Crypto and Digital Asset Authorisation: Navigating the FCA Gateway

FCA Gateway Workshop 2026 Recap

On 4 March 2026, Future of Finance and Edwin Coe LLP hosted an exclusive, invitation-only, half-day workshop in London on the upcoming UK cryptoasset regulatory regime, bringing together cryptocurrency and digital asset firms and financial services businesses to examine the new authorisation framework being introduced by the Financial Conduct Authority (FCA) in 2026. Discussions focused on the FCA’s threshold conditions, the authorisation application window between September 2026 and February 2027, the strategic implications of the Saving and Transitional Provisions, and the operational, governance and regulatory preparations firms must undertake to secure authorisation and operate successfully under the UK’s new cryptoasset compliance regime.

See Event Page ↗

Jump to Gallery ↓

With thanks to:

The Event in Numbers

4

Sessions

5

Speakers

20

Registered Delagates

17

Represented Companies

Key Takeaways

Keynote

The FCA has a binary methodology: a business either must be authorised or cannot be authorised, because it does not want to give any business that cannot be regulated (such as NFTs or utility tokens) the opportunity to claim the benefits of any measure of regulation short of full authorisation. The FCA prefers a UK legal entity with a meaningful physical presence and a comprehensible corporate structure in which the executive management and the beneficiaries are easily identifiable.

Mind and management

Insufficient capital and liquid assets, especially in the form of fiat currency cash and other assets such as government securities, is the main reason FCA authorisation applications fail. Bother with the back office because the other main reason applications for FCA authorisation fail is inadequate non-financial resources to support the business, such as lack of compliance staff, deficient governance and technology controls and a weak operational infrastructure. Authorisation is impossible without a three-to-six-month wind-down plan if the business gets into trouble, because the FCA expects a proportion of authorised firms to fail, though firms have a considerable degree of control over when the plan is triggered. Sandboxes have proved useless as a pathway to authorised status, as a 2025 Future of Finance analysis of the 152 companies that passed through the FCA Sandbox between 2016 and 2021 showed (see the “Event Resources and Materials” tab for the research analysis results).

Capital and appropriate resources

When it comes to proving personal integrity, it is best to over-disclose, no matter how impertinent or prurient the interest of the FCA appears to be. The FCA expects non-executive directors (NEDs) to have experience of working at a regulated firm and to be genuinely independent of the executive management. The cost of authorisation is real: it takes up to six months if the FCA raises no queries and up to 12 months if it does, and the FCA retains the option to spin it out even longer, since every question “stops the clock”; and the cost of the authorisation process alone is likely to be £250-350,000. The cost of remaining compliant is real: compliance officers must be hired and paid, systems and controls designed and implemented, including quarterly capital and liquidity reviews, and regular reporting to the FCA reduced to a matter of routine. Activities must be documented and records kept of how and when decisions were made: if in doubt, make a record. The FCA Consumer Duty means authorised firms distributing products to retail consumers must be fee-earning: they cannot pay for order flow, engage in margin lending or collect the yield on a Stablecoin. The FCA Consumer Duty also means authorised firms must make sure retail consumers are offered “fair value,” given adequate information about their investments regularly and achieve “good outcomes” from their investments.

When it comes to proving personal integrity, it is best to over-disclose, no matter how impertinent or prurient the interest of the FCA appears to be.

With a failure rate of 87 per cent, authorised status is a barrier to entry that serves as a defensive moat for those behind it, because it offers access to institutional capital and banking services and the right to charge premium prices; for those that fail to clear the regulatory hurdle, non-authorisation is an “extinction level event.”

The value of authorised status

Content coming soon, please check back later.