Digital money: Crypto, stablecoins and CBDCs

Four developments shaping the regulatory perimeter for cryptoassets, stablecoins and central bank digital currencies.

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Most of the regulatory obligations in this section sit with issuers and cryptoasset service providers rather than merchants. The immediate issue for merchants is provider continuity as the UK’s new cryptoasset authorisation regime approaches. Stablecoin regulation is also becoming more defined in the UK, EU and US, while the digital pound and digital euro remain longer-term developments rather than payment methods merchants need to implement today.

Developments covered

UK cryptoasset authorisation regime

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Sterling systemic stablecoins

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International stablecoin perimeter: MiCA and GENIUS

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Central bank digital currency: digital pound and digital euro

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UK cryptoasset authorisation regime

The new UK regime regulates cryptoasset providers, creating a continuity issue for merchants that rely on them.

The UK’s new cryptoasset regulatory regime will bring a wider range of cryptoasset activities within FCA authorisation. The FCA published its final rules in June 2026, with the new regime expected to take effect on 25 October 2027. Firms that need authorisation can apply between 30 September 2026 and 28 February 2027. Existing FCA registration under the Money Laundering Regulations does not automatically provide permission under the new FSMA regime. For merchants using cryptoasset payment providers, the principal risk is therefore provider continuity rather than a new merchant compliance requirement.

Key dates

  • 4 February 2026: the FSMA 2000 (Cryptoassets) Regulations 2026 made.
  • 30 June 2026: FCA final cryptoasset rules published (PS26/9 to PS26/13).
  • 30 September 2026 to 28 February 2027: the FCA authorisation gateway is open.
  • 25 October 2027: the FCA regime goes live.

Legal issue/risk

  • No merchant obligation anywhere in the regime. The risk is counterparty continuity.
  • A provider that misses the gateway cannot take new UK contracts and may run off its UK book, stranding any acceptance arrangement built on it.
  • MLR registration does not carry over, so a long-standing provider is not automatically a surviving one.
  • Get intended gateway status in writing before signing or renewing.
  • Build termination and migration rights into new crypto contracts, with the gateway close as the trigger date.

Next steps

  • Ask any existing crypto payments provider to confirm in writing that it intends to apply before 28 February 2027.
  • Add a regulatory-failure termination right to crypto contracts signed between now and the gateway close.

Source

FCA cryptoasset regime policy statements

Sterling systemic stablecoins

The emerging UK framework will shape the economics and operating model for sterling stablecoins used at scale.

The Bank of England published its policy framework and draft Code of Practice for systemic sterling stablecoin issuers in June 2026. The regime covers issues including backing assets, redemption, operational resilience and financial stability, alongside FCA requirements applying to stablecoin issuance. Systemic issuers will be jointly regulated by the Bank and FCA once formally recognised. These rules apply to issuers rather than merchants, but they will help determine the resilience, redemption model and commercial structure of any sterling stablecoins used at scale for payments.

Key dates

  • 22 June 2026: BoE systemic stablecoin policy statement and draft Code of Practice published.
  • 22 September 2026: BoE consultation on the draft Code closes.
  • End 2026: BoE intends to finalise the Code of Practice.
  • 2027: regulated stablecoins could begin operating in the UK.

Legal issue/risk

  • No merchant obligation. The question is purely whether acceptance ever pays.
  • The £40 billion cap and yield-constrained backing may keep issuer economics too thin for stablecoin acceptance to beat card costs.
  • The Code is draft until end 2026, so terms can shift after a provider has pitched you a proposition.
  • Treatment of stablecoin payments as payment services is settled in HM Treasury's consultation, not here. That window closes 6 October 2026.
  • A watching brief, not a project. Nothing to build in H2 2026.

Next steps

  • Ask your PSP whether regulated stablecoin acceptance is on its roadmap, and what it would change for settlement timing and cost.
  • Respond to HM Treasury's payments consultation by 6 October 2026 on how stablecoin payments are treated as payment services (see Modernising payments law and the PSR to FCA consolidation).

Source

Bank of England sterling systemic stablecoin policy statement.

International stablecoin perimeter: MiCA and GENIUS

The EU, UK, and US are developing distinct stablecoin regimes, increasing the importance of provider status across markets.

Stablecoin regulation is now established or developing across several major jurisdictions. The EU’s Markets in Crypto-Assets Regulation is fully applicable and regulates issuers of asset-referenced and e-money tokens as well as cryptoasset service providers. The European Commission is reviewing MiCA in 2026 following its first period of implementation. In the US, the GENIUS Act was signed into law on 18 July 2025, creating a federal regulatory framework for payment stablecoins. It includes requirements around permitted issuers, reserves and anti-money laundering controls. The obligations sit primarily with issuers and service providers rather than merchants accepting stablecoin payments.

Key dates

  • 30 December 2024: MiCA applies in full.
  • By 1 July 2026: the maximum MiCA transitional period under Article 143 expires. Actual national grandfathering periods could end earlier
  • 18 July 2026: US statutory rulemaking deadline under the GENIUS Act passes with no final rules issued.
  • By 18 January 2027: the GENIUS Act takes effect on the earlier of that date and 120 days after final implementing regulations are issued.

Legal issue/risk

  • Neither regime creates an obligation for a UK merchant.
  • MiCA grandfathering has closed, so an EU provider still trading unauthorised is an exit risk now, not a future one.
  • US rules are absent, with the effective date a year out, so any US stablecoin proposition rests on unwritten detail.
  • Taken with the UK regime, regulated stablecoin acceptance becomes a coherent cross-border proposition rather than a jurisdictional patchwork.
  • That coherence is the thing to watch. It is what would make acceptance worth a project rather than a brief.

Next steps

  • If you route euro or dollar flows through a crypto provider, confirm its authorisation status in each jurisdiction it serves you from.
  • Reassess the acceptance case once US rules are issued and the UK Code is final.

Source

ESMA MiCA implementation.

Central bank digital currency: Digital pound and digital euro

Neither project is an immediate merchant implementation issue, but both could shape future payment acceptance.

Neither the digital pound nor the digital euro is currently available for merchant payments. In the UK, the Bank of England and HM Treasury remain in the design phase and have not decided whether to introduce a digital pound. They expect to announce their decision on whether to proceed in 2026 alongside a digital pound blueprint. The digital euro is further advanced. The ECB moved into its next preparation phase in October 2025 and is building the technical capacity needed for a potential launch. If EU legislation is adopted during 2026, the ECB expects a pilot from the second half of 2027 and says it could be ready for a potential first issuance in 2029. For merchants, both remain strategic rather than implementation issues. Their eventual significance will depend on acceptance requirements, intermediary models, fees, settlement arrangements and integration with existing point-of-sale and online payment systems.

Key dates

  • 2026: digital pound design work continues towards completion of the design phase; no issuance decision has yet been made. No decision has been taken, and primary legislation would be required.
  • 2026: EU adoption of the digital euro regulation expected.
  • H2 2027: 12-month ECB digital euro pilot planned.
  • 2029: earliest possible digital euro issuance.

Legal issue/risk

  • No obligation and no decision in either jurisdiction. Nothing to plan for.
  • Digital pound needs primary legislation, so any timeline runs behind a parliamentary process that has not started.
  • A digital euro with the capped merchant fees in the draft regulation would be a genuinely cheap euro-area acceptance rail.
  • Those caps are the thing worth watching. They are drafting, not law, and merchant economics turn on whether they survive.

Next steps

  • EU-facing merchants: watch whether the digital euro's capped merchant fees survive into the final legislation.
  • Otherwise keep both on a watching brief.

Source

Digital pound update and the ECB digital euro pilot.

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