If you are a new entrant preparing for the FCA’s cryptoasset authorisation gateway in September 2026, the compliance framework you submit is not a supporting document — it is the application. A weak framework means delays, additional information requests or refusal. Here is the sequence of work and where to focus your effort.
The Six Steps
- Regulatory perimeter
Map all activities (trading, custody, exchange, advising, etc.) to FCA permission categories. Get this wrong and the entire application is misaligned. - Governance
The FCA assesses people first. Your board and senior management must demonstrate real understanding of crypto risks and regulatory obligations. - AML/KYC framework
Build a risk-based financial crime framework covering CDD, transaction monitoring (on-chain and off-chain), sanctions screening, and SAR processes. This is the most heavily scrutinised area. - Policies and procedures
Develop tailored policies for conduct, complaints, conflicts, data protection, record keeping, and operational resilience. Generic templates will not pass. - Financial promotions
All UK-facing marketing must be compliant before submission — including websites, social media, and apps. Include risk warnings and approval processes. - Capital and financial resources
Plan early for capital adequacy, wind-down, and 12–18 months of financial sustainability. Late issues here can delay approval significantly.
The Sequencing Matters
| Order | Workstream | Duration |
| 1 | Regulatory perimeter analysis | 2–4 weeks |
| 2 | Governance and senior management | 4–8 weeks |
| 3 | AML/KYC and financial crime framework | 4–6 weeks |
| 4 | Compliance policies and procedures | 4–8 weeks (parallel with step 3) |
| 5 | Financial promotions review | 2–4 weeks |
| 6 | Capital modelling and business plan | 2–4 weeks |
| 7 | Application drafting and internal review | 3–6 weeks |
Total realistic timeline: four to six months. With the gateway opening on 30 September 2026, firms that have not begun by spring 2026 are at serious risk of missing the February 2027 deadline.
How LHI Consulting Can Help
We help new entrants build FCA-ready compliance frameworks from the ground up: perimeter analysis, governance design, AML/KYC framework, full policy suite, financial promotions review, capital modelling and application preparation.
| Need help preparing? Contact us for a free 30-minute consultation to assess your readiness.
Email: info@lhiconsult.com | Phone: +44 203 319 5147 | Web: lhiconsult.com |
This article is for general information purposes only and does not constitute legal or regulatory advice. LHI Consulting is a trading style of LHI Holdings Ltd, registered in England and Wales, No. 11496647.
