The Financial Conduct Authority opened its authorisation gateway for the new UK crypto regime on 30 September, launching an application window that shields existing Bitcoin providers from immediate disruption. Firms that submit a pending application by the deadline may continue serving UK customers and take on new business when the full regime begins.
The window closes on 28 February 2027, while the full regulatory framework starts on 25 October 2027. The February date marks the cut‑off for qualifying for the temporary “saving provision”, which offers provisional protection to applicants awaiting final approval rather than imposing an abrupt service halt.
Key protection details
Eligible existing firms that apply within the window can keep their relevant services operational, including new business, as long as their applications remain undecided at the regime’s commencement. The protection is limited to the specific activities listed in the application and does not grant blanket authorisation for all services offered by a platform.
This statutory safeguard is time‑bound: the saving clause ends two years after full commencement, and filing an application does not guarantee eventual authorisation. The protection also extends to refusals that are still subject to review, but the FCA may place a firm into restricted run‑off if required for criminal enforcement, consumer protection, or other regulatory objectives.
Impact on late applicants
Platforms may still file an application after February, but a late applicant that submits before the regime’s start and remains pending on 25 October 2027 will be covered by the transitional provision while its case is assessed. If a firm is already authorised before that date, it avoids the pending‑application restrictions.
Under the transitional route, firms may only conduct newly regulated activities necessary to fulfil contracts entered into before the transition period begins. This prohibits new contracts with both existing and new UK customers, meaning that an existing account alone does not preserve the ability to offer fresh business.
The run‑off arrangements last a maximum of two years. Firms must notify the FCA and existing contract parties, and customer notices must explain the lack of relevant authorisation and any material changes to asset protection, dispute resolution, or compensation arrangements.
For Bitcoin providers, the regulated activities include trading platforms, dealing and arranging transactions, and custody. Overseas firms serving UK consumers may also fall within scope, though specific intermediary and custody exceptions apply under the territorial rules.
Firms that fail to apply before the regime’s commencement must complete their UK run‑off beforehand. An application rejected for insufficient information is treated as non‑existent unless a valid submission is made later.
