On 30 April 2026, the FCA confirmed in their press release that cryptoasset firms preparing for the new FSMA regulatory regime may request a pre-application meeting via its Pre-Application Support Service (PASS) from 11 May 2026. Meetings will be scheduled from July 2026 as requests are received.
Pre-Application Meetings
The PASS meetings are designed to give firms an opportunity to discuss their plans with the FCA and raise questions ahead of submitting an application for authorisation or a variation of existing permissions. The FCA has previously indicated that PASS meetings are supportive rather than evaluative such that no determination is made at this stage but they provide direct regulatory engagement that can inform and strengthen an application before it is submitted.
What the FCA Expects of Firms
Alongside the PASS announcement, the FCA published guidance setting out what firms should be doing now to prepare for the new regime. The FCA's expectations are clear: firms intending to apply for authorisation should not wait for the application gateway to open before beginning their preparations.
In particular, the FCA expects firms to:
- identify which of the new regulated cryptoasset activities they carry on and determine the type of authorisation required;
- review the proposed scope of permissions and confirm alignment with their business model and risk profile;
- conduct a gap analysis against the expected FSMA requirements, identifying where existing arrangements require strengthening;
- develop a realistic implementation plan, agreed at board level, covering accountability, the changes required, how those changes will be delivered, and the timeline for completion;
- assess the resources and costs associated with preparation, authorisation and ongoing compliance; and
- seek legal, compliance or regulatory advice where appropriate.
The authorisation gateway opens on 30 September 2026. The new regime commences on 25 October 2027. The FCA has encouraged firms to submit applications as early as possible within the application period. As noted in our earlier insight, firms that apply between 30 September 2026 and 28 February 2027 benefit from a saving provision ensuring continuity of service whilst their application remains pending at commencement of the regime.
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