The regulatory business plan is the spine of an FCA cryptoasset application
The FCA published an information document for the cryptoasset authorisation application form on 8 July 2026. One sentence in it does more work than any other: "This question requires you to upload your firm's regulatory business plan (RBP)." Everything else in the file — the forecasts, the compliance monitoring plan, the senior manager applications — is read against that document. If the plan is generic, the rest of the file has nothing to be consistent with.
What the form actually asks for
The FCA's information document sets the form out in sections: firm details and organisation structure; business model and strategy; governance, compliance and risk; and activity-specific sections covering stablecoin issuance, safeguarding, staking, lending and borrowing, intermediaries and trading platforms. Alongside the RBP it asks for:
- Financial forecasts — "Your firm will need to provide financial forecasts as part of its application."
- An IT self-assessment and information on IT controls.
- A compliance monitoring plan, which the FCA describes as needing to demonstrate "that it understands the risks it faces and it plans to control them".
- Separate applications for the approval of any senior managers.
Those are quotations from the FCA's own document, not from commentary on it. The document itself is dated 8 July 2026; we have seen a page count for it quoted in several places and have not been able to verify it, so we do not repeat it.
The plan has to name your activity heads by article number
Permission is granted by reference to activities specified in the Regulated Activities Order as amended by regulation 40 of SI 2026/102. The relevant articles are 9M, 9N, 9S, 9T, 9W, 9Y and 9Z6 — seven of them. You will also see the regime described as nine activities, and both counts are right. Article 9N(1) has two limbs, and article 9Y has two paragraphs, 9Y(1) and 9Y(2), each expressed as "a specified kind of activity". Seven is a count of articles; nine is a count of specified activities. Published summaries give one number or the other and generally do not reconcile them.
The practical point is that an RBP saying "we will operate a cryptoasset exchange" has not asked for anything the FCA can grant. It has to say which articles, on which limbs, for which client types.
Note also that the heads do not stack automatically. Articles 9V(2), 9X(2) and 9Z5(2) carve 9M, 9S and 9Z6 out of the dealing and arranging heads — so a firm issuing a qualifying stablecoin is not, by that fact alone, also dealing in it.
And the exclusions you are relying on
Chapter 2B of the amended RAO runs to 25 articles, of which 18 are exclusions rather than activity definitions. Most authorisation files are silent about them, which is a mistake: an exclusion you rely on but do not state is a perimeter position the FCA will discover later rather than agree with now. The ones that most often matter:
- Article 9Z10, the merchant exclusion — activity "carried on for the purpose of the sale of goods or supply of services, by a supplier to a customer", extended group-wide on both sides.
- Article 9Z11, incidental to a profession or business — four cumulative conditions, one of which is that the profession is supervised by a body listed in the DPB Order 2001.
- Article 9Z9, staking technical services including "the operation of a validator node", provided the firm does not hold itself out to the public.
- Article 9O group custody, article 9Q temporary settlement holding, and article 9U absence of holding out for principal dealing.
The forecasts have to reconcile to the plan
The permission set described in the RBP sets the capital number in the forecast. Under PS26/12 the permanent minimum requirement is GBP 75,000 for dealing as agent and arranging, GBP 150,000 for operating a trading platform, staking and safeguarding, GBP 350,000 for stablecoin issuance and GBP 750,000 for dealing as principal. The highest applicable figure applies — not the sum — and own funds are the higher of the PMR, the fixed overheads requirement and the K-factor requirement, where K-SII is 1% of stablecoins issued and K-RCS is 0.04% of assets safeguarded. There is no transitional relief.
Because the fixed overheads requirement is derived from prior-year figures, the forecast and the plan are usually built by different people on different assumptions, and that is where files come apart.
Dates, and one piece of framing worth correcting
Regulation 1(2) of SI 2026/102 provides that the Regulations come into force on 25 October 2027, "the full commencement day". Regulation 1(3) has had parts of the instrument in force since 21 days after making, to allow FCA rule-making and to enable applications to be made and determined. The FCA's direction under regulation 52, published 20 February 2026, runs the application period from 9:00am on 30 September 2026 to 11:59pm on 28 February 2027.
That period is widely described as the gateway closing. It is not. Regulation 52(5) says a direction "does not prevent applications for a relevant cryptoasset permission being made outside the relevant application period", and the FCA says the same on its own pages. What ends on 28 February 2027 is eligibility for the regulation 53 saving; the FCA has said it will not expedite a late application. The application fee has still not been published — PS26/14 deferred it to the September 2026 Handbook Notice, roughly three weeks before the window opens. Do not put a figure for it in your forecast.
The checklist behind this article
The UK FCA Cryptoasset Gateway readiness checklist works through the authorisation file item by item, including the article-by-article permission mapping and the exclusions the RBP should state: every item is cited to the article, regulation or policy statement behind it, every figure is marked as instrument text or as reporting of it, and the questions that are genuinely still open — the application fee among them — are left marked open rather than guessed. USD 149, with updated editions free as the position develops.
If you are applying for a single activity head with no group arrangements, the checklist is the whole job and you will not need anything else from us. If your plan spans several heads, leans on one of the Chapter 2B exclusions, or has a forecast that does not yet agree with the permission set, the 48-hour gap check looks at your specific facts.