The UK is building one of the world's most comprehensive cryptoasset regimes. With the application gateway opening in September 2026 and full regulation taking effect on 25 October 2027, crypto firms face a narrowing window to get their compliance house in order.
But there's an earlier deadline that many overlook: financial promotions of qualifying cryptoassets to UK consumers already require approval by an FCA-authorised Section 21 approver. And the FCA is watching closely.
At rebuildingsociety.com, we learned this lesson the hard way – then built the frameworks to help others succeed.
The S21 Gateway: More Than Just Copy Approval
The Section 21 gateway requires that any financial promotion of a qualifying cryptoasset to UK retail consumers be approved by an FCA-authorised person. That sounds simple. But as Dan Rajkumar, CEO of rebuildingsociety.com, explained in a recent Fintech North webinar:
"The FCA expected us to undertake comprehensive due diligence on each crypto asset – even for approving a promotion. They wanted to know that we understood the risk, not just the wording."
That meant developing a proprietary nine-vector risk analysis model, a Crypto Competency Framework of 80 distinct competencies, and robust governance structures – all reviewed and deemed suitable for authorisation by the FCA.
Our Journey: From Suspension to Authorisation
rebuildingsociety.com didn't take an easy path. Shortly after starting to approve promotions for firms including Binance, the FCA suspended us. We appealed to the Upper Tribunal and agreed to apply directly for authorisation – becoming one of the first firms to go through the process.
"The authorisations team were themselves learning how to understand a firm's approach to managing crypto risks," Dan noted. "The frameworks we built helped inform the FCA's expectations."
After developing comprehensive policies, competency training, and risk models, our permissions were granted. That hard-won experience – including knowing when and how to push back diplomatically on regulatory interpretations – is now available to your firm.
What We Offer: Support Built on Battle-Tested Frameworks
We don't just check your copy for "clear, fair, and not misleading". We provide a complete approval service that gives you and the FCA confidence.
1. Pre-screening & Due Diligence
We run 13 screening checks – including risk appetite, capitalisation, and fitness & propriety – before any promotion is approved.
2. Risk-Based Assessment
Our Crypto Risk Analysis Model evaluates assets across nine vectors: issuer & team, technology, market liquidity, cybersecurity, legal/regulatory, financial crime, operational risks, code defects, and network concentration.
3. Competent People
Our staff are trained under an 80-competency framework that the FCA has already reviewed and found suitable. You're not getting generic compliance – you're getting deep crypto and regulatory expertise.
4. QCAC Governance
Every approval goes through our Qualifying Cryptoassets Committee (QCAC) – not just a single compliance officer – ensuring robust challenge and oversight.
5. Auditable Trail
Every decision is documented. If the FCA asks why a promotion was approved, you have a clear, defensible answer.
Why the FCA Cares – And Why You Should Too
The FCA's Threshold Conditions require firms to have competent people, effective supervision, and strong risk management. For financial promotions, that means:
- Viable business model – not just hype.
- Effective supervision – documented committee oversight.
- Competent people – verifiable training and assessments.
- Risk management – consistent, objective due diligence on each asset.
- Consumer protection – vulnerable customers shielded from inappropriate promotions.
As Sam Robinson, regulatory lawyer at CMS, noted in the same webinar:
*"The new regime changes territorial scope – even non-UK firms dealing with UK consumers will need a licence. The window for applications opens September 2026. There's not much time."*
Beyond Approval: Preparing for Full Authorisation
Many of the firms using our S21 approval service are also preparing for full FCA authorisation under the new regime. Because we've already built the competency frameworks, risk models, and governance structures the FCA expects, we can help you:
- De-risk your application – replace ad-hoc processes with proven, regulator-reviewed frameworks.
- Accelerate readiness – fast-track internal training and policy development.
- Navigate the journey – including knowing when and how to push back on regulator interpretations that go beyond current policy.
"Having an agreed stakeholder approach to handling contentious matters is important," Dan explained. "There is a way to push back diplomatically when you feel there's an over-interpretation."
Who This Service Is For
We work with:
- Cryptoasset trading platforms needing promotion approval for listed assets.
- Overseas firms marketing qualifying cryptoassets to UK consumers.
- Firms in the RMMI regime seeking robust S21 support.
- Any crypto business preparing for full FCA authorisation.
Next Steps
The September 2026 gateway is closer than it seems. Don't leave your financial promotions – or your authorisation prospects – to chance.
Contact rebuildingsociety.com today:
Telephone: 0113 511 4644
Email: partners@rebuildingsociety.com
Registered Office: 10-12 East Parade, Leeds, LS1 2BH
Authorised and regulated by the FCA | FRN 656344
Registered in England & Wales No. 07885342
