Very helpful summary guide to the process and timing. As always, timing is key. Take advantage of the FCA’s Pre-App Support Service but make sure you have a cohesive story to tell and have considered your governance and controls framework and consumer duty approach.

UK Cryptoasset Regime: FCA PASS Opens July 2026   From July 2026, cryptoasset firms can engage early with the FCA through its Pre‑Application Support Service (PASS) — an opportunity to discuss proposed business models, permissions and expectations directly with a dedicated case officer ahead of submitting an application.   PASS gives firms early clarity, helps identify challenges and supports stronger, more complete applications under the new UK cryptoasset regime.   Why it matters: ⭐ Build early dialogue with regulators ⭐Receive feedback on permissions, models and business plans ⭐Prepare for a smooth transition into the new regime   👉 Firms planning to continue operating or launch new products should engage early. If you’d like guidance on preparing for PASS or navigating the UK cryptoasset framework, get in touch with our team — we’re here to help. John Salmon Sharon Lewis Michael Thomas Bryony Widdup Mark Aengenheister Nick Oxley Lavan Thasarathakumar Mark Orton James Sharp Charlie Middleton

The UK’s new Cryptoasset Regime goes live on 25 October 2027 — and firms should start preparing now.   Once the regime is live, firms carrying out regulated cryptoasset activities will need to be authorised under FSMA by the FCA. The regime introduces new activities (custody, trading platforms, dealing, arranging, staking, stablecoin issuance) and a far wider territorial scope that will capture many overseas firms serving UK retail clients.   How Hogan Lovells can help firms get ahead: ✔ Assess whether activities are considered “in the UK” ✔ Advise on group structuring, including branch and subsidiary models ✔ Advise on UK presence and substance requirements including assessing suitability under the SMCR ✔ Analyse activities, advise on permissions and conduct token analysis ✔ Support with documentation including drafting or obtaining QCDDs   Why start early: • Identify required permissions • Test whether your structure is fit for purpose • Build UK operations and governance well before authorisation   Early engagement will be key to securing FCA approval in 2027. If you’d like to understand how the regime affects your business, our team is ready to support. John Salmon Sharon Lewis Michael Thomas Bryony Widdup Mark Aengenheister Nick Oxley Lavan Thasarathakumar Mark Orton James Sharp Charlie Middleton

From October 2027, cryptoassets will be subject to a comprehensive FCA regime, marking a significant turning point for the sector. Find out which activities are in scope and key steps to authorisation. https://lnkd.in/erNU2Xs8

SEC Commissioner supports 2% haircut for stablecoins in net capital calculation In Commissioner Hester Peirce’s recent speech, "Cutting by Two Would Do," she supports a 2% haircut for payment stablecoins in broker-dealer net capital calculations. While the headline is catchy, this isn’t for just any stablecoin —it’s specifically for stablecoins with stringent reserves (U.S. dollars, Treasuries). The Shift: By allowing a 2% haircut (down from a punitive 100%), the SEC is effectively granting "ready market" status to proprietary positions in payment stablecoins. The Logic: Under the GENIUS Act, these issuers face reserve requirements that are actually more limiting than those of Government Money Market Funds (MMFs). If the reserves are "safer" than an MMF, it stands to reason they shouldn't be treated as non-marketable, capital-draining liabilities. In Singapore: Across the Pacific, the Monetary Authority of Singapore (MAS) imposes a 50% haircut on Digital Payment Tokens (DPTs) when assessing an individual’s wealth for Accredited Investor (AI) status. However, this haircut does not apply to MAS-regulated Single-Currency Stablecoins (SCS). SCS require 1:1 backing in high-quality liquid assets and monthly attestations. The Cross-Border Problem: While the SEC focuses on prudential firm safety and the MAS on investor protection—both agree that a high-quality stablecoin can be treated as cash equivalent. However, as the MAS SCS framework only focuses on tokens issued in Singapore, a US-regulated payment stablecoin—potentially "more stable than an MMF" under the GENIUS Act—could still be hit with a 50% haircut in a Singapore wealth assessment. It is suggested that exceptions be made for non MAS-regulated SCS that are regulated at levels MAS is comfortable with. This may reduce incentive to issue SCS from Singapore but will quite definitely ease friction in onboarding high net worth investors who prefer not to hold non MAS-regulated SCS. #CryptoLaw #SEC #MAS #Stablecoins #GeniusAct #Fintech #Regulation #Web3

The Financial Conduct Authority has published a new webpage (27 February 2026): “Cryptoasset firms: use of s.21 approvers.” For any cryptoasset firm relying on an authorised firm to approve its financial promotions under section 21 FSMA, this is required reading. A few practical points that stood out to me: 🔎 Approval is not a rubber stamp The FCA reiterates that approvers must carry out robust due diligence before approving a crypto financial promotion. That includes understanding the product, the business model, and the target market. If you are the crypto firm, expect real scrutiny, not just document edits. 🧠 Ongoing oversight matters Approval is not a one-off event. Approvers are expected to have systems and controls to monitor ongoing compliance. In practice, that means: • Change management processes • Clear version control of marketing • A documented re-approval process where products or risks evolve Crypto firms should contractually map this out upfront. ⚖️ Regulatory perimeter analysis is key Approvers must be satisfied that the promotion is compliant, including whether the underlying activity triggers other regulatory permissions. If you are tokenising, staking, lending, or operating a platform model, the perimeter analysis needs to be watertight before any promotion is approved. 🧾 Record-keeping and audit trail The FCA makes clear that approvers must retain adequate records of the basis on which approval was given. Crypto firms should assume that: • Substantive questions will be asked • Evidence will be required • Risk disclosures must be precise and tailored 🚫 Approver risk appetite is tightening Given supervisory focus and enforcement history in this area, many s.21 approvers are narrowing the scope of what they will approve - or imposing detailed conditions. If you are shopping around for an approver, be aware that capacity and risk appetite are real constraints. Practical takeaway: If you are a crypto firm planning a UK launch: 1. Engage with a potential approver early. 2. Prepare a proper regulatory perimeter memo. 3. Align your risk warnings and consumer journey with the UK financial promotions regime from day one. 4. Expect iterative drafting - and build time into your launch plan. The FCA’s message is consistent: approving crypto promotions is a regulated activity in its own right, and standards are high. Happy to discuss how firms are navigating this in practice - particularly where cross-border structures or tokenisation models are involved. #FinancialPromotions #Cryptoassets #FSMA #FinTech #UKRegulation

A big change is coming for the crypto sector. From October 2027, cryptoassets will be brought into a comprehensive FCA regulatory regime. In this article, Paul Staples breaks down which activities will be in scope and highlights the key steps firms will need to take on the road to authorisation. https://lnkd.in/eahZM5k8

The UK’s new cryptoasset regulatory regime is due to come into force in October 2027, with firms required to seek authorisation from the FCA to carry out newly regulated activities. In an article published by FT Adviser, Reed Smith partner Romin Dabir outlines how the FCA’s proposed application gateway - opening in September 2026 - will help firms prepare for the transition, and why early engagement and high-quality applications will be critical to avoiding delays. https://lnkd.in/gt5iJ9t2

The #FCA has announced the first cohort for its #stablecoin #sandbox. A few are commenting on the absence of the major global stablecoin issuers like #USDC, #USDT and #USDP. That does not necessarily mean they were rejected. More likely, it reflects how large players typically engage regulators. They tend to pursue direct licensing discussions or supervisory engagement behind the scenes. The FCA cohort instead looks intentionally composed of firms willing to help test UK-specific issuance models and payment use cases in a controlled environment. This is less about picking winners and more about shaping the regulatory architecture. Let's see how quickly the UK converts sandbox insights into a full authorization pathway. https://lnkd.in/egEdhjxu

FCA regime for cryptoasset regulation What firms need to know🤔 The Financial Conduct Authority (FCA) is finalising its regulatory framework for firms offering financial services related to cryptoassets. After a period of anticipation, the FCA has released clearer guidance and set out the timeline for firms to comply. Discover what you can do to prepare through the link in the comments. 🔗 👇 https://lnkd.in/ew-QZADs