FCA Crypto Application Checklist: Documents and a Weekly Plan to 28 February 2027

The FCA application window for the new UK cryptoasset regime closes on 28 February 2027. That date is a Sunday, so a firm should plan to file through FCA Connect by Friday 26 February 2027 at the latest. A firm that applies inside the window and is still awaiting a decision when the regime starts on 25 October 2027 can keep operating, including taking new business, until the FCA decides. From 20 October 2026 that leaves about 18 weeks to finish a complete application: business plan, financial projections, governance and senior manager approvals, financial crime controls, custody arrangements under CASS 17, a capital model and wind-down planning.

The dates that matter

Section 55V of FSMA requires the FCA to decide a complete application within six months of receiving it, and any application within 12 months. The six months only start once the application is complete. The FCA has said it will reject applications that lack its minimum information, and that poor-quality applications face delay or refusal.

The FCA's figures for the current registration regime show the standard it applies. As at 1 October 2026 it had received 427 cryptoasset registration applications under the Money Laundering Regulations since January 2020. It had registered 68 firms, and 265 applications had been withdrawn (FCA registration statistics). The FSMA test is wider than the registration test, because it adds capital, conduct, custody and senior manager approval. Our complete application guide explains that test.

Why filing inside the window matters

Firms relying on the saving provision must notify the FCA, by a method the FCA will set in a direction. MLR registration does not convert into authorisation, so registered firms must apply like anyone else. Our guide to moving from MLR registration to FCA cryptoasset authorisation covers that transition.

What a complete application contains

The FCA published an information document on 17 September 2026 setting out every question in the form. It has a core section for most applicants and modules by activity. Firms already authorised under FSMA answer the crypto-specific questions in a variation of permission application.

The core documents, one by one

Regulatory business plan. The plan explains what the firm does, for whom, through which channels and with which partners, and maps every activity to a permission. It is the document the FCA reads first, so it must agree with the forecasts, the policies and the organisational chart. A plan written for investors rather than the regulator is a common cause of questions.

Financial projections. The FCA's guidance on preparing financial information asks for an income statement, balance sheet and cash flow, with key assumptions, and describes three years of forecasts in Excel as best practice. Firms already trading add historical accounts, and the FCA describes three years as best practice. The same projections feed the fees section, so the numbers must reconcile.

Governance and senior managers. The Senior Managers and Certification Regime applies in full. Each senior manager needs an approval application with full disclosure, a statement of responsibilities and a place in the management responsibilities map. Candidates should be confirmed early, because the FCA assesses them alongside the firm.

Financial crime. The framework covers the firm's risk assessment, customer due diligence, transaction monitoring, sanctions screening, the Travel Rule for cryptoasset transfers and suspicious activity reporting. MLR-registered firms should update their existing framework to the new business model rather than resubmit it unchanged.

Custody under CASS 17. Firms that hold client cryptoassets must show how they hold them on trust, keep records for each client, reconcile, and protect private keys. Where a third-party custodian is used, the FCA asks for the agreement, the due diligence and how liability is allocated. The custody model needs to be settled before drafting starts. Our guide to crypto custody authorisation covers the rules.

Prudential. Own funds must be at least the highest of the permanent minimum requirement, the fixed overheads requirement and the K-factor requirement under CRYPTOPRU. The permanent minimum requirement runs from £75,000 for arranging or dealing as agent to £750,000 for dealing as principal. It is a threshold condition, so the money must be in place, not promised. Our guide to FCA crypto prudential requirements sets out the calculations.

Wind-down. The FCA asks some firms for a wind-down plan with their application. Its guidance describes four parts: the scenarios that would make the firm unviable, the steps to close in an orderly way, the financial and non-financial resources needed, and how obstacles are managed. For crypto firms, the plan should show how client cryptoassets are returned or transferred. The fixed overheads requirement, one quarter of annual relevant expenditure, is the capital proxy for that cost.

Readiness checklist

• Permissions chosen and the matching permanent minimum requirement confirmed
• UK legal entity in place, or the branch case made where the FCA allows it
• Own funds paid in and evidenced
• Senior manager candidates confirmed, disclosures gathered and approval forms drafted
• Controllers and close links identified up to the ultimate owners
• Regulatory business plan, forecasts and fees data reconciled with each other
• Financial crime framework, compliance monitoring plan and complaints policy final and board-approved
• Custody model settled, with trust documents, key management policy and custodian agreements where used
• Consumer Duty, appropriateness and customer disclosure documents ready where retail clients are served
• IT self-assessment complete and consistent with the operational resilience mapping
• Wind-down plan prepared and linked to the capital model
• FCA Connect access set up and the application fee (£2,820, £11,260 or £28,150 by activity) authorised for payment

A week-by-week plan from 20 October 2026 to 28 February 2027

The plan below works back from a target filing date in mid-February, leaving two weeks of contingency before the window closes. It assumes the firm already operates and has a working compliance function. A firm starting from nothing needs to compress the early weeks or add resource.

The FCA's pre-application meetings are optional and free, but the FCA rejects requests that come without meaningful information on the business model and activities. A meeting is most useful once the scoping note and capital model exist, in weeks 3 to 5.

Firms already authorised or registered

Firms that already hold FSMA permission apply for a variation of permission and complete the cryptoasset form with it, inside the same window. MLR-registered firms apply for authorisation and should not apply for new MLR registration after 31 July 2027. The UK crypto licence page sets out permissions, capital and fees in full, and the FCA cryptoasset AML registration page covers the current regime.

After filing

The FCA will usually ask questions. Each answer should arrive by the date set, signed off at the right level and consistent with the original documents. Material changes, such as a new controller, a change of senior manager or a new custodian, should be notified to the FCA while the application is open. If the decision is still pending on 25 October 2027, a window applicant notifies the FCA that it is relying on the saving provision and carries on under it.