How to use the FCA pre-application support service without wasting it
The FCA opened its pre-application support service — PASS — to cryptoasset firms on 11 May 2026. Meetings themselves began in July 2026. The service is optional and free of charge, and for most firms it is the only structured conversation they will have with the regulator before the application file is judged on paper.
One date that is regularly reported wrongly
The FCA's announcement says that "from 11 May 2026, cryptoasset firms preparing for the new FSMA regime will be able to request a pre-application meeting", and that "the pre-application meetings will take place from July 2026 but we will schedule them as requests come in".
Several published alerts compress that into a single claim that the service launches in July 2026. The distinction matters commercially. Requests opened in May; July is when the diary starts. Because the FCA schedules meetings as requests arrive, a firm's position in the queue is set by the date it asks, not by the date it is seen.
The FCA describes the meetings as an opportunity for firms "to discuss their plans with the FCA and ask questions before applying for authorisation or variation of existing permissions". Read that literally: it is a discussion, not a determination. Nothing said in a pre-application meeting binds the FCA at assessment, and nothing in the regime makes a meeting a precondition of applying.
The timing arithmetic behind the request
The FCA expects the application period to open on 30 September 2026 and close on 28 February 2027 (FCA, Cryptoassets: how the gateway will operate). Those dates do not appear in the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, SI 2026/102. They come from a direction the FCA made under regulation 52 and published on 20 February 2026.
It is worth being exact about what closing means, because the usual phrasing overstates it. Regulation 52(5) provides that a direction "does not prevent applications for a relevant cryptoasset permission being made outside the relevant application period". The gateway does not shut. What ends is eligibility for the regulation 53 saving — the provision that lets a firm that applied in time keep trading past full commencement while its application is undetermined. The FCA has separately said it "will not expedite our assessment of a firm's application to compensate for its late submission".
There is also more runway than the September date suggests. Regulation 1(3) brought parts of SI 2026/102 into force 21 days after it was made in February 2026, including so that applications may be "made and determined". The statutory power to apply has existed since well before the gateway date; the direction sets the period that carries the saving.
What the FCA has told firms to do first
On its preparation webpage the FCA asks firms to develop "a clear and credible plan that shows they have considered what the new regime will require of them", and sets out steps that include:
- reviewing regulated activities to establish what authorisation is needed;
- checking that permissions match the business model;
- running a gap analysis against FSMA requirements;
- producing a board-approved implementation plan;
- assessing the cost of preparation; and
- investing in professional advice where appropriate.
The FCA also encourages firms to apply as early in the period as they can, and warns that late or poor-quality submissions risk rejection, delay, refusal, or being unable to continue when the regime starts on 25 October 2027.
What to take into the meeting
None of the following is prescribed by the FCA. It is our own view of what turns an hour of free regulator time into something useful.
- A perimeter map to article numbers, not to product names — articles 9M, 9N, 9S, 9T, 9W, 9Y and 9Z6 of the Regulated Activities Order as inserted by SI 2026/102, with the exclusions you are relying on identified by article.
- Your prudential band. Permanent minimum requirements were confirmed in the FCA's prudential policy statement of 30 June 2026: GBP 75,000 for dealing as agent and arranging, 150,000 for operating a trading platform, staking and safeguarding, 350,000 for stablecoin issuance and 750,000 for dealing as principal. The highest applicable figure applies — not the sum — and there is no transitional relief.
- Your audit position. Own funds are the higher of the permanent minimum, the fixed overheads requirement and the K-factor requirement, and the fixed overheads calculation runs off prior-year figures. If you have no auditor yet, say so and ask about it.
- Specific questions, in writing. A meeting spent explaining what your business does is a meeting you have paid for with your own preparation time.
The question PASS cannot answer yet
The application fee is still unpublished. The FCA deferred it in PS26/14 to the September 2026 Handbook Notice, with the consultation running as CP26/17 — which puts the number roughly three weeks before the gateway opens. Do not budget against the old money laundering regulations registration fee; it is a different regime and a different fee. If your board paper needs a figure, mark it as an estimate and flag the publication date.
The checklist behind this article
Our UK gateway readiness checklist is the document version of the preparation the FCA describes: every item cited to a regulation, article or policy statement, every figure marked as instrument text or as reporting of it, and the still-open questions — the application fee, the draft amending SI — left marked open rather than guessed. USD 149, with the updated edition free as the position develops.
If your perimeter is clear and your only question is sequencing, the checklist is enough on its own. If it is not — a group structure, tokenised securities alongside qualifying cryptoassets, or an unresolved safeguarding question — the 48-hour gap check exists for that.