TK Global OS — Regulatory notesCryptoasset licensing: United Kingdom, Kenya, Brazil

What capital you need for FCA cryptoasset authorisation, by activity

UK Published 2026-08-12

The FCA published its final prudential rules for cryptoasset firms in PS26/12 on 30 June 2026. Two sourcebooks apply: COREPRU, the cross-sector core prudential regime, and CRYPTOPRU, the crypto-specific one. A firm carrying on cryptoasset activities is a CRYPTOPRU firm and both apply to it.

The permanent minimum requirement

The FCA confirmed the figures it consulted on. Its words in PS26/12: "After carefully considering all the feedback, our final rules set out the PMR and FOR as consulted on."

A firm carrying on more than one activity takes the highest applicable figure, not the sum. A platform that also deals as principal and holds customer assets sits at GBP 750,000.

There is no transitional relief

This is the part firms underestimate. The FCA's words: "We do not think transitional arrangements are appropriate. The PMR is a threshold condition for authorisation." It went on to say that the lead time from the policy statement to the gateway opening, with authorisation on or after 25 October 2027, provides a reasonable planning period.

In practice that means the money must be in place at authorisation. It cannot be phased in, and a commitment letter is not capital. For a firm that has been operating under money laundering registration with no prudential requirement at all, this is the single largest new obligation in the regime.

What sits on top of the PMR

Your own funds requirement is the higher of three numbers: the permanent minimum requirement; the fixed overheads requirement, which is a quarter of annual relevant expenditure — three months of running costs, taken from prior-year audited figures; and the K-factor requirement. The structure is deliberately shaped like MIFIDPRU.

The K-factors confirmed in the final rules are activity and exposure based:

K-CCD for counterparty default, also with a 40 per cent volatility adjustment, and K-CON for concentration complete the set.

Liquidity

Stablecoin issuers face an issuer liquid assets requirement calculated by reference to backing assets, with at least 5 per cent of the backing pool held in on-demand deposits. Other cryptoasset firms face a basic liquid assets requirement; CP25/15 proposed one third of the fixed overheads requirement held in core liquid assets, and the final figure should be checked against chapter 5 of PS26/12 rather than assumed. All firms must assess liquidity over a rolling 90-day period and review a 12-month funding profile.

The dependency nobody schedules

The fixed overheads requirement is calculated from prior-year audited figures. A firm that has never been audited cannot produce that number on demand, and an auditor engagement is not a two-week task. Working back from a February 2027 filing, that dependency starts in autumn 2026. It is the most common reason a capital calculation is still open when everything else is finished.

The checklist behind this article

Everything above is drawn from the same working document I use when I read a file: an 11-page readiness checklist for the FCA cryptoasset gateway, with the rule, article number or published FCA statement cited behind every item, and the open questions marked as open rather than guessed at. It covers the seven activity heads with their RAO article numbers, the permanent minimum requirement by activity, the application pack and its attachments, SM&CR, and the eight failure modes the FCA has published. It is USD 149, and buyers get the updated edition free when the September 2026 fee notice and the autumn perimeter guidance land.

If your situation is straightforward, the checklist is genuinely enough and you will not need to speak to me. If it is not, the 48-hour gap check reads what you have and returns a written list of what is missing, in the order it should be fixed.

Get the note when something actually changes

The UK gateway, Kenya's VASP Act and Brazil's BCB regime. Only when a rule, date or figure moves — and primary sources are always marked separately from press reporting.

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