How the FCA cryptocurrency gateway will work in practice

Daniel Howarth
Written by  Daniel Howarth - Partner, Audit and Assurance
Published on:  19 January 2026

The Financial Conduct Authority (FCA) has published new detail on how its cryptocurrency gateway will operate under the UK’s forthcoming cryptoasset regulatory regime. The FCA has provided important clarity for cryptoasset firms preparing for authorisation under the new framework.

For cryptoasset firms active in the UK, or planning to enter the market, this update offers a more concrete view of how the transition to full regulation will work in practice.

Which firms are in scope for the regulations?

According to FCA guidance, firms undertaking the following activities are in scope for the incoming regulations:

Cryptoasset service As described in the MLRs
Cryptoasset exchange provider (including Cryptoasset Automated Teller Machine (ATM), Peer to Peer Providers, and issuing new cryptoassets, eg Initial Coin Offering (ICO) or Initial Exchange Offerings). A firm or sole practitioner who by way of business provides one or more of the following services, including where the firm or sole practitioner does so as creator or issuer of any of the cryptoassets involved, when providing such services –

(a) exchanging, or arranging or making arrangements with a view to the exchange of, cryptoassets for money or money for cryptoassets,
(b) exchanging, or arranging or making arrangements with a view to the exchange of, one cryptoasset for another, or
(c) operating a machine which utilises automated processes to exchange cryptoassets for money or money for cryptoassets.

Custodian wallet provider A firm or sole practitioner who by way of business provides services to safeguard, or to safeguard and administer –

cryptoassets on behalf of its customers, or

private cryptographic keys on behalf of its customers in order to hold, store and transfer cryptoassets, when providing such services.

 

The role of the cryptocurrency gateway

The cryptocurrency gateway is intended to manage entry into the new regulatory regime in a structured and controlled way. Rather than allowing applications on a rolling basis, the FCA will set a defined application period ahead of the regime going live.

This approach is designed to encourage firms to prepare thoroughly, reduce the volume of incomplete applications, and allow the FCA to assess applications in an orderly manner. It also introduces clear consequences for firms that delay engagement or are not ready to apply when the window opens.

 

Pre application support from the FCA

The FCA has confirmed that firms can request a pre application meeting through its pre application support service. These meetings are optional and free of charge.

A pre application meeting allows firms to introduce their business model, discuss how the authorisation process works, and gain a clearer understanding of the FCA’s expectations. In practice, this can help firms submit higher quality applications and may support a more efficient assessment process.

That said, the FCA has been clear that these meetings do not involve regulatory advice and do not guarantee a successful outcome. Firms remain responsible for ensuring that their applications meet the required standards and thresholds.

 

The application period and expected timing

The FCA expects the application period to open in September 2026, with formal confirmation to be issued through a direction published on its website.

The application period must last at least 28 days and must close at least 28 days before the new regime begins. During this window, firms can apply for authorisation or apply to vary existing permissions if they are already authorised under UK financial services legislation.

The FCA expects to determine applications submitted during this period before the regime starts, although this may not always be possible.

 

What happens depending on when a firm applies

The FCA has set out different outcomes depending on whether a firm applies during the application period or outside it. These differences are important and are summarised below.

Firms that apply during the application period Firms that do not apply during the application period
FCA assessment FCA expects to determine the application before the regime starts, where possible Application will be assessed in the normal course and will not be expedited
Position when the regime starts if not yet authorised Firm can usually continue providing cryptoasset services under the saving provision while the application is determined Firm automatically enters the transitional provision by operation of law
Ability to carry out new regulated activities Can continue providing services while relying on the saving provision Cannot carry out new UK regulated cryptoasset activities until authorised
Existing contracts Can continue to provide cryptoasset services Can continue servicing pre-existing contracts only
Notification requirements Firm must notify the FCA when relying on, and when exiting, the saving provision FCA requirements apply under the transitional provision framework

 

In certain circumstances, including where an application is refused and referred to the Upper Tribunal, The FCA may direct a firm into the transitional provision rather than the saving provision.

 

What firms should be doing now

The FCA’s guidance makes clear that preparation cannot be left until the application period opens. Firms should be reviewing whether their activities fall within scope, how their governance and control frameworks operate in practice, and whether they are realistically ready to apply in 2026.

Independent legal and compliance advice can be valuable in testing readiness, identifying gaps and planning application timelines. The cryptocurrency gateway is not just a procedural step. It is a critical control point that will determine how and when firms can operate in the UK’s regulated cryptoasset market going forward.

Similar Insights

What to do if you receive an HMRC letter about crypto tax

5th November 2025
Written by: Dion Laycock
HMRC has started contacting individuals it believes may have under-reported income or gains from crypto transactions. These “one to many” letters, often known as nudge letters, are being sent to taxpayers whose records suggest they...
link to Find Out More

Empowering auditors to engage with digital assets

12th December 2024
 
Explore how utilizing an auditor's expertise in digital assets can improve guidance implementation and enhance auditors' ability to navigate digital asset audits.
link to Find Out More

Utilising Independent Auditor’s Experts in Blockchain-related Audits

3rd September 2024
 
The rapid growth of companies dealing in digital assets highlights the crucial need for thorough and transparent blockchain related audits.
link to Find Out More

Sign up to Gravita's latest updates and newsletters

Stay up-to-date with our event invites, latest news and updates, straight from Gravita's experts.