CRYPTOPRU: the UK's prudential rules for cryptoasset firms
Two sourcebooks, and one number that matters
The FCA's final prudential rules for cryptoasset firms were published on 30 June 2026 in PS26/12. They sit in two new sourcebooks: COREPRU, the core prudential sourcebook, and CRYPTOPRU, the prudential sourcebook for cryptoasset firms (PS26/12, para. 2.1). Firms usually ask what "the" capital requirement is, as though each permission carried a price. It does not. Under para. 3.24, a firm's own funds requirement is "the higher of its PMR, FOR or KFR" — the permanent minimum requirement, the fixed overheads requirement, or the K-factor requirement.
The permanent minimum requirements
PS26/12 paras. 3.3 and 3.4 set the permanent minimum requirement by activity:
- GBP 750,000 — dealing in qualifying cryptoassets as principal
- GBP 350,000 — issuing qualifying stablecoins
- GBP 150,000 — operating a cryptoasset trading platform, staking, and safeguarding qualifying cryptoassets
- GBP 75,000 — dealing as agent, and arranging deals
Where a firm holds more than one permission, the highest applicable PMR applies — not the sum. A firm that deals as principal and safeguards is at GBP 750,000, not GBP 900,000. That is the opposite of the multi-activity rule Kenya adopted in reg. 85(6) of Legal Notice 134, where additional activities add 50% of their paid-up figure, so a group planning both markets should not carry the assumption across.
The PMR is usually not the binding number
For most applicants the fixed overheads requirement or the K-factor requirement will exceed the PMR, and the PMR will never be the figure the firm actually holds. The FOR is derived from the firm's fixed overheads for the preceding year, which makes it dependent on prior-year accounts — if no auditor is engaged, that dependency, rather than the capital itself, is the long pole in the file. Read the calculation in COREPRU rather than assuming the MIFIDPRU fraction carries across unchanged.
The K-factors and their rates
The K-factor requirement aggregates activity-based coefficients. From PS26/12:
- K-SII, stablecoin issuance — 1% of stablecoins issued, reduced from the 2% consulted on (para. 3.41)
- K-RCS, cryptoassets safeguarded — 0.04%
- K-CCS, clients' cryptoassets staked — 0.04% (para. 3.33)
- K-CCO, client cryptoasset orders — 0.1% (para. 3.31)
- K-CTF, cryptoasset trading flow — 0.1% (para. 3.32)
- K-NCP, net cryptoasset position — 40% position risk adjustment (para. 3.85)
- K-CCD, cryptoasset counterparty default — 40% volatility adjustment for qualifying cryptoassets (para. 3.98)
Two refinements are worth reading in the sourcebook text before you model anything. Law-firm analysis of PS26/12 reports that K-CCO now excludes UK qualifying stablecoins, and that K-CCD applies a 100% adjustment to non-qualifying cryptoassets. Those are reported readings of the final rules rather than quotations from them, and the numbers are large enough to be worth confirming against CRYPTOPRU itself.
Own funds are also not the whole prudential picture. CRYPTOPRU carries a liquid assets requirement, set out in chapter 5 of PS26/12, and the FCA retained a GBP 10m revenue threshold for the requirements that apply to large qualifying cryptoasset trading platform (QCATP) firms. Model both alongside the own funds figure.
There is no phasing-in
PS26/12 para. 3.15 declines to phase the regime in, on the basis that firms have lead time between publication and the authorisation gateway. The regime itself commences on 25 October 2027 under reg. 1(2) of SI 2026/102, which reads: "Subject to paragraph (3) these Regulations come into force on 25th October 2027 (the full commencement day)."
The gateway opens at 9:00am on 30 September 2026 under an FCA direction made under reg. 52, and the application period in that direction runs to 11:59pm on 28 February 2027. It is worth being precise about what that end date does, because it is widely described as the gateway closing. Reg. 52(5) provides that a direction "does not prevent applications for a relevant cryptoasset permission being made outside the relevant application period". Nothing closes. What ends is eligibility for the reg. 53 saving, and the FCA has said it will not expedite a late application — which for a firm with a live UK book is a difference of substance, not of wording.
The checklist behind this article
Our UK gateway readiness checklist walks the authorisation file item by item — perimeter mapping across Chapter 2B, the prudential figures above, SM&CR allocation, wind-down — with each item cited to a regulation, article or policy statement paragraph, each figure marked as instrument text or as reporting of it, and the items that are still open (the application fee among them) left marked open rather than guessed. USD 149, with updated editions free as the position develops.
If your permission set is straightforward, the checklist is the whole of what you need. If it is not — overlapping activity heads, a group structure, or a perimeter call you are not certain of — the 48-hour gap check works through your specific facts instead.