The audited accounts dependency that decides your filing date
Why this is a sequencing question, not an accounting one
The FCA cryptoasset gateway opens on 30 September 2026 and closes on 28 February 2027. Capital is not something you demonstrate after authorisation. PS26/12, published 30 June 2026, declined to provide transitional arrangements on the basis that the permanent minimum requirement is a threshold condition for authorisation (paragraph 3.14). If your binding capital number turns out to be driven by your expenditure rather than by the flat permanent minimum, and if establishing that number depends on an audit you have not yet commissioned, then the audit is on the critical path to your filing date.
What the fixed overheads requirement is
A firm's capital requirement is the higher of its permanent minimum requirement (PMR), its fixed overheads requirement (FOR) or its K-factor requirement (PS26/12, paragraph 3.24). The higher of the three, not the sum.
The FOR is set at one quarter of relevant annual expenditure, calculated on the previous year's audited expenditure. PS26/12 paragraph 3.5 describes its function: a stabilising measure ensuring firms hold adequate capital to withstand the costs associated with an orderly wind-down. Paragraph 3.6 puts the design goal plainly — simplicity and proportionality, recognising that the FOR is designed to approximate potential wind-down costs.
The audit myth, corrected
It is widely said that a firm without audited accounts cannot compute a FOR and therefore cannot apply. That overstates the position. PS26/12 paragraph 3.5 records that the FCA proposed to accommodate newer firms by allowing them to use unaudited figures where necessary. The feedback section of the policy statement does not record that proposal being withdrawn.
Two cautions. First, that sentence describes the consultation proposal; confirm the final wording in the made instrument text before you rely on it, because a policy statement narrative is reporting of a rule, not the rule. Second, the concession is for newer firms. A firm that has been trading under MLR registration for three years and simply never appointed an auditor is not a newer firm, and should expect the audited figure to be asked for. The real dependency is not the audit certificate. It is having an expenditure ledger clean enough that someone can classify every line against the deduction rules below.
What comes out, and what does not
PS26/12 sets out crypto-specific treatments that generic prudential templates do not carry (paragraphs 3.19 to 3.22):
- Gas fees: firms can deduct 100% of gas fees passed on to customers, and 80% of other gas fees.
- Not deductible: global shared services, intercompany and compliance technology, amortisation, depreciation and cybersecurity costs.
- Research write-offs may be deducted if they are non-recurring.
- Costs settled in cryptoassets are treated the same way as the equivalent costs settled in fiat.
- Where third-party arrangements give rise to expenses incurred on behalf of the firm, the firm must capture these to reflect its operating footprint. Intra-group service level agreements are dealt with under this heading — COREPRU 4.3.5R, expenses incurred on behalf of the firm by third parties.
That last item is where most group structures get a surprise. If a parent absorbs your engineering, compliance or infrastructure cost, the expense does not vanish from your FOR because it does not appear in your own profit and loss account.
The FOR is a moving number
PS26/12 retained the dual test for a material increase: either a 30% increase in projected relevant annual expenditure, or a GBP 2m increase in the FOR (paragraphs 3.19 to 3.20). A firm scaling headcount through the application window can trip that test between drafting its financial forecasts and being authorised. Build the test into the forecast, not into a later remediation.
When the FOR overtakes the flat minimum
The permanent minimums are GBP 75,000 for dealing as agent and for arranging deals, GBP 150,000 for operating a trading platform, for staking and for safeguarding, GBP 350,000 for stablecoin issuance and GBP 750,000 for dealing as principal (PS26/12, paragraphs 3.3 to 3.4). The highest applicable head applies, not the sum of the heads.
On the one-quarter basis, the crossover is straightforward arithmetic rather than a published figure: an arranging or dealing-as-agent firm passes its GBP 75,000 permanent minimum once relevant annual expenditure after deductions reaches roughly GBP 300,000; a safeguarding or trading platform firm passes GBP 150,000 at roughly GBP 600,000; a principal dealer passes GBP 750,000 at roughly GBP 3m. Those crossovers are our arithmetic on the rule, not FCA-published thresholds — treat them as a sighting shot and compute your own after deductions.
The practical consequence: a firm with fifteen staff in London is very likely FOR-bound rather than PMR-bound, and its capital number therefore cannot be settled until its expenditure base is settled.
What is still open
- The final instrument wording on unaudited figures for newer firms — verify against the made text.
- The authorisation application fee, deferred to a later Handbook Notice. It is not the GBP 11,260 MLR registration fee, and it should not be budgeted from any figure you cannot cite.
The checklist behind this article
The UK Gateway Readiness Checklist sets out the authorisation file in order, including the prudential workstream — activity heads, permanent minimum, fixed overheads deductions, the material change test and the financial data template — with each item cited to a rule or policy statement paragraph, each figure marked as instrument text or as reporting of it, and unresolved points such as the application fee left marked open. USD 149, updated edition free as the position develops.
If you have one activity head, a single legal entity and a clean set of accounts, the checklist will get you there without help. If your cost base sits partly in a parent company, or you are unsure whether you are a newer firm for the unaudited-figures purpose, the 48-hour gap check answers that specific question faster than a full advisory engagement.