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CRYPTOPRU permanent minimum requirement

Five amounts from £75,000 to £750,000, and one rule that catches people: where a firm is authorised for several activities the PMR is the highest applicable, not the sum. Tick the permissions and see the figure, and whether your fixed overheads requirement already exceeds it.

PS26/12 final rules · PMR by activity · highest applicable · FOR comparison · nothing stored

Work out the PMR

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Select every regulated cryptoasset activity the entity is authorised for. The PMR is a baseline and is deliberately not risk-sensitive — risk sensitivity comes through the K-factors and the overall risk assessment.

Step 1 — Authorised activities

PS26/12 §3.3–3.4
ActivitiesEach carries its own PMR. Only the highest one applies to the firm.

Optional — compare against the FOR

Own funds are the higher of PMR, FOR and K-factors
Fixed overheads requirement PS26/12 §3.5 · based on the previous year’s audited expenditure Leave blank if you have not calculated it. Newer firms may use unaudited figures where necessary.
What this means: an indicative PMR and a two-way comparison against a FOR you supply. It is not your own funds requirement, which is the higher of the PMR, the FOR and the K-factor requirement — and this tool does not calculate K-factors. The PMR exemption and the treatment of groups are not modelled. These are final rules published on 30 June 2026 that apply to firms authorised on or after 25 October 2027. This is not advice.

The binding measure changes as the firm grows. The capital module keeps the PMR, FOR and K-factor requirement current together and shows which one binds — with free monitoring to start.

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The amounts

Proportionality by activity, not by size

The FCA built proportionality into the PMR by varying the level by activity, from £75,000 to £750,000. The final rules set the PMR as consulted on.

£75,000

Agency and arranging

Dealing as agent and arranging deals in qualifying cryptoassets. The firm handles client orders without taking principal risk, so the baseline sits at the lowest level in the regime.

£150,000

Custody, platforms, staking

Safeguarding qualifying cryptoassets, operating a cryptoasset trading platform, and qualifying cryptoasset staking. Client assets or client orders are held or matched, without principal exposure.

£350,000

Stablecoin issuance

Issuing qualifying stablecoins. Money-like liabilities and a backing pool, which is also why the operational risk K-factor K-SII applies on top — reduced from 2% to 1% in the final rules.

£750,000

Dealing as principal

Deliberately aligned with the initial capital requirement for investment firms dealing on own account under MIFIDPRU. The FCA’s reasoning: the infrastructure required does not become less demanding because the instrument is a cryptoasset.

Rules reviewed 21 August 2026 · PS26/12 §3.3, §3.4 and the response at §3.9 · published 30 June 2026

Scope

What this calculator does

It doesApply the amounts and the rule

  • Takes the highest applicable PMR across the selected activities rather than adding them together.
  • Shows every activity you selected and the PMR each would carry alone, so the binding one is visible.
  • Compares the PMR against a FOR you supply and names which of the two is higher.
  • Flags that lending and borrowing carries no PMR of its own.
  • States the FOR deduction treatment confirmed in the final rules, including gas fees.

It does notGive you an own funds requirement

  • Calculate K-factors, which can exceed both the PMR and the FOR.
  • Calculate the FOR. You supply it.
  • Model the PMR exemption, or the treatment of groups of cryptoasset firms.
  • Determine whether the entity qualifies for the permissions you selected.
  • Cover the overall risk assessment under Chapter 7, where non-Handbook guidance was still in consultation.

The PMR is a floor, and often not the binding one

The FCA is explicit that the PMR is a baseline representing the minimum each firm should hold, and is not designed to be risk-sensitive. Risk sensitivity is delivered through the K-factor framework, which scales with activity volume, and through the overall risk assessment. A firm of any real size will usually find the FOR or its K-factors binding instead.

Scope the rulebooks first

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Every figure is evaluated on your own machine. Nothing is sent to REGREP, written to a log, saved to a database, or passed to any analytics tool.

That is deliberate. Your intended permissions and your cost base are not something we want to hold.

Questions

About the PMR

If we hold several permissions, do the PMRs add up?

No. The permanent minimum requirement is the highest applicable across the activities the firm is authorised to do. A firm safeguarding cryptoassets, arranging deals and dealing as principal has a PMR of £750,000 — not the £975,000 you would get by adding the three together. Summing is the most common way to get this wrong.

Why is dealing as principal ten times the agency figure?

Because it aligns with the initial capital requirement for investment firms dealing on own account under MIFIDPRU. The FCA's stated reasoning is that the operational and risk management infrastructure required to deal as principal does not become less demanding because the underlying instrument is a cryptoasset, and that aligning with the analogous MIFIDPRU activity supports a level playing field across regimes.

Is the PMR our own funds requirement?

Only if it is the highest of the three measures. Own funds are the higher of the permanent minimum requirement, the fixed overheads requirement and the K-factor requirement. The PMR is a baseline and is not risk-sensitive by design, so for most firms with real volume something else binds.

What can we deduct when calculating the FOR?

The final rules confirmed several points. Gas fees are treated like brokerage fees: 100% deductible where passed on to customers, 80% otherwise. Research and development write-offs, smart contract audit costs and protocol development costs are deductible if non-recurring and incurred through non-ordinary activities. Global shared services, intercompany and compliance technology, amortisation, depreciation and cybersecurity costs are not deductible, as they form a core part of the firm's operations.

Does lending and borrowing have a PMR?

Not one of its own. It is a business model rather than a standalone firm category, and the FCA assumes firms conducting it are authorised as a trading platform or an intermediary. The PMR follows from those permissions instead, so select whichever the entity actually holds.

When does this bite?

The rules were published on 30 June 2026 and apply to firms authorised under FSMA on or after 25 October 2027. The gateway for permission applications opens in September 2026, so a firm applying now is modelling capital against a requirement that commences later.

A floor is not a capital plan.

Create a free account and model the PMR, the FOR and the K-factor requirement together, so you know which one binds before the application does.

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