What the FCA expects in a cryptoasset wind-down plan
The application form does not ask for one. That is not the point.
On 8 July 2026 the FCA published a 68-page information document describing the authorisation application form for cryptoasset firms. It walks through firm details and governance, business model and strategy, and activity-specific sections for stablecoin issuance, safeguarding, staking, lending, intermediaries and trading platforms. It tells you to upload a regulatory business plan and to supply financial forecasts using the financial data template for cryptoasset firms. It does not contain a section headed wind-down plan.
A number of firms have read that and concluded the subject can wait until the regime commences on 25 October 2027. It cannot. The obligation lives in the prudential rules rather than in a form field, and the case officer reading your business plan and your forecasts is reading them for wind-down adequacy whether or not a question prompts it. A one-paragraph wind-down section is a recognised marker of a thin file.
Where the requirement actually sits: CRYPTOPRU 7
The prudential sourcebook for cryptoasset firms, CRYPTOPRU, contains an overall risk assessment at chapter 7. CRYPTOPRU 7.2.6R requires a firm to assess the financial resources it needs to exit the market without causing material harm. That is instrument text. The FCA's explanation of what the assessment should contain is in GC26/5, a guidance consultation on CRYPTOPRU 7 which closed on 30 July 2026; the finalised guidance had not been published when this was written. So the rule is settled and the commentary on it is not — mark that distinction in your own file rather than presenting draft guidance as settled expectation.
On the draft guidance, the wind-down assessment covers:
- the operational, financial and liquidity needs that may arise during wind-down;
- anticipated reductions in revenue and the additional costs of closing operations;
- the cost of distributing custody assets or unwinding the stablecoin backing assets;
- obligations that must continue to be met during wind-down.
The third of those is the crypto-specific one and the one generic templates miss. Returning client cryptoassets is not a book transfer. It is a key-management, network-fee and counterparty-availability exercise, and the firm doing it is by definition already in distress.
Triggers are part of the plan, not a refinement of it
GC26/5 ties reverse stress testing to the point at which wind-down action may be needed, and says that testing should inform recovery and wind-down planning including the setting of triggers for the decision to wind down. A plan that describes an orderly exit but never says what observable condition starts it is incomplete on its own terms. The FCA has published on this before: TR22/1, Observations on wind-down planning: liquidity, triggers & intragroup dependencies, is cited in the draft guidance and remains the clearest statement of what weak triggers look like.
Documented, and approved by the governing body
CRYPTOPRU 7.5.1R and 7.5.2R require the overall risk assessment to be clearly documented — recording the main judgements, assumptions and evidence — and to be reviewed and approved by the firm's governing body. The FCA's Wind-down Planning Guide says the same thing about the plan itself: the end product is a documented wind-down plan approved by the firm's governing body (WDPG 3.1.4). WDPG 3.1.2 frames the purpose as reducing the risk of negative effects on consumers and market participants; WDPG 3.3.3 gives the scenario set — significant financial losses, loss of key clients, loss of critical infrastructure; WDPG 3.9 deals with the end state, cancellation of permission.
The capital link most firms miss
Wind-down is not only a narrative document. It is priced into your capital. PS26/12 (30 June 2026) describes the fixed overheads requirement as a stabilising measure ensuring firms hold adequate capital to withstand the costs associated with an orderly wind-down, calculated on the previous year's audited expenditure, with newer firms allowed to use unaudited figures where necessary (paragraph 3.5). A firm's capital requirement is the higher of its permanent minimum requirement, its fixed overheads requirement or its K-factor requirement (paragraph 3.24) — the higher, not the sum. 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. The FCA declined to provide transitional arrangements, on the basis that the permanent minimum is a threshold condition for authorisation (paragraph 3.14).
So the sequence runs one way: your wind-down analysis produces a cost, that cost tests whether the fixed overheads requirement is genuinely the binding number, and the answer changes how much capital you must have in place before the gateway closes on 28 February 2027.
What is still open
- Finalised guidance on CRYPTOPRU 7 has not been published; GC26/5 remains a consultation.
- The authorisation application fee has not been published. It was deferred to a later Handbook Notice and is not the GBP 11,260 MLR registration fee. Do not budget against a figure you cannot cite.
The checklist behind this article
The UK Gateway Readiness Checklist works through the authorisation file item by item — the wind-down assessment, the regulatory business plan, the prudential calculation and the SM&CR mapping — with every item cited to a rule, article or policy statement paragraph, every figure marked as instrument text or as reporting of it, and open questions such as the application fee left marked open rather than guessed at. USD 149, and the updated edition is free as the position develops.
If your wind-down question is a straightforward one — a single activity head, no group dependencies, no custody — the checklist is enough on its own. If you are winding down across entities, relying on intragroup liquidity, or holding client cryptoassets you would have to return, a 48-hour gap check is the faster way to find out what your plan is missing.