UK cryptoasset regime · rules final 30 Jun 2026 · perimeter guidance final 16 Sep 2026 · application window OPEN 30 Sep 2026 – 28 Feb 2027 · fully in force 25 Oct 2027
Is your firm ready for the FCA's cryptoasset gateway?
Every MLR-registered cryptoasset firm must apply for full FSMA authorisation in one window — and overseas firms reaching UK customers through a s.21 approver are caught by the same deadline. The FCA has said poor-quality applications will be rejected without assessment — and at its last gateway, over 87% of crypto registrations were rejected, withdrawn or refused (FCA Annual Report 2023/24). The window is open now: the FCA has been accepting applications through Connect since 30 Sep 2026 and closes the window on 28 Feb 2027. Permora screens your readiness against the final rulebook, in minutes, in your browser.
Readiness triage · recommended
26 checks across the five things the FCA will actually test
1
Window & timing — saving vs frozen-book mechanics, submission quality
2
Threshold conditions — UK mind-and-management, close links, resources, disclosure, business model
3
Application pack — RBP, forecasts, Form A, fincrime framework, policy uploads
4
Governance & prudential — SM&CR, capital floors, ORA, wind-down
Perimeter check · if you're not sure you're in scope
Do you need FSMA authorisation at all?
The FCA's own statutory decision trees: is your token a qualifying cryptoasset, is your activity in scope, and what permissions and minimum capital follow.
Read this first. Permora produces an indicative screening, not legal advice and not a regulatory determination. Readiness checks are verified against the FCA's final rules and application materials. Perimeter results are verified against the FCA's final perimeter guidance, PERG 18 (PS26/18, 16 Sep 2026); an amending statutory instrument has been laid before Parliament and the FCA will consult on follow-on guidance in late 2026 — see the guidance note on the perimeter report. Permora is an independent tool: it is not affiliated with, endorsed by, or acting for the Financial Conduct Authority. Your answers stay in this browser unless you ask us to email you the report; we count page views, not answers. Professional review is required before relying on any output.
Readiness triage · your current status
Routing · how you reach UK customers today
Which best describes the firm right now?
This shapes how the window mechanics apply to you — the saving provision, the frozen-book risk and the s.21 cliff-edge work differently for each.
SI 2026/102 Part 7 · Webinar Q&A (Feb 2026) Q9, Q11, Q13
Readiness triage · your activities
Activities → permission set, capital floor & upload packs
Which of these does the firm do (or plan to do in the first 12 months)?
Tick everything that applies — this determines your permission set, your permanent minimum capital and which activity-specific document packs your application must include.
Perimeter check · Part 1 of 4 · Asset test · step 1 of 6
Tree 1 · qualifying cryptoasset
Is your token a cryptoasset within the FSMA s417 definition?
A cryptographically secured digital representation of value or contractual rights that can be transferred, stored or traded electronically, using technology supporting the recording or storage of data.
PERG 18.4.1 · s417 FSMA
Perimeter check · Part 1 of 4 · Asset test · step 2 of 6
Tree 1 · qualifying cryptoasset
Is the token a tokenised share, debt security or other specified investment?
Substance over label: look at the rights conferred and how holders obtain returns — whether off-chain-backed or digitally native.
PERG 18.4.6–18.4.7 · PERG 2.6
Perimeter check · Part 1 of 4 · Asset test · step 3 of 6
Tree 1 · qualifying cryptoasset
Is each unit fungible — freely interchangeable with any other unit?
A question of fact, not labels: a token marketed as an "NFT" can still be fungible, and vice versa.
PERG 18.4.2
Perimeter check · Part 1 of 4 · Asset test · step 4 of 6
Tree 1 · qualifying cryptoasset
Is the token — or the rights it confers — transferable between persons?
Contractual lock-ups do not negate transferability; nor do KYC, whitelisting, transfer-approval or freeze controls; burn-and-mint mechanisms count; rights transferable off-chain count even where the token itself cannot move on-chain.
PERG 18.4.3 · art 88F(3)
Perimeter check · Part 1 of 4 · Asset test · step 5 of 6
Tree 1 · qualifying cryptoasset
Is the token solely a record of value or contractual rights?
Functional test: if it is traded as an object of exchange and transferring it is how value moves, it is more than a mere record. Liquid staking tokens and wrapped tokens are "unlikely to constitute mere records" — usually in scope.
PERG 18.4.4
Perimeter check · Part 1 of 4 · Asset test · step 6 of 6
Tree 1 · qualifying cryptoasset
Is the token excluded from the QCA definition by art 88F(4)?
E-money; UK or foreign currency (including CBDC); tokens redeemable only with the issuer; tokens usable only within a limited network of providers with direct commercial agreements with the issuer; or cryptoassets falling within another specified investment category.
PERG 18.4.1(6)–(9) · art 88F(4)
Perimeter check · Part 1 of 4 · Asset test · stablecoin check
Tree 1 · qualifying stablecoin
Does the token seek to maintain a stable value against a single fiat currency, backed by held assets?
Algorithmic stablecoins (no backing assets), hybrid part-backed/part-algorithmic designs and multi-currency-basket tokens are not qualifying stablecoins — they remain plain QCAs. A wrapped token of a stablecoin is not automatically one either.
PERG 18.4.5 · art 88G
Perimeter check · Part 2 of 4 · Scope test · step 1 of 5
Tree 2 · do you need authorisation?
Are you carrying on any activity in relation to qualifying cryptoassets, qualifying stablecoin or specified investment cryptoassets?
PERG 18 Annex 2.1 · PERG 18.1.11
Perimeter check · Part 2 of 4 · Scope test · step 2 of 5
Tree 2 · do you need authorisation?
Will the activity be carried on in the UK?
Careful — this is wider than where your office is. Selling to (or buying from) a UK consumer is deemed carried on in the UK even for a wholly overseas firm (s418(6C)); the Overseas Persons Exclusion does not apply to the new cryptoasset activities; and an interposed UK agent or arranger does not take an overseas firm out of scope — only a principal dealer or QCATP does.
PERG 18.3.1–18.3.2, 18.3.6 · s418(6C) FSMA
Perimeter check · Part 2 of 4 · Scope test · step 3 of 5
Tree 2 · do you need authorisation?
Will the activity be carried on by way of business?
Deliberately narrower than the general FSMA business test: is the activity offered to customers as part of the business model? Occasional own-account trading as an end-user is out — but note the MLR business tests are different and assessed separately.
PERG 18.2.1–18.2.2
Perimeter check · Part 2 of 4 · Scope test · step 4 of 5
Tree 2 · do you need authorisation?
Does a tailored exclusion clearly apply to everything you do?
The crypto exclusions are narrow and activity-specific: intra-group transactions; genuine no-consideration airdrops; merchants accepting crypto for goods/services; DPB professional firms' incidental activity; pure technical provision. Familiar RAO exclusions (OPE, art 15) do not carry over.
PERG 18.11 · art 9Z10–9Z11
Perimeter check · Part 2 of 4 · Scope test · step 5 of 5
Tree 2 · do you need authorisation?
Does a PERG 2.10 exemption apply (e.g. appointed representative, exempt person)?
PERG 18 Annex 2.1 · PERG 2.10
Perimeter check · Part 3 of 4 · Activities & capital
Permission mapping · CRYPTOPRU 4.2.1R
Which of these does the firm do (or plan to do)?
Tick everything that applies — permissions stack, capital doesn't: the permanent minimum requirement is the highest single figure, not the sum.
Perimeter check · Part 4 of 4 · Transition position