FCA opens crypto authorisation 390 days before the regime takes effect

The gap between the two dates is 390 days ^[10]. The gap between the gateway opening and the FCA reopening its own guidance is much shorter. Applications start on 30 September 2026 ^[1]. The consultation on targeted updates to the perimeter guidance comes in October ^[4], the month that begins the next day ^[13].

The two lists overlap. The guidance published now covers issuing qualifying stablecoins, operating cryptoasset trading platforms, dealing and arranging deals, safeguarding cryptoassets and arranging cryptoasset staking ^[2]. The October consultation covers UK qualifying stablecoins, proprietary trading and market making, certain technology providers, decentralised protocols, safeguarding arrangements involving central securities depositaries and financial promotions ^[4]. Stablecoin issuance and safeguarding sit on both ^[11].

The Government set out the legislation bringing cryptoassets into UK regulation in February 2026 ^[6], about 20 months before the regime binds ^[12]. David Geale, the FCA's executive director of consumers, payments and competition, said: "This guidance gives firms the clarity they've asked for so they can prepare with confidence." ^[5]

For a firm that custodies and trades, the calendar is a budget line. For a firm running its own book as a market maker, or operating something that answers to the description of a decentralised protocol, the scope of the perimeter is not settled until the October consultation is resolved ^[4]. The FCA did not give a date for the final updated guidance ^[8].

There are two ways this runs from here. If October's changes turn out narrow, filing on day one costs little and buys queue position, and the 390 days become a scheduling exercise ^[10]. If they do not, the firms in those six named areas hold back and the applications compress into 2027 against a fixed 25 October date ^[1]. On the evidence I would expect the second, because proprietary trading, market making and decentralised protocols are on the consultation list ^[4] and those are whole business models. One thing settles it the other way: an October consultation with a short closing date and final text published early enough for a firm to file against it in 2026.