Most first-wave applications will be rejected on regulatory business plan quality alone. This piece sets out what we are seeing in the preparation stage, and what will cost firms their application.
CASP authorisation timelines vary between 6 and 18 months depending on NCA. The jurisdiction decision is now as commercially important as the quality of the application.
What a compliant AML/KYC programme looks like for a digital asset business in 2026, the BWRA, CDD standards, on-chain analytics, Travel Rule compliance, and the MLRo function the FCA actually expects.
The regulatory position on DeFi is more settled than the evolving framing suggests. Where the FCA and MiCA perimeters sit, what triggers regulatory exposure for protocol teams, and what compliance is now considered baseline.
Six months into MiCA enforcement, the gap between what the Regulation says and how NCAs are applying it is wider than anticipated, and consistently wide in the same places.
RWA tokenisation has moved from concept to live market. Token classification across jurisdictions, AML obligations specific to tokenised assets, custody compliance, and cross-border distribution.
MiCA Title VI introduced a market abuse framework for crypto markets in force since December 2024. First enforcement actions expected H2 2026. Prohibited behaviours, surveillance obligations, and suspicious transaction reporting.
Two years after implementation, the FCA has begun active Travel Rule compliance review. The gaps across supervised firms are consistent, and almost entirely avoidable.
Consumer Duty is one of the most misunderstood requirements in the FCA authorisation process for cryptoasset firms. Most applicants treat it as a policy exercise. The FCA treats it as an outcomes question.
DORA has been in force since January 2025 and enforcement has begun. Digital asset firms regulated under MiCA are within scope. The mandatory incident reporting, TLPT, and third-party requirements are more operationally demanding than most compliance teams have modelled.
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