UK FCA DIGITAL ASSETS APPLICATIONS
From 2021 to present Coburn has a 100% TRACK RECORD of successful digital assets applications to the FCA.
Well prepared firms with quality applications succeed.
QUALITY.ASSURED
EU & UK CRYPTO and NON-CRYPTO APPLICATIONS
Services | FSMA | MLRs | MiCA | EMR/PSR
Case Studies | Regulatory applications | Governance & FSMA topics
Digital Assets FSMA applications open
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Digital assets fsma applications close
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IMMMEDIATE APPLICATIONS:
The FCA will accept applications under the MLRs as normal until the FSMA application window opens on 30 September 2026.
After that they would prefer FSMA applications.
FSMA requirements build on the MLR requirements so nothing is lost by doing an MLR application by 30 September 2026 and then following up with a FSMA application by 28 February 2027. For firms with no experience of working with the FCA this might be a valid strategy.
Our Fixed Price Gap Analysis (see below) can help you decide on the best approach.
| FSMA applications open 30 Sep 2026 ---- close 28 Feb 2027 ---- Regime live 25 Oct 2027 |
| FSMA applications open 30 Sep 2026 ---- close 28 Feb 2027 ---- Regime live 25 Oct 2027 |
| FSMA applications open 30 Sep 2026 ---- close 28 Feb 2027 ---- Regime live 25 Oct 2027 |
| FSMA applications open 30 Sep 2026 ---- close 28 Feb 2027 ---- Regime live 25 Oct 2027 |
| FSMA applications open 30 Sep 2026 ---- close 28 Feb 2027 ---- Regime live 25 Oct 2027 |
| FSMA applications open 30 Sep 2026 ---- close 28 Feb 2027 ---- Regime live 25 Oct 2027 |
SERVICES - Digital assets firms mlr applications
FIXED PRICE MLR GAP ANALYSIS
FIXED PRICE MLR GAP ANALYSIS
FIXED PRICE MLR GAP ANALYSIS
UNTIL 30 JUNE 2026
For firms who wish to know if they are likely to succeed with an MLRs application by 30 September 2026 Coburn can conduct a quick fixed-price gap analysis and advise.
MLR APPLICATION PREPARATION
FIXED PRICE MLR GAP ANALYSIS
FIXED PRICE MLR GAP ANALYSIS
UNTIL 12 JUNE 2026
For digital assets firms without UK registration, but with a strong operating model and licensing elsewhere there is still possibly time to prepare and submit an MLRs application.
MLR APPLICATION ASSURANCE
FIXED PRICE MLR GAP ANALYSIS
MLR APPLICATION ASSURANCE
APPLICATION BY 30 SEPTEMBER 2026
Coburn experts will assess a draft application, identify any gaps and build a roadmap to fix. We then provide application preparation support to ensure all frameworks, policies and controls are in good order and complete and evidenced.
SERVICES - Digital assets firms fsma applications
FIXED PRICE FSMA GAP ANALYSIS
FIXED PRICE FSMA GAP ANALYSIS
FIXED PRICE FSMA GAP ANALYSIS
FSMA Regulation builds on the foundations laid by MLR Registration and has core similarities to other recognised regulatory regimes.
Coburn can conduct a gap analysis of existing Business & Operating Model and Regulatory Frameworks to determine how much work is needed to prepare a successful Digital Assets FSMA application. Coburn has decades of FSMA experience. See our Case Studies
FSMA APPLICATION ROADMAP
FIXED PRICE FSMA GAP ANALYSIS
FIXED PRICE FSMA GAP ANALYSIS
The window for FCA FSMA applications opens on 30 September 2026 and closes on 28 February 2027.
Firms wishing to service UK crypto customers unencumbered must apply in the window.
Coburn can assist you by developing a detailed Roadmap & Work-plan for timely and successful
submission of the application.
FSMA APPLICATION PREPARATION
FIXED PRICE FSMA GAP ANALYSIS
FSMA APPLICATION PREPARATION
Digital Assets FSMA applications expand the scope of supervision to be on a par with the supervision of banks & asset managers and to be wider than EMR/PSR regulation of payments firms..
Coburn has decades of experience of regulatory applications and retention under the FSMA regime. Our service coverage such as Regulatory Rules Mapping, SMCR Advisory and Client Assets mean we are well positioned to support the full scope of applications.
Case Studies
UK MLRs - Stablecoin brokerage
UK MLRs - Stablecoin brokerage
UK MLRs - Stablecoin brokerage
At the request of the firm's board Coburn assessed feasibility of applying for FCA MLRs Registration. We then designed the application roadmap and worked closely with Executive Management & the MLRO to document the Regulatory Business Plan, execute the BWRA, document Governance & Compliance Frameworks and submit the application.
UK MLRs - Crypto Exchange
UK MLRs - Stablecoin brokerage
UK MLRs - Stablecoin brokerage
Coburn worked with our partners at Lysis Group to conduct an initial gap analysis, designed the application roadmap and an associated remediation programme and worked closely with Executive Management & the MLRO to submit the application. Coburn also ran several governance and compliance workstreams in the remediation programme.
UK MLRs - Crypto Custodian
UK MLRs - Stablecoin brokerage
UK MLRs - Crypto Custodian
A crypto asset business, a subsidiary of a US Nasdaq-listed company requested assistance with the process to obtain FCA registration. Coburn worked with Lysis Group to provide the client with a highly experienced MLRO and compliance team who worked with senior management to implement required controls and processes.
UK MLRs - Crypto Trading Platform
UK FSMA - Roadmap - Crypto Exchange
UK MLRs - Crypto Trading Platform
A UK-based crypto trading platform sought FCA registration under the Money Laundering Regulations to support its digital asset trading activities. While commercially established, the firm required a comprehensive uplift of governance, AML, and financial frameworks to deliver a complete, regulator-ready application with supporting evidence across business model, risk, and compliance architecture.
EU MiCA - Crypto Broker
UK FSMA - Roadmap - Crypto Exchange
UK MLRs - Crypto Trading Platform
A Norway-based crypto broker registered with the Norwegian Financial Authorities required a MiCA-readiness review and support in applying for MiCA Authorisation. The client had rapidly scaled its operations to meet growing demand in the crypto sector but faced increasing regulatory scrutiny from both national and European regulators. Coburn executed this programme with our partners at Lysis Group
UK FSMA - Roadmap - Crypto Exchange
UK FSMA - Roadmap - Crypto Exchange
UK FSMA - Roadmap - Crypto Exchange
GAP & ROADMAP COMPLETE
APPLICATION IN PROGRESS
Coburn completed a FSMA gap analysis for the UK operation of a global crypto exchange then developed a roadmap for submitting the FSMA application. We are currently working on the first phase of the application work.
SERVICES - OTHER application sERVICES
REGULATORY CHANGE & FRAMEWORK REMEDIATION
REGULATORY CHANGE & FRAMEWORK REMEDIATION
REGULATORY CHANGE & FRAMEWORK REMEDIATION
We cooperate with our partners at Lysis Group to provide a full range of regulatory change and framework remediation services. We can conduct a review to determine what is required then work with you to remediate and update as necessary.
OPERATIONAL REMEDIATION
REGULATORY CHANGE & FRAMEWORK REMEDIATION
REGULATORY CHANGE & FRAMEWORK REMEDIATION
We work with our partners at Lysis Group to provide a full range of operations remediation services. Our experience shows us that this is often an essential element of getting ready to submit a regulatory application.
UK FSMA - TRADITIONAL NON-CRYPTO
REGULATORY CHANGE & FRAMEWORK REMEDIATION
UK & EU PSR/EMR - PAYMENTS & ELECTRONIC MONEY
After decades of working with banks and asset managers Coburn has extensive experience of UK FSMA applications, permissions retention and regulatory intervention and remediation across the full spectrum of governance, risk and compliance. Please enquire for more details.
UK & EU PSR/EMR - PAYMENTS & ELECTRONIC MONEY
UK & EU PSR/EMR - PAYMENTS & ELECTRONIC MONEY
UK & EU PSR/EMR - PAYMENTS & ELECTRONIC MONEY
Coburn has extensive experience of UK & EU EMR/PSR applications, regulatory rules mapping and regulatory intervention. Please enquire for more details.
EU MiCA Applications
UK & EU PSR/EMR - PAYMENTS & ELECTRONIC MONEY
Governance and UK SMCR / IRISH SEAR
The Coburn team has supported multiple MiCA applications across the EU including in Ireland, Norway, Sweden, France and Malta. Please enquire for more details.
Governance and UK SMCR / IRISH SEAR
UK & EU PSR/EMR - PAYMENTS & ELECTRONIC MONEY
Governance and UK SMCR / IRISH SEAR
Since the regimes' inception Coburn has conducted a large number of SMCR / SEAR programmes and was involved in a pre-regime pilot with a customer and the FCA. We partner with PeopleClear SMCR top broaden our SMCR capability and benefit from their tooling.
CASS - Client Assets & Safeguarding
CASS - Client Assets & Safeguarding
CASS - Client Assets & Safeguarding
Coburn has solid experience of CASS and Safeguarding programmes.
Operational Resilience & DORA
CASS - Client Assets & Safeguarding
CASS - Client Assets & Safeguarding
Coburn has conducted a number of operational resilience and DORA programmes.
PRIN, COND, SYSC
CASS - Client Assets & Safeguarding
PRIN, COND, SYSC
Coburn has been working with the PRIN. COND and SYSC regimes for many years and is well versed in the requirements and practical application of these regimes.
Case Studies - Non-Crypto / NON-UK
UK FSMA - Asset Manager
UK FSMA - Guarantor Loans Provider
UK FSMA - Guarantor Loans Provider
Coburn supported a UK asset manager in delivering a comprehensive FSMA regulatory rules mapping, aligning business processes to FCA Handbook obligations. Leveraging deep compliance expertise, Lysis structured requirements across the regulatory perimeter, improving traceability, governance, and audit readiness in line with evolving UK regulatory expectations.
UK FSMA - Guarantor Loans Provider
UK FSMA - Guarantor Loans Provider
UK FSMA - Guarantor Loans Provider
Coburn and our partners Lysis Group supported a sub-prime lender to regain its regulatory authorisations. Our contribution was to work with the firm's Executives to design and implement a new Financial Crime Framework and advise on the Governance Framework.
EU MiCA - Crypto Exchange
UK FSMA - Guarantor Loans Provider
UK EMRs/PSRs - Payments Provider
Coburn, supported by Lysis Advisory, delivered a MiCA application for a Norwegian crypto trader. Leveraging a structured permissions approach, the team designed governance, risk and control frameworks, aligning with EU MiCA authorisation requirements to ensure transparency, compliance, and readiness for cross-border operations under a single harmonised regulatory regime. Detail
UK EMRs/PSRs - Payments Provider
UK FSMA & SMCR - Inter-Dealer Broker
UK EMRs/PSRs - Payments Provider
Coburn, supported by Lysis Advisory, delivered a successful EMR/PSR application for a UK payments provider. Aligning with FCA authorisation requirements, including Payment Services Regulations and Electronic Money Regulations, the team developed governance, risk and compliance frameworks, ensuring a robust, regulator-ready submission and efficient approval process.
EU EMRs/PSRs - Payments Provider
UK FSMA & SMCR - Inter-Dealer Broker
UK FSMA & SMCR - Inter-Dealer Broker
Coburn delivered a Central Bank of Ireland EMR/PSR application for an Irish payments provider. Leveraging a structured permissions approach, the team designed governance and compliance frameworks, drafted EWRA, risk models and policies, and implemented a robust control environment, ensuring a regulator-ready submission and successful authorisation outcome.
UK FSMA & SMCR - Inter-Dealer Broker
UK FSMA & SMCR - Inter-Dealer Broker
UK FSMA & SMCR - Inter-Dealer Broker
Coburn implemented SMCR and FSMA-aligned governance and reporting for a UK inter-dealer broker. Leveraging FCA frameworks, the team embedded accountability, strengthened controls, and enhanced regulatory reporting, delivering a scalable, compliant operating model aligned to evolving FCA expectations and best practice governance standards.
UK CASS - EMI
UK Operational Resilience - Bank
UK Operational Resilience - Bank
Coburn, supported by Lysis Advisory, delivered a UK CASS remediation for an EMI, strengthening client money safeguarding controls. Aligning with regulatory expectations, the team conducted a detailed review, remediated gaps, and implemented a robust control framework, enhancing governance, audit readiness, and ongoing compliance with CASS requirements.
UK Operational Resilience - Bank
UK Operational Resilience - Bank
UK Operational Resilience - Bank
Coburn delivered an operational resilience programme for a UK/EU bank, aligning with DORA and FCA rulebook requirements. The team enhanced governance, mapped critical services and embedded robust testing and reporting frameworks, strengthening resilience, regulatory compliance and oversight across key business operations and third-party dependencies.
see Lysis Group case studies
UK Operational Resilience - Bank
see Lysis Group case studies
Case Studies from our partners @ Lysis Group can be viewed here