 September 2026 / 25 October 2027 marks. Contact us: T: +44 20 3695 9251 E: info@grtconsult.com Web: grtconsult.com
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