SM&CR for cryptoasset firms: you are almost certainly a Core firm
SM&CR applies in full, from commencement
PS26/13 confirms that the Senior Managers and Certification Regime applies to authorised cryptoasset firms, and that it applies in full rather than in some reduced crypto-specific form. It bites when the regime commences in October 2027. The elements are the familiar ones: senior management functions requiring FCA approval, prescribed responsibilities allocated to named individuals, the certification regime for staff whose roles can cause significant harm, and the conduct rules.
There is no crypto carve-out and no phase-in of the substance. A firm that is authorised is inside the regime.
The Enhanced thresholds are set where almost nobody reaches them
SM&CR sorts firms into tiers, and the tier determines how much of the regime applies. For cryptoasset firms PS26/13 sets two Enhanced thresholds:
- GBP 100 billion in combined safe custody assets and client cryptoassets, for firms safeguarding cryptoassets (paragraph 7.18).
- GBP 20 billion in backing assets for UK stablecoin issuers, calculated as a three-year rolling average (paragraph 7.19).
The FCA is direct about what this means in practice. At paragraph 7.4 it says it does not anticipate many, if any, firms conducting cryptoasset activities exclusively would meet the Enhanced threshold when the regime commences in October 2027.
The consequence is that essentially the whole cohort should plan on being a Core firm. That is not a downgrade or a lighter regime to be relieved about. Core is the baseline, and the baseline is substantial.
What being Core actually requires
A Core firm has to identify its senior management functions and get each holder approved by the FCA before they perform the role. It has to allocate the prescribed responsibilities across those individuals, without gaps and without responsibilities parked with someone who has no realistic ability to discharge them. It has to identify and annually certify its certification staff. And it has to train its people on the conduct rules and report breaches.
Enhanced firms carry more on top, including a Management Responsibilities Map and approval for a further set of supplemental senior management functions such as the Chief Finance Officer role. Most crypto firms will not need those. What they will need is a defensible answer to a simpler question: who is accountable for each part of this business, and can they show it.
Why this lands during the application, not in 2027
The commencement date is October 2027, which is comfortably distant. The approvals are not. Senior manager candidates form part of what the FCA assesses at the gateway, and the application window runs from 30 September 2026 to 28 February 2027. A firm that has not decided who holds which function, and cannot evidence that those individuals are fit and proper and have the time and competence for the role, is not ready to file, whatever else is finished.
The awkward cases are predictable. Founder-led firms where one person holds every material responsibility. Groups where the decision-making sits with an overseas parent and the UK entity has a thin senior team. Firms whose compliance function is an outsourced arrangement with no individual willing to be approved. Each of these is fixable, but not in weeks, because fixing them usually means hiring.
Practical steps that are worth taking now
- Draft the responsibilities map even though a Core firm is not required to file one. It is the fastest way to find the gaps and the overlaps.
- Name candidates for each senior management function and confirm they are willing to be approved. Willingness is not a given.
- Identify the certification population early. It is usually larger than firms first estimate.
- Check whether your governance arrangements actually support UK-based accountability, and if the answer is uncomfortable, treat it as a hiring question rather than a drafting one. If you are unsure how the threshold conditions interact with an overseas parent, take advice on it rather than assuming.
The checklist behind this article
Our UK gateway readiness checklist is an 11-page document covering what has to be settled before you file, governance and senior manager arrangements among it, with each item cited to a rule, an article number or a published FCA statement, and open questions marked as open. USD 149, and the updated edition is free when the September 2026 fee notice and the autumn perimeter guidance land.
If you have a UK senior team and know who holds what, the checklist is all you need to confirm the file is complete. If your accountability sits offshore or one person currently holds everything, a 48-hour gap check is a better use of the time you have left.