UK FCA previews its crypto application forms

The Financial Conduct Authority will start receiving cryptoasset authorisation applications from 30 September 2026. The FCA has now given unregulated crypto firms a first look at what they will need to include in their applications for authorisation. Its information document is also relevant to firms that are already FCA-authorised but wish to vary their permissions to provide any of the new cryptoasset regulated activities.

Firms’ applications will comprise two layers. The “core” layer contains standard information the FCA asks of most firms seeking authorisation (e.g. information about senior management, controllers and IT arrangements), plus crypto firms are expected to provide a cryptoasset records management policy. The second layer includes crypto-specific modules that applicants must complete based on their business model and the regulated activities they are applying for (e.g. operating a cryptoasset trading platform or crypto staking).

Applying for even a single activity triggers a substantial documentation exercise. For example, cryptoasset safeguarding firms will need to demonstrate robust custody arrangements by providing:

• A records and reconciliation policy showing how the firm checks and maintains accurate books and records each business day;

• Proof of trust arrangements, including a draft trust agreement and disclosure documents explaining to clients how their cryptoassets are held on trust;

• A means of access policy covering private key management, security controls, and key-mapping record templates; and

• Where third-party custodians are used, written agreements, proof of due diligence and governance documentation including detail on how liability is assigned between the firm, the custodian and the client.

Prospective applicants should note:

• The volume and specificity of the supporting documentation underlines how much there is for firms to do to get their applications ready for submission. 

• Firms will need to demonstrate they are ready, willing and organised to comply with the FCA’s rules. Firms will need to carefully consider what “ready” means when they apply several months before the crypto regime takes effect on 25 October 2027. The information document suggests that the FCA expects a mixture of draft documents and binding commitments.

• The FCA says the application form is still being finalised. Firms should be aware that there may be changes to details in the final form which the FCA will make available from the end of September.

Firms should treat this document, along with the suite of final rules that the FCA published last week, as the starting gun for their crypto licence and variation of permission applications. Firms need to apply by 28 February 2027 to take advantage of transitional measures.