On 30 April 2026, the Financial Conduct Authority (FCA) announced that, from 11 May 2026, cryptoasset firms preparing for the new regulatory regime will be able to request a pre-application meeting with the FCA through its Pre-Application Support Service (PASS). The FCA also published a new webpage setting out what firms need to do when preparing for the new cryptoasset regulatory regime.
Pre-application meetings
The FCA explains that pre-application meetings through PASS are free of charge and give firms the opportunity to discuss their plans with the FCA and ask questions before applying for authorisation or variation of existing permissions.
The FCA also sets out that pre-application meetings will take place from July 2026 but that it will schedule them as requests come in. It also reminds firms that the authorisation gateway will open on 30 September 2026 and the new regime will commence on 25 October 2027.
Preparing for the new regime
The FCA’s new webpage sets out what it considers cryptoasset firms need to do to prepare for the new regime, including:
- What the FCA expects firms to be doing now: The FCA encourages firms to develop a clear and credible plan that shows they have considered what the new regime will require of them, and how they will be ready. In particular, it highlights that firms that intend to apply for authorisation should: (i) review the new cryptoasset regulated activities and determine what type of authorisation is required, (ii) review proposed scope of permissions and ensure this aligns with their business model and risk profile, (iii) carry out a gap analysis against the expected Financial Services and Markets Act 2000 (FSMA) requirements, identifying where existing arrangements need to be strengthened, (iv) develop a realistic implementation plan, agreed at board level, (v) assess the resources and costs associated with preparation, authorisation and ongoing compliance, and (vi) where appropriate, invest in legal, compliance or regulatory advice to support preparations.
- Apply as soon as possible: The FCA also encourages firms to apply as soon as possible within the application period and to read the FCA’s information on how the application process works. In particular, the FCA highlights that firms that apply outside of the application period or submit poor quality applications may face: (i) having their application rejected if it does not contain the minimum information asked for, (ii) delays in the assessment of their application, (iii) refusal of authorisation, and (iv) for existing cryptoasset firms, the inability to continue carrying on cryptoasset activities when the new regime comes into force.
- Becoming authorised: The FCA makes clear that, for MLR-registered firms, their current systems and controls will help demonstrate compliance with FSMA, but firms should also begin assessing what will need to change to meet the expectations, including in areas such as market conduct, customer treatment, and senior leadership. In relation to FSMA-authorised firms, these firms should consider how the new cryptoasset activities and requirements affect their current permissions, business model, governance and systems and controls.