FCA cryptoasset gateway / Opens 30 Sep 2026 / Closes 28 Feb 2027 / — days left to apply
Free assessment · nothing is sent anywhere

How ready is your firm for the FCA cryptoasset gateway?

Twenty four questions against the standards the FCA will actually assess you on. Answer honestly rather than optimistically: a score you like is worth nothing. Under the existing cryptoasset registration regime the FCA approved 6% of the applications it determined in one recent twelve month period, and the FSMA bar is higher, not lower.

Takes about fifteen minutes · answers stay in your browser · no email required

The FCA's own words

Four failings the FCA has named.

Published feedback on cryptoasset applications it rejected. These are not our opinions about what good looks like. They are the regulator's stated reasons for saying no, and every one of them is a document problem rather than a business problem.

1. The risk assessment does not assess risk

Applicants failed to identify and assess money laundering, terrorist financing and proliferation financing risk properly, and did not explain the methodology behind the assessment they did produce. A risk register is not a risk assessment.

2. Control weaknesses recorded as inherent risks

Firms conflated the two. Inherent risk is what the business is exposed to before controls. A gap in your controls is a control failure, and presenting it as an inherent risk tells the FCA you do not understand your own framework.

3. The business plan does not explain the business

Business plans lacked adequate explanation of the cryptoasset activities themselves, the risks attached to them, and how those risks are mitigated by specific corresponding controls. The chain from activity to risk to control has to be visible on the page.

4. Underdeveloped framework, weak governance

The FCA has said plainly it will not approve an application where the AML framework is underdeveloped or the governance structure is weak, with particular attention to how procedures work day to day rather than how they read in a policy.

The same feedback describes what good looks like: full outsourcing detail including intragroup and overseas, product and service descriptions with token vetting policies, a clear customer risk scoring methodology, enhanced due diligence triggers, transaction monitoring proportionate to the complexity of the business, compliance staff who can actually investigate on chain, and suspicious activity reporting with a defined escalation path.

Working backwards

What has to be true, and when.

Dated backwards from 28 February 2027. The dates that matter are not the FCA's, they are the internal ones these imply.

Sources

  1. FCA, Cryptoassets: how the gateway will operate. Gateway opens 30 September 2026, closes 28 February 2027, regime commences 25 October 2027. Application information document and financial data template; pre-application meetings require meaningful supporting information.
  2. FCA, Cryptoassets: our standards. Threshold conditions under Schedule 6 FSMA; COND, PRIN, GEN, FIT, TC, SYSC and CRYPTOPRU; fit and proper test; Senior Managers and Certification Regime.
  3. FCA, Cryptoasset AML/CTF regime: feedback on good and poor quality applications, as reported by the National Law Review and Norton Rose Fulbright. Source of the four named failings and the 6% approval figure.
  4. FCA, Registration under the MLRs ahead of the new FSMA regime. MLR registration does not convert to FSMA authorisation.
  5. FCA PS26/12, A prudential regime for cryptoasset firms, published 30 June 2026. Source of the permanent minimum requirement figures, the own funds structure, the fixed overhead requirement approach and reassessment triggers, and the 25 October 2027 effective date. The fixed overhead calculation itself sits in COREPRU 4.3.5R.

Accurate as at 11 September 2026. The permanent minimum requirement figures are taken from the final policy statement. The fixed overhead figure this page calculates is indicative: the binding calculation is in COREPRU 4.3.5R and uses audited figures with specified deductions. This assessment is a planning aid, not regulatory or legal advice, and it does not create a client relationship. Perimeter Advisory is not a law firm.