CP25/40: Regulating Cryptoasset Activities
This paper establishes the framework for core cryptoasset activities. Firms and individuals conducting new regulated cryptoasset activities in the UK will generally need FCA authorisation. The paper also discusses the following:
Cryptoasset Trading Platforms
Firms running cryptoasset trading platforms (CATPs) in the UK must obtain FCA authorisation. The consultation addresses:
- Location criteria: Firms operating domestically or serving UK consumers from overseas must secure authorisation and establish UK presence via a subsidiary or branch. However, firms exclusively serving UK institutional clients may operate from overseas without UK authorisation.
- Platform requirements: The paper examines platform access and operational requirements, retail customer protections, conflict management, transparency standards, record-keeping obligations, and settlement procedures.
Cryptoasset Intermediaries
Acting as a cryptoasset intermediary covers several activities: dealing in qualifying cryptoassets as principal (including lending and borrowing services), dealing in qualifying cryptoassets as agent, and arranging deals in qualifying cryptoassets (including operating a cryptoasset lending platform). Intermediaries applying to be authorised in the UK to serve retail clients directly must establish a UK legal entity. The FCA will publish separate guidance for international firms seeking UK authorisation.
- Execution requirements: The FCA proposes the execution or transmission of orders for UK retail or elective professional clients to occur exclusively on UK-authorised venues. Additionally, when executing retail or elective professional client orders as principal, firms should avoid systematically sourcing liquidity from affiliated platforms lacking UK authorisation.
- Retail requirements: The consultation establishes eligibility and execution standards for retail orders, conflict management protocols, transparency requirements for pre and post-trade information, record-keeping standards, client reporting obligations, and settlement expectations.
Lending and Borrowing Services
The FCA proposes permitting retail participation in cryptoasset lending and borrowing, subject to specific safeguards including disclosure requirements, consumer comprehension standards, and express prior consent. The consultation also examines proprietary token usage, liquidity and counterparty risk management, creditworthiness assessment, and margin call and liquidation procedures.
Staking Services
Firms providing regulated staking services must furnish retail clients with comprehensive information about the firm, the staking service, and agreement terms.
Decentralised Finance
The FCA intends to apply its framework to DeFi activities where identifiable controlling persons conduct regulated cryptoasset activities. A separate DeFi guidance consultation will address how control and decentralisation levels factor into regulatory analysis, along with best practices for managing financial crime and operational resilience risks.
CP25/41: Regulating Cryptoassests: Admissions & Disclosures and Market Abuse Regime for Cryptoassets.
This consultation establishes the regulatory structure for public offerings of qualifying cryptoassets and their admission to CATP trading (the A&D regime), alongside a cryptoasset market abuse regime (MARC).
Admissions and Disclosures Framework
The regime covers designated activities including:
- Public offerings of qualifying cryptoassets in the UK;
- disclosing, other than in an advertisement, information about an offer of a qualifying cryptoasset;
- disclosing information relating to a qualifying stablecoin offered to the public in the UK;
- requesting or obtaining the admission of a qualifying cryptoasset to trading on a CATP;
- disclosing, other than in an advertisement, information about an admission, or proposed admission, of a qualifying cryptoasset to trading on a CATP; and
- admitting a qualifying cryptoasset to trading on a CATP.
The consultation paper examines rules for trading admission, liability frameworks for qualifying cryptoasset disclosure documents (QCDDs), withdrawal rights, financial promotion treatment (including QCDD exemptions from promotional restrictions), and consumer duty implications.
The FCA will also regulate UK-issued qualifying stablecoin issuers specifically for issuance activities. These stablecoins face distinct admission and disclosure requirements compared to other qualifying cryptoassets.
Market Abuse Regime for Cryptoassets
MARC proposals address:
- Inside information disclosure obligations and methods of disseminating inside information;
- Legitimate market practices;
- Market abuse systems and controls for CATPs and intermediaries;
- On-chain monitoring;
- Insider list; and
- Cross-platform information sharing mechanisms.
These requirements extend to issuers, offerors, CATPs, and intermediaries.
CP25/42: A Prudential regime for cryptoasset firms.
This paper details prudential requirements for authorised cryptoasset firms, concentrating on CATP operations, staking, deal arrangement, and principal and agency dealing in qualifying cryptoassets. Core proposals encompass own funds requirements, comprehensive risk assessment, and prudential information disclosure.
The FCA has prioritised ensuring its prudential framework addresses UK-specific risks and regulatory standards. The regulator acknowledges that firms may interact with cryptoassets, counterparties, or arrangements with third countries with differing regulatory approaches.
Current stablecoin proposals limit certain exclusions (including position risk requirement exemptions) to qualifying stablecoins meeting UK standards. The FCA has not extended these exclusions to foreign stablecoins presently, though it recognises potential future consideration where regulatory outcomes substantially align.
Following the consultation period closing on 12 February 2026, the FCA will consider feedback before publishing final policy statements in 2026. The regulations will come into force on 25 October 2027, providing firms with substantial time to prepare for compliance.
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