At 7am on 30 September 2026, the FCA will open its application gateway for firms seeking permission to carry out activities under the UK’s new cryptoasset regime. The application period is expected to close on 28 February 2027, ahead of the regime’s expected start on 25 October 2027.
For crypto firms, the first job is to establish which activities fall within the new rules and what permissions they need. For marketing and compliance teams, there is a second question: will their processes for reviewing financial promotions stand up as the business moves into a broader regulatory framework?
Who needs to apply for FCA crypto authorisation?
The new regime brings activities such as operating a cryptoasset trading platform, dealing in or arranging cryptoasset transactions, safeguarding cryptoassets, arranging staking and issuing qualifying stablecoins within the FCA’s regulatory perimeter. Firms should assess their specific activities against the FCA’s perimeter guidance, including where services are provided into the UK from overseas.
An existing FCA registration does not automatically become permission under the new regime. Firms registered under the Money Laundering Regulations will need to apply for authorisation if they intend to carry out a newly regulated activity. Firms already authorised under the Financial Services and Markets Act will need to apply to vary their permissions.
Why does the application window matter?
The FCA expects firms to apply between 30 September 2026 and 28 February 2027. If a firm applies during that period and its application remains undecided when the regime starts, a saving provision may allow it to continue providing cryptoasset services while the application is determined, subject to the relevant conditions.
Firms can apply after the window closes, but the consequences differ. If a late applicant has not secured the required permission by commencement, it may enter a transitional provision that limits activity to what is necessary to fulfil existing contracts. It cannot enter into new contracts with UK customers while relying on that provision. Firms that do not apply before commencement must run off their UK cryptoasset business before the new regime begins.
That makes the window a practical deadline for firms planning to continue serving and acquiring UK customers.
What changes for crypto marketing?
Crypto financial promotions are already regulated in the UK. Since October 2023, qualifying promotions aimed at UK consumers have been subject to FCA requirements across channels including websites, apps, social media and online advertising. Firms must consider requirements such as the obligation for promotions to be fair, clear and not misleading, as well as applicable risk warnings and controls in the customer journey.
The new regime broadens the regulatory responsibilities of firms carrying out the newly regulated activities. Authorised firms will need to meet the FCA’s applicable standards on an ongoing basis, including requirements concerning governance, systems and controls and the Consumer Duty.
For a marketing team, this makes the approval process worth examining now. A firm may have product pages, paid ads, emails, social posts and influencer content moving through different teams at once. It needs a reliable way to identify the requirements for each communication, review the right version, resolve feedback and retain a record of the decision.
What about firms using a section 21 approver?
Some crypto firms currently rely on an authorised firm to approve their financial promotions under section 21 of FSMA. Those arrangements need to be considered alongside the firm’s authorisation plans.
The FCA has published specific guidance on how the application window, saving provisions and transition affect firms using section 21 approvers. Firms should review their own route for communicating promotions as part of their wider preparation for the regime.
What should firms do now?
The immediate priority is to map the firm’s activities against the new regulatory perimeter and determine whether it needs authorisation or a variation of permission. The FCA offers a pre-application support service for firms preparing an application.
Marketing and compliance teams can use the same period to review how promotions move from draft to publication:
- Which rules and internal policies apply to each product, claim, audience and channel?
- Who reviews higher-risk communications, and which lower-risk content can follow a proportionate approval route?
- Can the team retrieve the version that was approved, the feedback it received and the evidence behind the decision?
- How are changes to live content, including affiliate and influencer posts, identified and reviewed?
These are operational questions, but they have a direct effect on how confidently a firm can market under the new regime.
At Adclear, we help financial-services teams review promotions against regulatory and firm-specific requirements, manage risk-based approvals and keep a record of what was reviewed and approved. For crypto firms preparing for FCA authorisation, the coming months are an opportunity to put those processes in place alongside the application itself.
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