Summary
An estimated 200-500 firms will enter the FCA's 5-month application window (Sept 30, 2026 - Feb 28, 2027). Currently ~50 firms hold FCA MLR registration — the new perimeter is materially wider. Application preparation requires 4-6 months and costs vary significantly. The FCA's historic MLR approval rate was ~14%, but FSMA approval is expected higher for prepared firms.
Key Points
- Application window: Sept 30, 2026 to Feb 28, 2027 (5 months); full regime commences Oct 25, 2027
- 7 new regulated activities: issuance, safeguarding, trading platforms, dealing as principal/agent, arranging, staking
- Territorial scope extends to non-UK firms targeting UK consumers — reverse solicitation narrowly drawn
- Capital requirements tiered by activity (being finalised); stablecoin issuers face highest requirements
- SM&CR applies in full — senior management hiring is typically the largest budget item
- MLR registration does NOT auto-convert to FSMA authorisation
- FCA's PASS (Pre-Application Support Service) available from July 2026 — optional, free, high information threshold
- Firms that miss the window face restricted transitional provisions: can only service pre-existing contracts