The FCA Cryptoasset Authorisation Window Is Open. Is Your Firm Ready to Apply?
13 October 2026 | Mediajem Consultancy Ltd
The FCA's cryptoasset authorisation application window opened on 30 September 2026. Firms have until 28 February 2027 to apply within the designated period, ahead of the new regulatory regime taking effect on 25 October 2027.
For affected businesses, this is an important transition. But opening the application window is not the same as being ready to submit an application.
The real question is whether a firm can demonstrate that its arrangements, controls and oversight are sufficiently developed to withstand regulatory scrutiny.
From preparing for regulation to demonstrating readiness
In our earlier article, Five Weeks to the FCA Cryptoasset Window: What “Ready” Looks Like, we considered the preparations firms should be making before applications opened.
That question has now become more immediate.
The FCA expects applicants to understand which activities require authorisation, identify the permissions they need and provide credible supporting information. Firms should also be able to demonstrate how their arrangements will meet the applicable regulatory requirements.
This is not simply a matter of producing policies.
A policy may describe how an organisation intends to operate. The more demanding question is whether its responsibilities, controls and escalation arrangements are understood, implemented and supported by evidence.
Seven questions worth asking now
Before submitting an application, firms should consider:
1. Regulatory scope: Have we established which of our current or proposed activities fall within the new regime?
2. FCA permissions: Do we understand which permissions or variations of permission we need?
3. Accountability: Is it clear who is responsible for regulatory obligations, oversight and consequential decisions?
4. Financial crime controls: Can we demonstrate how applicable AML/KYC, sanctions and Travel Rule controls operate in practice?
5. Technology and third-party risk: Do we understand the risks associated with our systems, outsourcing arrangements, service providers and AI-enabled processes, where used?
6. Evidence: Can we produce current records demonstrating how our controls, management oversight and escalation processes actually work?
7. Remediation: Have we identified material gaps, assigned responsibility and established realistic timescales for addressing them?
These questions are not a substitute for the FCA's authorisation requirements. They are a practical starting point for examining whether an organisation is prepared for the application process.
Why early action matters
The FCA has encouraged firms to apply as early as possible within the application period.
That encouragement should not be mistaken for an invitation to submit an incomplete or inadequately supported application.
The practical challenge is to balance timely submission with sufficient preparation.
Firms already operating under existing arrangements should also examine how the new requirements and any applicable transitional provisions affect their ability to continue their activities. Existing registrations or permissions do not automatically provide the new authorisation.
Where gaps exist, identifying them now provides an opportunity to prioritise remedial work before they become obstacles to an application.
Start with a readiness assessment
Mediajem Consultancy Ltd has introduced a free FCA Crypto Asset Readiness Pulse: a short, seven-question self-assessment designed to help firms consider some of the practical issues involved in preparing for authorisation.
It takes only a few minutes to complete. Respondents may submit their answers without providing contact details.
The Pulse is an initial screening exercise. It does not determine whether authorisation is required, establish regulatory compliance or predict the outcome of an FCA application.
Take the Free FCA Crypto Asset Readiness Pulse
Where more detailed support is needed
A short questionnaire can help identify areas for closer attention. It cannot establish whether the underlying evidence, controls and operational arrangements are sufficient.
For firms seeking a more structured assessment, Mediajem offers a paid, targeted Cryptoasset Authorisation Readiness Review, focused on identifying potential readiness gaps, examining relevant supporting arrangements and helping management prioritise practical next steps.
The objective is not to guarantee an authorisation outcome. It is to help firms approach the application process with a clearer understanding of their position, responsibilities and outstanding work.
The window is open. The priority now is to establish what your firm can demonstrate — not merely what it intends to do.
Mediajem Consultancy Ltd provides independent regulatory, compliance and risk advisory services. This article is general information, not legal advice or an assessment of any individual firm's regulatory position. Mediajem is not affiliated with or endorsed by the FCA.
