On 15 April 2026, the Financial Conduct Authority (FCA) published a consultation paper and accompanying press release setting out proposed perimeter guidance for the new cryptoasset regulatory regime. The proposals take the form of a new chapter in the FCA’s Perimeter Guidance manual (PERG), structured as a series of questions and answers.
Scope of the Consultation
The consultation sets out proposed guidance on the interpretation of the following regulated cryptoasset activities:
- Issuing qualifying stablecoins in the UK: The proposed guidance addresses when the issuance of a qualifying stablecoin is regarded as carried on in the UK and what it means to issue for these purposes.
- Safeguarding qualifying cryptoassets: The guidance covers safeguarding, and arranging the safeguarding of, qualifying cryptoassets and relevant specified investment cryptoassets, with particular attention to the concepts of ownership and control.
- Operating a qualifying cryptoasset trading platform (QCATP): The proposed guidance sets out examples of different operator types and models, operating from different locations, and addresses when authorisation is required. The permissions that may be required vary depending on the activities carried out and may include a permission to operate a UK QCATP, a safeguarding cryptoasset permission or a dealing in qualifying cryptoassets as principal permission.
- Intermediary activities: The guidance addresses dealing in qualifying cryptoassets as principal, dealing as agent and arranging deals in qualifying cryptoassets, including the differing exclusions that may apply. The consultation also sets out proposed guidance on arranging qualifying cryptoasset staking.
Cryptoasset Lending and Borrowing
The consultation also addresses cryptoasset lending and borrowing. Whilst this is not a standalone regulated activity, the FCA takes the position that such activity will generally engage the dealing and/or arranging perimeter where it involves buying, selling or subscribing for qualifying cryptoassets. The safeguarding activity may also be engaged in such circumstances.
A central objective of the consultation is to clarify the scope of the new regulated cryptoasset activities and the circumstances in which permission is required. The FCA has included a decision tree in Annex 2 of the proposed PERG chapter to assist firms in navigating the perimeter. The key questions are:
- Is the person carrying on a regulated activity?
- Is the activity carried on in the UK?
- Is the activity carried on by way of business?
- Does an exclusion apply?
- Does an exemption apply?
Next Steps
The consultation is open for responses until 3 June 2026. The FCA intends to publish final rules by way of policy statements in the summer, with final perimeter guidance to follow in September 2026.
Firms should review the proposed PERG guidance against their current and intended activities to assess whether authorisation or additional permissions may be required.
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