Describe the actual service and location
FCA guidance requires registration before starting in-scope cryptoasset services carried on by way of business in the UK. It treats the activity and whether business is carried on in the UK as separate questions. Describe the people, premises, agents and service functions rather than assuming incorporation alone resolves the analysis.
Prepare a workflow showing exchange, custody, payment and token-issuance functions where relevant. Identify the customer and asset flows for each. A business already authorised for another service may still need the cryptoasset registration analysis. Keep a permissions matrix so an existing status does not quietly become an assumption about a new activity.
Create a separate marketing workstream
UK cryptoasset financial promotions have their own legal routes and can affect overseas firms. Record who drafts, approves and distributes each invitation to invest. Include social media, affiliate pages and onboarding screens in the inventory. The route used for a promotion should be documented before publication, not inferred from a supplier’s assurance.
Build responsibilities around customer checks, complaints, custody access, technology resilience and incident handling. These are operating design questions for the project file. Confirm which obligations and application materials apply to the particular business; a generic compliance policy purchased for another model is unlikely to describe the controls your service actually uses.
Plan the transition with dated evidence
The FCA’s current registration page states that the new cryptoasset regime starts on 25 October 2027. Keep that future transition distinct from the requirements applying to a launch today. Record the date of the guidance consulted and build a review point into the plan rather than presenting future authorisation as already granted.
Before accepting customer funds, obtain advice on the launch conditions and unresolved permissions. Maintain a decision log with activity, source, owner and next action. Reopen it when introducing a new token function, jurisdiction or custody arrangement, because the operational change may alter the regulatory analysis even if the company name stays the same.
Sources & scope
Official sources support the jurisdiction context. The working checklists are CryptoGov’s editorial preparation suggestions, not an exhaustive application or filing requirement. Confirm the rules and your circumstances before acting.