On 21 October 2026 the FCA published two consultations that will shape how decentralised finance is treated under the UK cryptoasset regime. Both close on 18 November 2026.
CP26/36: Cryptoasset Perimeter Guidance
CP26/36 sets out draft amendments to the FCA's cryptoasset perimeter guidance in PERG 18. It reflects the Cryptoassets Amendment Regulations, which the Government laid the day before the FCA published its final perimeter guidance in PS26/18.
The amending regulations introduce new exclusions from some regulated cryptoasset activities. CP26/36 explains how the FCA reads them, covering:
- temporary settlement arrangements;
- temporary UK qualifying stablecoin holding arrangements for payment transactions, and arrangements involving backing assets held for a UK qualifying stablecoin;
- proprietary trading where a person is not providing a service to another person, or acts as a market maker on a qualifying cryptoasset trading platform; and
- technical services that merely allow access to services provided by a third person or to a decentralised protocol.
The FCA is also proposing new guidance on how decentralisation affects perimeter analysis. Its starting point is that the perimeter is technology neutral: the same statutory tests apply however decentralised a business model is.
One practical point stands out. The FCA has said it will exercise some forbearance for firms whose applications were affected by uncertainty over the technical services provider exclusion, provided they submit an otherwise complete application within the current application period, which closes on 28 February 2027.
GC26/7: Decentralised Finance Guidance
GC26/7 sets out draft non-Handbook guidance for FCA-authorised firms providing financial services using DeFi. It explains how the FCA expects firms to apply its rules on operational resilience (SYSC 15A) and financial crime (SYSC 6), and the Money Laundering Regulations, when they use or interact with DeFi. It includes case studies and worked examples, from staking through decentralised protocols to non-custodial wallets.
The FCA states that GC26/7 should be read alongside CP26/36 and PS26/18.
Why it matters
Together, these papers will decide which DeFi businesses need authorisation and what authorised firms must do before they integrate a protocol. Both papers aim to finalise in early 2027 (January 2027 for CP26/36), ahead of the regime's commencement on 25 October 2027. Builders, wallet providers and regulated firms with DeFi exposure should review them now and consider responding. The deadline for responses to both is 18 November 2026.
How we can help
LawBEAM advises protocol developers, exchanges, wallet providers and payments firms on the UK cryptoasset perimeter, and is preparing a response to GC26/7. For a first, confidential reading of where your business stands, use our free UK Cryptoasset Perimeter Scanner.
Further reading
From the FCA:
- CP26/36: Cryptoasset Perimeter Guidance (21 October 2026; closes 18 November 2026)
- GC26/7: Decentralised Finance Guidance (DeFi) (21 October 2026; closes 18 November 2026)
- PS26/18: Cryptoasset Perimeter Guidance (16 September 2026)
From LawBEAM:
- The FCA Cryptoasset Gateway Is Open
- The FCA Finalises the UK Cryptoasset Regime: Final Rules Published
Contact us
Contact us to discuss how either consultation affects your business.
Roshi Sharma
Founding Partner
Email: roshi@lawbeam.io
Tel: +44 (0) 7815 610 474
LinkedIn: linkedin.com/in/roshi-sharma-lawbeam
This insight is provided for general information only and does not constitute legal advice. It reflects the FCA's publications CP26/36 and GC26/7 (21 October 2026) and PS26/18 (16 September 2026), as at 22 October 2026. For advice on your specific circumstances, please contact us.
