The UK cryptoasset timeline to 25 October 2027, and the longstop that is a day out
The UK cryptoasset regime has a small number of dates that actually govern anything, and a larger number that circulate as shorthand. This is the calendar as it appears in the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102) and in the FCA material made under it, with the source for each.
February 2026: the instrument is already partly in force
SI 2026/102 was made on 4 February 2026. Regulation 1(3) brings part of it into force 21 days after making — so from late February 2026 — for the purposes of FCA rule-making and to enable applications for a relevant cryptoasset permission to be made and determined. The statutory power to apply therefore predates the gateway opening by roughly seven months. This is the least-reported date on the list and the one that most often surprises firms, who assume nothing legal exists until the FCA opens its window.
30 September 2026 to 28 February 2027: a direction, not a cut-off in the instrument
These dates are not in the SI at all. They come from an FCA direction under regulation 52, published on 20 February 2026, which runs the application period from 9:00am on 30 September 2026 to 11:59pm on 28 February 2027. Regulation 52(2) constrains what the FCA can specify: the period must be at least 28 days, and its last day must fall at least 28 days before full commencement.
The common description of 28 February 2027 as "the gateway closes" is wrong, and regulation 52(5) says so in terms: a direction under paragraph (1) does not prevent applications for a relevant cryptoasset permission being made outside the relevant application period. The FCA states the same on its own page describing how the gateway will operate. Nothing closes. What ends on 28 February 2027 is eligibility for the regulation 53 saving, and the FCA has said it will not expedite an application to compensate for late submission. That is a serious commercial difference, but it is not a bar to applying, and firms that have written "we missed the window, we are out of the UK" into a board paper have overstated their position.
25 October 2027: full commencement day
Regulation 1(2): subject to paragraph (3), these Regulations come into force on 25 October 2027, defined in the instrument as "the full commencement day". Every transitional period in the SI is measured from this date, which is why getting the arithmetic on it right matters.
24 October 2029: the longstop, one day earlier than commonly published
Regulation 53(3) and regulation 55(9) both express the outer limit as "at the end of the period of 2 years beginning with the full commencement day". The phrase "beginning with" includes the first day of the period, so the two years begin on 25 October 2027 and run to the end of 24 October 2029 — not to 25 October 2029.
Several well-regarded firms, including Travers Smith, K&L Gates and Freshfields, have published 25 October 2029. The difference is one day and it changes nothing about strategy. It does change a wind-down plan that assumes it can trade through the final day, a diarised board decision point, and any contractual term drafted by reference to the longstop. If a date is going into a legal document, take it from regulation 53(3) rather than from a summary.
The money laundering clock runs separately
Regulation 48 substitutes MLR 2017 regulation 54(1A) so that the FCA cryptoasset register covers only firms that are not authorised cryptoasset firms or specified investment cryptoasset firms. Authorised firms come off the MLR register altogether, and registration is replaced by a notification duty in a new MLR regulation 56B, with its own periods: notify before acting or within 28 days of doing so; firms already acting at commencement have 30 days; material changes or inaccuracies, 30 days; ceasing, 28 days. Breach is enforceable as a relevant requirement. These are short periods and they are easy to miss because they sit in a different instrument from the one everyone is reading.
Two dates nobody can give you yet
- The application fee. PS26/14 deferred it to the September 2026 Handbook Notice, three weeks or so before the gateway opens. Track CP26/17. Anyone quoting you a figure today is quoting the MLR registration fee or guessing.
- The amending SI. HM Treasury published a draft amending instrument on 21 April 2026, with submissions closing 22 May 2026. It would insert a new article 9Z10A excluding certain transfers and exchanges of qualifying stablecoins from the dealing and arranging heads, among other changes. As far as we can establish it had not been made as at 16 August 2026. If your business model is stablecoin distribution, the perimeter you are advising against is one HM Treasury has already proposed to move; check the status before you rely on SI 2026/102 alone.
Regulation 65 requires the Treasury to publish a review report within five years of full commencement, and at intervals not exceeding five years after that — the point at which the regime as built gets formally revisited.
The checklist behind this article
The UK FCA Cryptoasset Gateway readiness checklist turns this calendar into a working file: each requirement cited to the regulation, article or policy statement behind it, each figure marked as instrument text or as reporting of it, and the genuinely unresolved items — the application fee and the draft amending SI among them — marked as open rather than filled in with a plausible number. USD 149, with updated editions free as the position develops.
If you are a single-entity UK firm applying inside the window, the checklist covers what you need and that is the end of it. If you are working out the consequences of a late filing, an in-flight refusal, or a group structure where different entities hit different dates, the 48-hour gap check is built for that.