From the journal

FCA Opens Pre-Application Support for UK Cryptoasset Authorisation, PASS from 11 May 2026

The Financial Conduct Authority (FCA) announced on 30 April 2026 that cryptoasset firms preparing for the new Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (the Crypto Regime) may request pre-application meetings via its Pre-Application Support Service (PASS) starting 11 May 2026. Pre-application meetings are free of charge and give firms the opportunity to discuss their regulatory plans and ask questions before submitting a formal authorisation application or

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The Financial Conduct Authority (FCA) announced on 30 April 2026 that cryptoasset firms preparing for the new Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (the Crypto Regime) may request pre-application meetings via its Pre-Application Support Service (PASS) starting 11 May 2026. Pre-application meetings are free of charge and give firms the opportunity to discuss their regulatory plans and ask questions before submitting a formal authorisation application or variation of existing permissions. The meetings will commence in July 2026. The Crypto Regime authorisation gateway opens on 30 September 2026, and the new regime will commence on 25 October 2027.

The Crypto Regime, made in February 2026 and establishing the UK's financial services regulatory framework for cryptoassets, requires firms seeking to carry on any of the new regulated cryptoasset activities, including dealing in qualifying cryptoassets, arranging deals in qualifying cryptoassets, operating a cryptoasset trading platform, safeguarding qualifying cryptoassets, issuing qualifying stablecoin, and issuing qualifying cryptoassets, to be authorised by the FCA. The PASS service operates under the FCA's general supervisory and authorisation powers derived from the Financial Services and Markets Act 2000, as extended by the Crypto Regime. The FCA has described the pre-application meetings as part of its broader strategy of supporting firms to engage early and test safely before formal submission.

Any firm that currently operates or plans to operate under one or more of the new regulated cryptoasset activities must submit a formal application for authorisation or variation of permissions by or following the opening of the authorisation gateway on 30 September 2026. Firms that engage with the PASS prior to submission may discuss their business model, the specific regulated activities they intend to conduct, the threshold conditions they must satisfy, and any issues arising from their existing permissions or regulatory history. The FCA has indicated it will publish a good and poor practice report for AI in financial services later in 2026, underscoring its increasing integration of AI tools into its own supervisory toolkit, including its recently announced pilot of AI-powered analysis of suspicious activity reports and enforcement case files.

Firms wishing to request a pre-application meeting must do so via the FCA's PASS portal from 11 May 2026. Slots will be allocated on a scheduling basis. Firms should note that engaging with PASS does not confer any approval or pre-clearance of their business model, and the FCA retains full discretion to refuse authorisation following formal application. The new Crypto Regime regime runs in parallel with, and partially supersedes, the existing Money Laundering Regulations 2017 registration requirements for cryptoasset exchange providers and custodian wallet providers, which remain operative until the new regime commences in October 2027.

Our firm advises cryptoasset exchanges, stablecoin issuers, custodians, and digital asset service providers on UK regulatory authorisation, FCA application strategy, crypto regime compliance, and pre-application support under PASS. We have a dedicated partner network covering UK financial services regulation. Contact us to prepare for the Crypto Regime gateway: work we undertake includes FCA authorisation applications, regulatory business plan drafting, threshold condition analysis, crypto compliance reviews, and MLRO engagement.

Source: Financial Conduct Authority, "Cryptoasset firms can request pre-application meetings from 11 May 2026," published 30 April 2026, https://www.fca.org.uk/news/news-stories/cryptoasset-firms-can-request-pre-application-meetings-11-may-2026 (confirmed 3 May 2026); Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (made February 2026).

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

Crypto Regulatory

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