The operating answer
FCA PS26/18 was published on 16 September 2026. The FCA identifies 25 October 2027 as the start of the new cryptoasset regime. Record the distinction between existing obligations, future requirements and unresolved questions before changing a product or an application plan. [FCA] [FCA]
The workflow below is our editorial synthesis. Regulatory statements link to primary sources. Examples are hypothetical, and applicability requires a firm-specific assessment.
Use a status field, not just a date
A consultation, a policy statement, made legislation, Handbook guidance and an application gateway are different events. A useful tracker records what each document actually does. A date alone can make a proposal look like an obligation or make a published rule look as though it is already in force.
For each entry, keep the issuing body, publication date, effective date if stated, scope and the primary document. Where commencement depends on another step, record that condition. Do not replace an unknown date with an estimate that looks official.
Write down the activities
Describe the service in operational terms: what the customer can do, which legal entity contracts with them, who holds assets or money and which parties execute instructions. This is the starting point for a perimeter analysis.
A marketing term such as “wallet” can cover different arrangements. The working file should distinguish the actual activities rather than assuming the label determines the outcome. Map the product to the current official guidance and retain the advice used for difficult judgments. [FCA]
Keep two requirement registers
Maintain one register for requirements applicable to the business now and another for published future changes. Link them where the same control is affected, but do not merge their statuses. A team preparing for a future regime still needs to meet its existing obligations.
The separation also improves resource planning. A change that is necessary for a future application may have a different dependency from a defect in a current control. Both can be important; they should not compete inside an undifferentiated list called “regulatory work”.
Record what existing status does not prove
A current register entry should be checked for the precise legal entity, status and activities. Do not treat a limited registration as approval of every service a group markets. Likewise, a future authorisation plan is not a present permission. [FCA]
Keep customer-facing descriptions aligned with the evidence. Product pages, contracts and staff scripts should not imply that a future approval has already been obtained. Record who reviews these claims when the regulatory status changes.
Turn the future date into internal dependencies
The FCA's stated commencement date of 25 October 2027 belongs in the external milestone column. Internal milestones should then be labelled as the firm's own plan: activity assessment, governance decisions, system changes, testing and application preparation. [FCA]
Assign a dependency and an owner to every internal date. A policy cannot be tested before the underlying process exists. A contractual change may require third-party agreement. Keep these constraints visible so that a single target date does not hide an impossible sequence.
Review the source before declaring a change complete
Close an action only against the applicable document version and the intended business configuration. If guidance is updated, identify which conclusion or control changes. Retain the earlier assessment so a reviewer can understand the decision made at the time.
The tracker on this site is a dated research snapshot, not a regulatory alert service. Its role is to organise the questions and link to the issuing authority. It cannot confirm the eligibility or authorisation position of a particular business.
| Event | Status in this edition | How to use it |
|---|---|---|
| PS26/18, 16 September 2026 | Published perimeter guidance | Read against the actual activity |
| New regime, 25 October 2027 | Future commencement stated by FCA | Plan dependencies; do not describe it as current authorisation |
| Firm application preparation | Internal workstream | Use the current FCA application guidance |
Working checklist
Progress is saved only in this browser when local storage is available. Ticks record your work; they are not a compliance score.
Method, assumptions and limits
We use official sources for regulatory facts and label our suggested workflows as editorial methods. Illustrative examples are hypothetical. The content does not establish the position of any individual firm and is not a prescribed regulator template.
Source review date: 12 November 2026. No automatic monitoring is running. Check the underlying document, applicable entity, activity and jurisdiction before using this material.
Read the full methodologyQuestions, answered.
Is the 2027 regime already in force?
The FCA source cited here gives 25 October 2027 as commencement. The tracker labels it as future as at the editorial review date.
Does registration equal permission for every crypto service?
No. Check the exact legal entity, status and activity scope. Do not infer wider permission from a group brand or a narrow registration.
Is the tracker updated automatically?
No. It is a dated editorial snapshot. Every row links to an official source that should be checked before acting.
Sources & scope
Primary sources used for this research edition. Document dates and commencement dates are different fields. Recheck the issuing authority before acting.
- FCA: PS26/18: cryptoasset perimeter guidancePolicy statement · source reviewed 12 November 2026
- FCA: A new regime for cryptoasset regulationRegulatory programme · source reviewed 12 November 2026
- FCA: Financial Services RegisterRegister guidance · source reviewed 12 November 2026
- FCA: How to apply for authorisation or registrationApplication guidance · source reviewed 12 November 2026