FCA crypto authorisation: fees and the application window

Bratby Law Payments Regulation header card reading FCA crypto authorisation: fees and the application window

In short: FCA crypto authorisation applications open at 9am on 30 September 2026 and the application window closes at 11.59pm on 28 February 2027. Handbook Notice 144 fixes the price of applying: one fee where a firm also seeks MLR registration, £11,260 to issue a qualifying stablecoin, and 2028/29 fees and Ombudsman levy set from the income figures in the application.

By Rob Bratby, Managing Partner, Bratby Law. 30+ years in regulated industries, including current Fractional General Counsel to UKPI. Chambers UK Band 2 (Telecommunications), Legal 500 Leading UK Telecoms Partner.

A firm that wants to issue a sterling stablecoin, hold cryptoassets for customers or run a crypto trading service in the UK after 25 October 2027 will need FCA crypto authorisation, in the form of a Part 4A permission under the Financial Services and Markets Act 2000 (FSMA). An authorisation as an e-money institution or payment institution does not count. The first date on which a firm can apply is Wednesday 30 September 2026, and a firm that applies by 28 February 2027 has a legal protection that a later applicant does not.

The Financial Conduct Authority (FCA) listed in Handbook Notice 144 the rules its Board made on 24 September 2026. In three of those instruments the FCA fixed the cost and the paperwork of applying: the fees instrument (FCA 2026/58), the financial promotion notification instrument (FCA 2026/60) and an amendment to the Decision Procedure and Penalties manual (DEPP), the FCA’s statement of how it takes enforcement decisions (FCA 2026/61).

Key points

  • The application window for FCA crypto authorisation opens at 9am on 30 September 2026 and closes at 11.59pm on 28 February 2027. Source: FCA direction under regulation 52, 20 February 2026.
  • A firm applying for a Part 4A permission and a Money Laundering Regulations (MLR) registration at the same time pays one fee, at the highest applicable category. Source: FEES 3.2.2G, Cryptoasset Activities (Periodic and Application Fees) Instrument 2026 (FCA 2026/58).
  • Issuing a qualifying stablecoin, dealing as principal and safeguarding cryptoassets are each in pricing category 6, currently £11,260. Source: FEES 3 Annex 1 and FEES 3 Annex 1A.
  • Authorised cryptoasset firms join a new fee block, A.26, charged on annual income. The rate for 2026/27 is £0. Source: FEES 4 Annex 1A and FEES 4 Annex 2A, FCA 2026/58.
  • Stablecoin issuers and principal dealers will pay a flat Financial Ombudsman Service levy, set at £0 now and intended to be £75 for 2028/29. Source: Handbook Notice 144, paragraph 3.57.
  • From 1 October 2026, a section 21 approver notifies the FCA of cryptoasset promotion approvals only in its first three months of approving, and for direct offer promotions. Source: SUP 16.31.5R, FCA 2026/60.
Regulated cryptoasset activityPricing categoryApplication feeOmbudsman levy basis
Arranging deals, dealing as agent, arranging staking4£2,820Annual income from relevant business
Dealing in qualifying cryptoassets as principal6£11,260Flat fee
Safeguarding cryptoassets, or arranging safeguarding6£11,260Annual income from relevant business
Issuing a qualifying stablecoin6£11,260Flat fee
Operating a qualifying cryptoasset trading platform7£28,150Annual income from relevant business

The statutory basis for FCA crypto authorisation and the application window

From 25 October 2027, when the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102) come fully into force under regulation 1(2), a firm that issues a qualifying stablecoin, safeguards cryptoassets, operates a trading platform, or deals, arranges or stakes cryptoassets carries on a regulated activity, and a person who does so without permission breaches the general prohibition in section 19 of FSMA. Firms may already apply for the new permissions under regulation 1(3), and the FCA may already determine those applications.

The FCA had to set a “relevant application period” by direction under regulation 52, and gave that direction on 20 February 2026. What happens to an applicant after 25 October 2027 depends on when it applied. Under regulation 53, a firm that applies inside the window and whose application is still undetermined on that date is treated as if the new regime had not come into force for the activity applied for, until 25 October 2029 at the latest. A firm that applies after 28 February 2027, or whose application inside the window is refused and no longer open to review, is exempt under regulation 56 instead, and only so far as it needs to perform contracts entered into before the relevant day. The FCA describes that exemption as the route for an unsuccessful firm to run off its UK business and leave the market.

Fees and notifications for FCA crypto authorisation applicants

An applicant pays one application fee even where it applies for FSMA authorisation and MLR registration together. The FCA added that position to FEES 3.2.2G after consulting in CP26/11, because under the first draft a firm would have paid a separate category 6 fee for the MLR registration. A stablecoin issuer applying for both therefore pays £11,260 once. An MLR-registered cryptoasset business currently pays periodic fees in fee block G30. Once it is authorised under FSMA, it moves into fee block A.26 and does not pay in both.

A firm in fee block A.26 pays on annual income, defined in FEES 4 Annex 11A as the gross inflow of economic benefits recognised in its accounts in respect of the UK regulated activities. No firm will pay an A.26 fee before the 2028/29 fee year, and the FCA will set that year’s rates from the income projections firms give in their applications. A trade body questioned whether that definition fits cryptoasset revenue models. The FCA kept the definition and will set out its proposals in detail when it consults on the 2028/29 rates.

A firm carrying on most cryptoasset activities will pay the Financial Ombudsman Service levy on income from relevant business, meaning business with consumers, on the same timetable as the FCA fee. Firms that issue qualifying stablecoins or deal as principal will pay a flat fee instead, because the FCA expects few complaints and could not find an income measure that tracks complaints risk. A respondent disagreed with the FCA’s comparison between stablecoin issuers and e-money issuers, and suggested a £0 rate for an initial period. The regulator kept the flat fee and ruled out a permanent £0 rate, saying every firm that could generate Ombudsman complaints should contribute. The respondent also asked for sector-specific guidance on identifying income from relevant business. The FCA declined, on the ground that cryptoasset business models are no more complex than many others within its perimeter, and pointed firms to the best-estimate provision in FEES 5.4.1R(3). The FCA has set 2029/30 as a transitional year and expects firms to have levy reporting systems in place from 2030/31.

From 1 October 2026, an approver under section 21 of FSMA must notify the FCA within seven days of approving a qualifying cryptoasset promotion in two cases only: approvals in the three months after its first cryptoasset approval under a new or varied approver permission, and approvals of direct offer promotions. The FCA made the change because the vast majority of the notified promotions it reviewed complied with its rules. From 30 September 2026, FCA staff under executive procedures will decide whether to direct under regulation 55(3) that a refused applicant whose case is open to review moves from the regulation 53 saving to the regulation 56 run-off exemption (DEPP 2.5.18G). The applicant may refer that decision to the Upper Tribunal. The wider changes to DEPP penalty policy proposed in the same consultation are covered in FCA penalty policy changes for payment and e-money firms.

FCA crypto authorisation for payment and e-money firms

An authorised electronic money institution or payment institution holds its authorisation under the Electronic Money Regulations 2011 or the Payment Services Regulations 2017, and has no Part 4A permission under FSMA to vary. An EMI that plans to issue a qualifying stablecoin, or to hold stablecoins for customers, must make a fresh Part 4A application. A firm that already holds a Part 4A permission applies to vary it. In both cases the planned activity must fall within one of the new regulated activities and outside the exclusions, and the firm must meet the threshold conditions for the permission sought. The FCA’s final guidance on the activities is a new chapter 18 of its Perimeter Guidance manual (PERG 18), most of which takes effect on 25 October 2027 (PS26/18). Paying the right fee does not make a firm authorisable; the application stands or falls on the perimeter and the threshold conditions.

A payment firm that plans to use stablecoins in payment flows has an open question on scope. HM Treasury has published a draft of the Financial Services and Markets Act 2000 (Cryptoassets) (Miscellaneous Amendments) Regulations 2026, which has not been made. As drafted, a firm that holds a UK qualifying stablecoin temporarily in connection with the execution of a payment transaction would fall outside the safeguarding activity, under a new article 9QA of the Regulated Activities Order. Until that instrument is made, the safeguarding activity in SI 2026/102 applies to a payment firm that holds stablecoins for its customers, and the application window closes on 28 February 2027 whether or not the exclusion is made. The Bank of England’s separate regime for systemic stablecoins is covered in the Bank of England stablecoin cap and the dual-track UK regime. Scoping the business against the current perimeter is covered on the regulatory perimeter and market entry page, and the FSMA and payments authorisation routes on the authorisation and licensing page.

Viewpoint

I read 28 February 2027 as the date that matters most. Regulation 53 protects an applicant who applies by then. A firm that waits for the draft Miscellaneous Amendments Regulations to settle the payments exclusion, and applies after that date, keeps only the regulation 56 exemption for its existing contracts if its application is still pending on 25 October 2027; a firm that first applies on or after 25 October 2027 has no exemption at all.

Frequently asked questions

When can a firm apply for FCA crypto authorisation?

From 9am on 30 September 2026. The FCA’s direction under regulation 52 of SI 2026/102 sets the relevant application period as 9am on 30 September 2026 to 11.59pm on 28 February 2027. A firm may apply outside that period, but only an application for FCA crypto authorisation made inside it qualifies for the regulation 53 saving provision.

Does an e-money institution need a new permission to issue a stablecoin?

Yes. Issuing a qualifying stablecoin is a regulated activity under article 9M of the Regulated Activities Order from 25 October 2027, and needs FCA crypto authorisation in the form of a Part 4A permission under FSMA. An authorisation under the Electronic Money Regulations 2011 is not a Part 4A permission, so an EMI must apply for one.

How much is the application fee for a stablecoin issuer?

Issuing a qualifying stablecoin is in pricing category 6, currently £11,260 under FEES 3 Annex 1A. Under FEES 3.2.2G, a firm that applies for MLR registration at the same time pays one fee, at the highest applicable category.

What happens to a firm that applies after 28 February 2027?

A firm that applies after 28 February 2027 but before 25 October 2027, and whose application is still undetermined, or is refused or withdrawn, falls under regulation 56 of SI 2026/102. The firm is exempt from the general prohibition only so far as it needs to perform contracts entered into before the relevant day, which in practice means running off its UK business. A firm that first applies on or after 25 October 2027 has no exemption.


For advice on FCA crypto authorisation for a payments or stablecoin business, and on the application itself, contact Rob Bratby at Bratby Law.

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