New UK cryptoasset regime: FCA reaches the end of the roadmap

The policy statements: who should read what?

The summary table below indicates in broad terms the relevant policy statements and related materials for each type of crytoasset firm. 

The policy statements: content overview

The FCA’s five policy statements contain the final rules and guidance for firms that will need to be authorised with permission to carry on cryptoasset regulated activities under the new regulatory regime. 

While the FCA’s final rules and guidance are broadly as consulted on, it has made targeted changes, taking into account feedback from the consultation process, to simplify some of the key parts of the regime and better tailor the policy to reflect crypto market operation.

What follows is a brief summary of the contents of each policy statement, highlighting some key changes from the consultation proposals, and referring to any related publications. We also look ahead to ongoing and future FCA initiatives in the relevant topic areas.

A&D and MARC

PS26/9

This policy statement sets out the FCA's final regimes for A&D and MARC. 

The A&D regime will operate as a gateway for admissions to trading of qualifying cryptoassets on UK qualifying cryptoasset trading platforms (UK QCATPs). The FCA's rules are designed to improve the quality and accessibility of information for investors, strengthen UK QCATPs' admission arrangements, and support fair and orderly markets. The A&D regime (except for the relevant record-keeping requirements for a UK QCATP) does not apply to public offers of UK-issued qualifying stablecoins or to the admission to trading of UK-issued qualifying stablecoins on a UK QCATP. The disclosure framework for UK issued qualifying stablecoins is set out in the final rules contained in PS26/10 (see below).

MARC will prohibit insider dealing, unlawful disclosure of inside information and market manipulation in cryptoasset markets. There will be proportionate systems and controls requirements for UK QCATPs and intermediaries, with additional obligations for large UK QCATPs, reflecting the role of firms in preventing, detecting and disrupting market abuse in cryptoasset markets.

The FCA has largely maintained its proposed framework in its consultation (CP25/41) , with targeted changes, including:

• A&D:
  • clarification of requirements relating to due diligence, admission criteria and the trigger for supplementary disclosure documents; 
  • specification of a digital token identifier standard, strengthening withdrawal rights notifications;
  • increase in withdrawal rights notification; and
  • removal of an exception that allowed qualifying cryptoassets to be admitted to trading without a qualifying cryptoasset disclosure document if they were fungible with those already admitted to trading on the same platform.
• MARC:
  • limiting the requirement for on-chain monitoring for large UK QCATPs, but retaining the industry-led framework and the threshold for large UK QCATP obligations; 
  • clarification of key requirements relating to inside information disclosure and intermediary notifications to UK QCATPs; and
  • refining “legitimate market practices” and adding inside information examples.

Looking ahead

In September 2026, the FCA will consult on proposed deferral arrangements under the A&D regime for cryptoassets already in circulation at the point the wider cryptoaset regime comes into force. Work is still ongoing and therefore subject to change, but the FCA indicates the arrangements are likely to include a six-month deferral period for these cryptoassets, under which relevant A&D requirements would be deferred to help reduce cliff-edge effects and mitigate potential operational and market disruption.

Stablecoin issuance

PS26/10

This policy statement sets out final rules for non-systemic UK-issued qualifying stablecoins. The rules cover issuance, backing assets, redemption, safeguarding and disclosures. They are intended to establish an appropriate baseline for stablecoin issuance and to support stability, consumer confidence and market integrity. 

In the light of feedback to its consultations (CP25/14 and CP25/41), the FCA has largely maintained the proposed framework, while making targeted refinements to improve clarity, operability and proportionality in the following areas:

• simplification of the backing asset composition ratio calculation;
• requirement for the backing asset pool to be in the denominated currency and to be held on statutory trust for the benefit of tokenholders;
• requirement that stablecoins must be fully backed from the point at which they are minted;
• amendment to allow the use of intragroup custodians;
• requirement for issuers to obtain an acknowledgment letter from each custodian before holding backing assets with them;
• requirement for daily reconciliations and resolution of shortfalls by the end of the business day on which they are identified;
• amendment for the T+1 redemption timeline to commence when the issuer receives the stablecoin being redeemed in their wallet, rather than a full redemption request;
• requirement for contracts with anyone to whom the issuer issues stablecoins, which must incorporate the conditions of redemption and must pass the issuer’s obligations to redeem from one holder to the next; and
• clarifications surrounding disclosures, taking into account the need for proportionality and flexibility.

Approach Document: Joint systemic stablecoin regulation

Alongside PS26/10, the FCA and the Bank are consulting on the Approach Document. This sets out how they will apply the UK’s stablecoin regime jointly to systemic stablecoin issuers. The FCA’s rules are in PS26/10 and the Bank’s rules will be in its Code of Practice for systemic stablecoin issuers (Code). The Bank is currently consulting on a draft version of the Code - see our recent blog post for an overview of the Bank’s policy statement on sterling-denominated systemic stablecoins and the draft Code.

Where stablecoins are recognised as “systemic” by HM Treasury (HMT) under the Banking Act 2009, their issuance will be subject to joint regulation by the Bank and the FCA. The Approach Document contains further details on how and when issuers are recognised as systemic (this is also covered in PS26/10) and an overview table of the proposed split of supervisory responsibility per policy area for jointly regulated systemic stablecoin issuers. Through the consultation, the Bank is seeking feedback on its proposed application of rules for systemic stablecoin issuers during transition when recognised as systemic by HMT (the specific consultation questions are included in section 4 of the Approach Document). 

Looking ahead

Further revisions to the cryptoasset regime are to be expected, particularly regarding the proposed carve-outs for stablecoin payments (as summarised in our blog post on HMT’s proposed amendments to the Cryptoasset Regulations).

The consultation on the Approach Document closes on 30 September 2026. The Bank will then publish a summary of responses and consider whether updates are required to existing materials. The regulators may follow up with a final joint publication including further detail on how the Code and the FCA rules will apply in areas of overlap. Once the Code is finalised, the FCA will consult on which rules it will disapply when a firm is recognised as a systemic stablecoin issuer.

Firms should also be aware that the FCA and the Bank have updated section 4 of their joint guidance on the operation of the Digital Securities Sandbox (DSS), to permit certain stablecoins to be used as a settlement asset in the DSS provided they meet the minimum criteria set out in the guidance. As explained on the Bank's DSS Dashboard, permitting and observing this use case will help inform how to facilitate the use of stablecoins in wholesale settlement over the longer-term, once the DSS has closed, including any amendments to regulation that may be required.

Regulated cryptoasset activities

PS26/11

This policy statement sets out the final rules and guidance for the regulated cryptoasset activities set out in the RAO, including operating a QCATP, dealing, arranging, lending and borrowing, staking, safeguarding and the FCA's current approach to decentralised finance (DeFi).

The proposed framework in the FCA's consultations (CP25/14, CP25/40 and CP26/4) has largely been maintained, with targeted amendments and the addition of further guidance. Notably: 

• principal dealers have been removed from pre-trade transparency requirements; and
• best execution expectations are that firms should check prices from at least three reliable UK authorised execution venues, but  are not required to execute on those venues or undertake mechanical transaction-by-transaction checks so long as overall arrangements are effective and are supported by periodic post-trade analysis.

PS26/11 also confirms retail protections for cryptoasset lending, borrowing and staking, targeted refinements to collateral and auto-staking rules and the application of safeguarding requirements under CASS 17, with adjustments to reflect cryptoasset custody. 

In respect of DeFi, the FCA states that it intends to proceed on the basis that rules apply where there is an identifiable controlling entity. 

Looking ahead

The FCA indicates that separate DeFi guidance will follow, covering how decentralisation will be assessed in practice, and how the proposed requirements and guidance for regulated cryptoasset activities would interact with firms engaging in DeFi. The guidance will also cover operational resilience and financial crime risk mitigation when integrating or interacting with DeFi. The FCA intends to consult on this guidance later in 2026.

Prudential regime

PS26/12

This policy statement sets out the FCA’s final prudential framework for regulated cryptoasset firms, covering capital (‘own funds’), liquidity, risk management and public disclosure requirements. The FCA’s new Core Prudential sourcebook (COREPRU) initially applies only to firms carrying on regulated cryptoasset activities and is supplemented, where necessary, with sector-specific sourcebooks, including the new Prudential sourcebook for CRYPTOPRU firms (CRYPTOPRU).

The proposed framework in the FCA's consultation papers (CP25/15 and CP25/42) has largely been maintained, with some targeted changes, including in relation to:

• reduction of the operational risk K-factor capital requirement for stablecoin issuance from 2% to 1%;
• simplification of the market risk framework; and
• introduction of greater proportionality in the public disclosure regime.

Related consultations on proposed non-Handbook guidance

The FCA is consulting on proposed non-Handbook guidance to support firms by setting out its expectations around the purpose and scope of the overall risk assessment in the new Prudential sourcebooks (COREPRU and CRYPTOPRU):

• GC26/4: Non-Handbook Guidance on COREPRU 7: Overall risk assessment.
• GC26/5: Non-Handbook Guidance on CRYPTOPRU 7: Overall risk assessment for CRYPTOPRU firms.

By distinguishing supporting material from core Handbook content - in line with its wider rule accessibility strategy - the FCA intends to make it easier for firms to navigate requirements, and to build more consistent adoption of prudential standards.

Looking ahead

The non-Handbook guidance consultations close to responses on 30 July 2026. 

Application of the FCA Handbook for regulated cryptoasset activities

PS26/13

This policy statement sets out final rules and guidance on how key cross-cutting FCA Handbook obligations will apply to regulated cryptoasset activities. Most firms carrying on regulated cryptoasset activities will be subject to requirements including the Consumer Duty, COBS, DISP and access to the Financial Ombudsman Service (FOS), SYSC, the SMCR, ESG, CASS and regulatory reporting.

The proposed framework in the FCA’s consultations (CP25/25 and CP26/4) has largely been maintained, with targeted refinements to improve clarity and proportionality, including:

• exclusion of UK-issued qualifying stablecoins from the definition of restricted mass market investments;
• focused amendments to SYSC, COBS, DISP, CASS and reporting requirements;
• adjustment of the enhanced threshold in relation to SMCR qualifying UK stablecoin issuers in the light of the Bank’s proposals;
• clarifications to the new non-Handbook guidance on the Consumer Duty (FG26/5), including in respect of territorial scope, fair value, consumer support, consumer understanding, and the roles of distributors and manufacturers in the supply chain (note that the FCA will apply the Consumer Duty to cryptoasset firms in full, subject to limited exemptions in the case of A&D activities and trading on a UK QCATP);
• further clarity on operational resilience expectations under SYSC 15A, including a new example for firms arranging deals in qualifying cryptoassets; and
• clarification of the FCA’s AICF, to enable dual-regulated international cryptoasset firms to operate in the UK through a branch, where the PRA is satisfied that its threshold conditions and ongoing requirements are met.

The FCA confirms that, as proposed, it does not intend to extend Financial Services Compensation Scheme (FSCS) protection to regulated cryptoasset activities.

Related finalised non-Handbook guidance

The FCA has published the following finalised non-Handbook guidance alongside PS26/13:

• Consumer Duty (FG26/5): this guidance explains how firms involved in cryptoasset activities should apply the Consumer Duty and understand the FCA’s expectations in this area. It includes illustrative examples of good and poor practice.
• Operational resilience (FG26/6): under the new cryptoasset regime, the FCA is applying its existing operational resilience framework to cryptoasset firms. This guidance is designed to help firms implement the FCA's operational resilience requirements (SYSC 15A), with reference to the outsourcing provisions under SYSC 8, under the new cryptoasset regime. 
• AICF (FG26/7): this guidance sets out the FCA’s general approach to cryptoasset international firms providing, or seeking to provide, cryptoasset services that require authorisation in the UK. It aims to provide clarity on how the FCA will assess international cryptoasset firms against minimum standards, both on application for authorisation and on an ongoing basis. In brief, the FCA’s baseline expectation is for firms requiring FCA authorisation to carry out their regulated cryptoasset activities from a UK legal entity. This is subject to some specific exceptions where the FCA sees a case for overseas cryptoasset firms serving UK customers through a UK branch to be authorised as a QCATP operator. It would expect, in such cases, the home regulator to have in place comparable levels of regulatory protection and regulatory requirements.

Looking ahead

In FG26/6, the FCA encourages firms to consider “separate forthcoming non-Handbook guidance on operational resilience for distributed ledger technology (DLT) use.” It intends to consult on this guidance later in 2026.

Next steps

For the FCA: future publications and further policy work

The FCA’s next steps include a number of future publications, several of which are due to be published later the year. These include:

• Regulatory perimeter: a policy statement in September 2026, setting out how the regulatory perimeter applies to cryptoasset activities. In a previous blog post, we considered the FCA’s proposed perimeter guidance (including in a new chapter 19 of the Perimeter Guidance Manual (PERG)) on which it recently consulted (CP26/13).
• Resolution: a consultation paper later in 2026 on the FCA’s proposed approach to managing cryptoasset firm failure. This will include distribution rules that would apply where a stablecoin issuer or a cryptoasset custodian has failed, and it may include consideration of the rules on suspension of redemption of stablecoins to ensure they achieve their aims, both in firm failure and the run-up to it, which may result in some changes.  
• Additional components of the cryptoasset regime not addressed through the policy statements: these include DeFi, DLT, cryptoasset derivatives, stablecoin-related policy development, audit requirements and saving and transitional provisions. The FCA will progress these topics through policy development and further consultation. Specifically, and as noted above, later in 2026 the FCA will consult on (i) DeFi guidance; and (ii) operational resilience guidance for firms using DLT.
• Financial crime: the FCA plans to provide further clarity on financial crime requirements, including the application of AML and KYC obligations, through updates to the Financial Crime Guide (FCG). These updates will aim to ensure a consistent and comprehensive framework, including clear guidance and practical examples of good and poor practice. The FCA will publish a consultation paper on these changes later in 2026.

For firms: planning and preparation

The FCA’s authorisation gateway opens on 30 September 2026 and runs until 28 February 2027. The FCA is encouraging firms to apply as soon as possible, and firms can request pre-application meetings with the FCA’s Pre-Application Support Service (PASS), as part of their preparations. However, the FCA has made clear that any requests that are not accompanied by “meaningful supporting information” will be rejected, so firms must have carried out sufficient detailed analysis before requesting a PASS meeting. 

Taking this into account, most immediately:

• The focus for firms that are currently registered under the MLRs 2017 is to assess the steps they need to take, and what will need to change, to meet the FCA’s expectations and become authorised under FSMA.
• The focus for existing authorised firms is to consider how they need to adapt their business model, governance and systems and controls, and vary their current permissions, to carry on the new cryptoasset regulated activities and comply with the requirements of the regime.

As always, please contact our team if you would like to discuss these or any other UK cryptoasset policy developments.