What Is PASS and who should use it?
The Financial Conduct Authority’s (FCA) Pre-Application Support Service, or PASS, is a free, pre-application meeting service where firms can discuss their plans and intentions with the FCA’s authorisations team ahead of submitting a formal application. While the service has existed for some years, the FCA has placed renewed emphasis on PASS when there is regulatory change and as part of the transition to the new cryptoasset authorisation regime.
PASS is available to unauthorised firms and authorised firms needing a variation of permission. The FCA has strongly encouraged uptake among prospective cryptoasset applicants, viewing the service as a tool for proactive engagement with the industry and as a means of gauging the volume of expected applications whilst the gateway is open. Firms that are already authorised and familiar with the regulatory framework, or that have a named supervisor, may find PASS less relevant.
Preparing for a PASS meeting
The FCA expects firms to approach PASS with a clear business plan and a well-articulated understanding of the proposed business model. Firms should be prepared to discuss a range of topics including their regulatory compliance approach to the new cryptoasset regime, staffing arrangements (including board composition and key senior managers), the target customer base, and the risk profile of their proposed products and services. Where relevant, firms should also be ready to address how they are implementing operational elements to comply with regulatory requirements which will be new for cryptoasset firms such as safeguarding arrangements, outsourcing, and Consumer Duty requirements.
We would recommend that firms prepare for PASS meetings by presenting a business plan supported, where appropriate, by an overview slide deck. Whilst firms may have different approaches to who might attend the meeting, we would expect individuals such as the UK-based board members, the Money Laundering Reporting Officer or the Compliance Officer to attend.
What to expect from the process
PASS meetings will be conducted by members of the FCA’s payments and digital assets authorisations team who are familiar with the cryptoasset sector. Meetings may be virtual rather than in person, and firms should be prepared for the possibility that sessions will be recorded. Importantly, PASS does not need to be considered as a one off meeting; the FCA envisages a series of conversations where appropriate. However, the FCA will not draft business plans or complete application forms on a firm’s behalf.
PASS sits outside the FCA’s formal authorisation process. No formal consequences flow from the meeting itself, and firms must still submit a separate authorisation application. That said, there is a practical benefit, the FCA will endeavour to appoint the same case officer as the point of contact on each application. Conversely, if a PASS meeting reveals material issues and no remedial steps are taken, the FCA is likely to look unfavourably on the application.
Timing
PASS meetings for cryptoasset firms are scheduled to begin in July, with a request link having gone live on 11 May 2026.