From 25 October 2027, the UK’s new cryptoasset framework will bring activities including operating trading platforms, dealing, arranging deals, safeguarding cryptoassets, staking and issuing qualifying stablecoins within the FCA’s regulatory perimeter. This section brings together the legislation establishing the regime, the authorisation process and the FCA’s detailed rules on conduct, safeguarding, prudential requirements, disclosures and market abuse. It also covers the Bank of England’s emerging framework for stablecoins that may become systemically important.
Developments covered
🟥 Urgent / significant impact
Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026
From October 2027, a range of cryptoasset activities will be regulated under FSMA, and firms will require FCA authorisation to carry out these activities
The Regulations establish a comprehensive framework for cryptoasset activities, bringing activities such as issuance, safeguarding, trading platform operation, dealing, arranging and staking within the FCA’s regulatory perimeter. Firms carrying on these activities by way of business will require FCA authorisation. The regime also introduces new restrictions on public offers of qualifying cryptoassets, a market abuse framework covering insider dealing and market manipulation, and updates to the AML and financial promotions regimes to reflect the new regulatory perimeter.
Key dates
- 25 February 2026: Certain provisions commenced, enabling the FCA to make rules, issue guidance and take preparatory steps.
- 30 September 2026 to 28 February 2027: FCA authorisation application window
- 25 October 2027: Regime comes into force
Potential impact
From 25 October 2027, firms carrying on regulated cryptoasset activities in the UK without the necessary FCA authorisation may breach the general prohibition under FSMA, unless an exemption or applicable transitional provision applies. The Regulations also introduce new requirements for cryptoasset offers and market abuse, while changes to the regulatory perimeter mean firms should review existing AML and financial promotions compliance arrangements.
Next steps
- Assess whether your cryptoasset activities fall within the new regulated perimeter and whether FCA authorisation will be required.
- Prepare and submit authorisation applications during the FCA’s application window, which opened on 30 September 2026 and closes on 28 February 2027.
- Monitor FCA rulemaking and guidance as the detailed regime develops.
- Review AML and financial promotions controls against the new framework.
🟥 Urgent / significant impact
Cryptoasset authorisation gateway opens
The FCA has set out how firms will apply for authorisation under the new UK cryptoasset regime, including key application deadlines and transitional arrangements.
FCA has published guidance explaining how the authorisation gateway for the new regulated cryptoasset activities under FSMA 2000 will operate. Firms wishing to undertake regulated cryptoasset activities will need FCA authorisation or, where appropriate, a variation of existing permissions. Existing MLR registration will not convert automatically to FCA authorisation.
The FCA will also offer information sessions and its optional pre-application support service (PASS). Firms applying within the application window should receive a determination before the new regime comes into force or, where necessary, benefit from saving provisions while their application is determined. Firms applying late may be restricted to servicing existing contracts only.
Key dates
- Ongoing: PASS meetings
- 30 September 2026 to 28 February 2027: Authorisation gateway
- 25 October 2027: Regime comes into force
Potential impact
MLR-registered firms must obtain FCA authorisation to continue carrying on regulated cryptoasset activities. Firms with existing UK cryptoasset business that miss the application window may be unable to benefit from the savings provisions when the new regime begins, potentially disrupting their ability to continue regulated activities.
Next steps
- Confirm whether your activities require FCA authorisation or a variation of existing permissions
- Submit an FCA authorisation application, or an application to vary existing permissions, by 28 February 2027.
- Consider using the FCA’s PASS service and information sessions to support application readiness
- MLR-registered firms should not assume existing registration will carry over into the new regime
🟥 Urgent / significant impact
PS26/9 Crypto Regime: Admissions & Disclosures and Market Abuse Regime for Cryptoassets
The Admissions and Disclosures (A&D) regime introduces due diligence and disclosure requirements for qualifying cryptoassets admitted to trading, while the Market Abuse Regime for Cryptoassets (MARC) establishes controls to detect and prevent market abuse.
PS26/9 sets out the FCA’s final rules for the Admissions & Disclosures (A&D) regime and the Market Abuse Regime for Cryptoassets (MARC). Under the new framework, retail UK qualifying cryptoasset trading platforms (UK QCATPs) become gatekeepers, responsible for carrying out due diligence and ensuring a qualifying cryptoasset disclosure document (QCDD) is published before a qualifying cryptoasset is admitted to trading. MARC also introduces systems and controls requirements to detect and prevent insider dealing, unlawful disclosure and market manipulation, with enhanced obligations for larger platforms.
The FCA has largely confirmed its consultation proposals, while refining areas such as disclosure requirements, digital token identifiers, on-chain monitoring and intermediary notification rules.
Key dates
- September 2026: FCA consultation on transitional arrangements for cryptoassets already in circulation.
- 30 September 2026 – 28 February 2027: FCA authorisation application window for firms seeking permission under the new cryptoasset regime.
- 25 October 2027: Regime go-live/rules apply
Potential impact
Although the regime does not take effect until October 2027, firms will need sufficient time to implement disclosure processes, admission controls and market abuse surveillance before go-live. Failure to publish a compliant QCDD or meet MARC obligations could result in firms being unable to admit qualifying cryptoassets or operate compliantly.
Next steps
- Confirm whether your firm is in scope as a UK QCATP, intermediary, issuer or large platform
- Begin preparing QCDD publication, due diligence and record-keeping processes
- Develop market abuse surveillance, insider-list governance and disclosure controls
- Review the outcome of the September 2026 consultation and assess whether any transitional arrangements affect your business.
🟥 Urgent / significant impact
PS26/10 Crypto Regime: Stablecoin Issuance
The FCA’s final rules establish the regulatory framework for non-systemic UK-issued qualifying stablecoins, covering issuance, backing assets, redemption, safeguarding and disclosures.
PS26/10 sets out the FCA’s final framework for non-systemic UK-issued qualifying stablecoins. Issuers will need FCA authorisation and must comply with requirements on backing assets, redemption, statutory trust arrangements, custody, reconciliations and disclosures.
The FCA has largely confirmed its consultation proposals, with targeted refinements to improve proportionality. The Backing Asset Composition Requirement has been simplified by removing the forward-looking redemption-forecast component. The FCA has also confirmed statutory trust arrangements, permitted limited intragroup custody with safeguards, allowed a 5% backing-pool excess, and reduced the issuer capital requirement to 1% of issued value.
Systemic stablecoin issuers will be subject to a separate regulatory framework involving both the FCA and Bank of England.
Key dates
- 30 September 2026: Consultation deadline for the FCA/Bank of England approach to joint regulation of systemic stablecoin issuers
- 30 September 2026 to 28 February 2027: Authorisation gateway
- 25 October 2027: Rules apply
Potential impact
Issuing a UK-qualifying stablecoin will be a regulated activity, so firms must obtain FCA authorisation. Existing AML or MLR registrations will not convert automatically. Firms will also face an ongoing compliance burden, including backing-asset requirements, CASS 16 custody and segregation, statutory trust arrangements, redemption rights, stablecoin QCDD disclosures and record retention.
Issuers that could become systemic should also plan for a potential step-up into the joint FCA-Bank of England regime, with materially different requirements on backing assets, redemption, capital and operational arrangements.
Next steps
- Map current or planned stablecoin activity against the final rules and prepare for the authorisation gateway; use the FCA's pre-application support (PASS) service
- Assess backing-pool strategy, redemption arrangements and the 1% capital requirement.
- Build stablecoin QCDD, quarterly disclosure, custody, reconciliation and record-keeping processes.
- Track the BoE/FCA joint-regulation consultation (closes 30 September 2026) if systemic recognition is plausible
🟥 Urgent / significant impact
PS26/11 Crypto Regime Regulated Cryptoasset Activities
The FCA’s final rules establish the conduct and operational requirements for regulated cryptoasset activities, including trading platforms, dealing, lending, staking, safeguarding and certain DeFi arrangements.
PS26/11 sets out the FCA’s final rules for the core regulated cryptoasset activities under the Cryptoasset Regulations 2026. It covers operating a qualifying cryptoasset trading platform (QCATP), dealing, arranging, lending and borrowing, staking, safeguarding, and the FCA’s current approach to DeFi, where there is an identifiable controlling entity.
The FCA has largely confirmed its consultation proposals while refining areas such as best execution, pre-trade transparency, retail protections for lending and staking, safeguarding under CASS 17, and the treatment of DeFi. Further guidance on assessing decentralisation is expected.
Key dates
- 16 September 2026: FCA publishes final guidance on the regulatory perimeter for cryptoasset activities (PS26/18).
- 30 September 2026 to 28 February 2027: Authorisation gateway
- 25 October 2027: Rules apply
- Date TBC: Further DeFi guidance
Potential impact
Firms carrying on regulated cryptoasset activities in the UK may require FCA authorisation, including overseas firms where their activities fall within the UK regulatory perimeter. Missing the application window could restrict firms’ ability to continue operating under transitional arrangements. The new safeguarding requirements under CASS 17 also introduce significant operational, record-keeping and notification obligations.
Next steps
- Confirm which regulated cryptoasset activities your firm carries on and whether it falls within scope.
- Prepare an authorisation application ahead of the gateway window.
- Assess readiness for CASS 17 safeguarding requirements, including custody, record-keeping and notification processes.
- Review the FCA’s published perimeter guidance (PS26/18), monitor its further consultation (CP26/36) and assess the implications alongside PS26/9, PS26/12 and PS26/13.
🟥 Urgent / significant impact
PS26/12 Crypto Regime A Prudential Regime for Cryptoasset Firms
FCA finalises the UK prudential rulebook for cryptoasset firms (COREPRU and CRYPTOPRU), setting capital, liquidity and risk-management standards
PS26/12 sets out the FCA’s final prudential framework for FCA solo-regulated cryptoasset firms. The new COREPRU and CRYPTOPRU sourcebooks establish requirements covering own funds, liquidity, concentration risk, overall risk assessment and public disclosures, including provisions for stablecoin issuers and cryptoasset custodians.
The FCA has broadly confirmed its consultation proposals while making targeted refinements to improve proportionality, including changes to capital requirements, market risk and disclosure obligations. The rules do not apply to PRA-regulated banks, insurers or PRA-designated investment firms.
Key dates
- 24 September 2026: FCA publishes PS26/18, its final cryptoasset perimeter guidance.
- 30 September 2026 to 28 February 2027: Authorisation gateway
- 25 October 2027: Rules apply
Potential impact
Many in-scope firms may need to increase or restructure capital to meet the new prudential requirements, which could affect authorisation readiness. Firms that are also subject to MIFIDPRU should consider how the two prudential regimes interact.
Next steps
- Confirm whether your firm falls within scope and identify the prudential requirements that apply
- Carry out an early capital and liquidity gap analysis and assess any wind-down planning implications
- Prepare prudential information as part of your authorisation application
- Monitor forthcoming FCA guidance on the regulatory perimeter and prudential framework
🟥 Urgent / significant impact
PS26/13 Crypto Regime Application of FCA Handbook for Regulated Cryptoasset Activities
The FCA’s final policy statement applies key Handbook requirements, including Consumer Duty, SM&CR, CASS, SYSC, DISP and regulatory reporting, to regulated cryptoasset firms
PS26/13 sets out how the FCA’s cross-cutting Handbook obligations apply to firms carrying on regulated cryptoasset activities. Most firms will be subject to requirements including Consumer Duty, Conduct of Business (COBS), the Senior Managers and Certification Regime (SM&CR), SYSC, CASS, DISP and Financial Ombudsman Service access, alongside regulatory reporting obligations.
The FCA has broadly confirmed its consultation proposals while making targeted refinements, including the treatment of UK-issued qualifying stablecoins, the application of Consumer Duty in certain cryptoasset activities, and arrangements for dual-regulated firms operating through UK branches. Further perimeter guidance is expected in autumn 2026.
Key dates
- 16 September 2026: FCA publishes final cryptoasset perimeter guidance (PS26/18).
- 30 September 2026 to 28 February 2027: Authorisation gateway
- 25 October 2027: Rules apply
Potential impact
Most Handbook obligations will apply once firms are authorised, meaning firms will need appropriate governance, systems and controls in place before go-live. Consumer Duty and SM&CR will increase senior management accountability, while aspects of the Duty continue to evolve pending related FCA guidance.
Next steps
- Identify which FCA Handbook sourcebooks apply to your regulated cryptoasset activities
- Carry out a gap analysis ahead of the authorisation gateway, prioritising Consumer Duty, SM&CR, CASS and safeguarding
- Dual-regulated firms should engage with the PRA early to confirm the most appropriate operating structure
- Monitor forthcoming FCA guidance before finalising compliance plans
🟥 Urgent / significant impact
CP26/36 and PS26/18: Cryptoasset perimeter guidance
The FCA's final guidance on which cryptoasset activities need authorisation, and which permissions they need, issued as the authorisation gateway opens.
PS26/18 finalised the FCA’s perimeter guidance for the new regulated cryptoasset activities in a new PERG 18, following CP26/13. It reflects the Cryptoassets Regulations as made in February 2026, but not HM Treasury’s amending SI, laid on 15 September 2026, which adds new exclusions. CP26/36 consults on the PERG changes needed to reflect that SI. The proposals most relevant to payments firms are:
- indicators for telling qualifying stablecoins apart from e-money (a product cannot be both)
- a safeguarding exclusion for UK qualifying stablecoins (UKQS) held temporarily to execute a payment transaction, which the FCA expects to be accompanied by an order for onward transfer
- a dealing and arranging exclusion for transfers and exchanges of UKQS, which does not cover lending or borrowing
- a technical-services exclusion from arranging, which authorised persons and payment service providers cannot use
Several of the stablecoin exclusions apply only to UKQS, not to overseas or other qualifying stablecoins. CP26/36 also covers decentralisation and DeFi, the revised temporary settlement exclusion, proprietary trading and market making, and CSD arrangements.
Key dates
- 16 September 2026: PERG 18 came into force
- 30 September 2026 – 28 February 2027: Authorisation application window, for firms wishing to use the savings provisions
- 18 November 2026: consultation closes
- 28 February 2027: application window closes
- Spring 2027: Final amended PERG guidance (expected)
- 25 October 2027: Regime comes into force, and the remaining PERG amendments (PERG App 1 definitions) apply
Potential impact
- There is no automatic conversion: existing FSMA permissions, MLR registrations and PSRs/EMRs authorisations do not convert. EMIs and PSPs are named as firms whose activities may intersect with the regime
- The new exclusions are conditional and narrow:
- The payment-transaction safeguarding exclusion covers UKQS only and depends on a linked onward transfer.
- The dealing and arranging exclusion does not cover UKQS lending or borrowing.
- The stablecoin collateral exclusion is unavailable where the counterparty is a consumer.
- EMIs and PIs cannot rely on the technical-services exclusion. It also does not extend to dealing, safeguarding, financial promotions or the MLRs.Exclusions differ from traditional markets. Familiar RAO exclusions are not all replicated for cryptoasset activities, and there is no Overseas Persons Exclusion. Firms cannot assume an exclusion carries over
- Labels such as “DeFi” or “DAO” do not take an arrangement outside the perimeter. UK-based people involved in governance, operation or development may create a UK nexus.For custody firms with existing Article 40 permissions need a variation of permission to safeguard relevant specified investment cryptoassets (RSICs)
- The SI awaits approval and final guidance is due after the application window closes, so perimeter analyses in applications may need revisiting
Next steps
- Respond to CP26/36 by 18 November 2026, via the form on the FCA website or at: cp26-36@fca.org.uk
- Classify each stablecoin product you issue, hold or transmit
- Re-run perimeter analyses for stablecoin payment flows, collateral arrangements and technical integrations against PS26/18 read with the draft CP26/36 guidance
- Apply within the window, by 28 February 2027, to preserve the savings provisions. Flag in the application where conclusions rest on draft guidance, and consider booking a PASS meeting
🟧 Important, uncertain timing/impact
Sterling-denominated systemic stablecoins: Policy statement and consultation on draft Code of Practice
The Bank of England has published revised draft rules for systemic sterling stablecoins, together with a consultation on the Code of Practice that will govern prudential and operational requirements.
The policy statement responds to the Bank's November 2025 consultation, and confirms a more proportionate approach to the proposed regime. Changes include greater flexibility for backing assets, removal of proposed per-coin holding caps, and revised arrangements for firms expected to become systemic. Systemic stablecoin issuers will be jointly regulated by the Bank of England and the FCA, while non-systemic issuers remain under FCA supervision.
Key dates
- 22 September 2026: Consultation on the draft Code of Practice closes
- End-2026: Bank intends to finalise the Code of Practice
- 2027: Further guidance and supporting materials expected
- 2027: Regulated systemic stablecoins expected to begin operating in the UK
Potential impact
The proposals apply only to firms recognised by HM Treasury as systemic, but firms expecting to scale should assess the impact of the more demanding prudential, capital, liquidity and safeguarding requirements. As the Code of Practice is still in draft form, firms should expect further refinement before implementation.
Next steps
- You can respond to the consultation questions (Section 3.2 here) using the web form or via email at: CP-systemicstablecoin@bankofengland.co.uk You can also respond via post at: FMID Payments Policy Team, Bank of England, 20 Moorgate, London, EC2R 6DA
- Assess whether your stablecoin activities could become systemic and model the impact of the proposed prudential requirements.
- Review the draft Code of Practice against your operating model, including backing assets, redemption, safeguarding and capital arrangements.
- Monitor publication of the final Code and related FCA guidance.
🟧 Important, uncertain timing/impact
Bank of England & FCA: Approach to Joint Regulation of Systemic Stablecoin Issuers
The Bank of England and FCA have outlined how UK-issued stablecoin issuers will transition from FCA-only supervision to joint regulation once recognised by HM Treasury as systemic.
The approach document explains how responsibilities will be shared between the FCA and the Bank of England, with the FCA retaining responsibility for conduct and consumer protection, while the Bank oversees prudential and financial stability matters. It also explains how firms transition into the joint regime, the introduction of the “systemic at launch” category, and how the two regulatory frameworks will interact.
Recognition as systemic will be determined by HM Treasury on a case-by-case basis. Firms recognised as systemic will be subject to significantly more demanding prudential and operational requirements than FCA-only issuers.
Key dates
- 22 September 2026: Consultation on the Bank’s draft Code of Practice closes
- 30 September 2026: Consultation on the joint regulatory approach closes
- End-2026: Bank intends to finalise the Code of Practice
- 25 October 2027: FCA stablecoin authorisation regime takes effect
- 2027: Further supervisory guidance and supporting materials expected
Potential impact
Firms that become systemic will face a significant increase in prudential, operational and supervisory requirements, including dual oversight by the Bank and FCA. As the regime and Code of Practice are not yet finalised, firms should expect further refinement before implementation.
Next steps
- Assess whether your stablecoin activities could plausibly become systemic and model the implications of transitioning to the joint regime.
- Consider responding to the consultations, particularly on transition arrangements and business-model impacts.
- Prepare for coordinated supervision across the Bank, FCA and, where relevant, the PRA and PSR.
- Monitor finalisation of the Code of Practice and further guidance during 2027.
🟧 Important, uncertain timing/impact
FS26/1: Tokenisation in Wholesale Financial Markets
The FCA and Bank of England set out what industry told them about wholesale tokenisation and what their joint Tokenisation Roadmap will cover.
FS26/1 is the joint FCA and Bank of England feedback statement on their May 2026 Call for Input on tokenisation in UK wholesale markets. It summarises 123 responses and sets out next steps. It does not make rules. Respondents broadly supported the authorities' vision and principles. They saw post-trade, and especially collateral mobility, as the main opportunity. They asked for faster progress and a move from sandboxes to permanence, including a long-term settlement model after the Digital Securities Sandbox (DSS).
The authorities confirm that stablecoins can be used as settlement assets in the DSS, subject to conditions and to Treasury amendments to regulations. They will also consider whether tokenised assets such as stablecoins can be eligible collateral in the Bank's Sterling Monetary Framework, including DIGIT. They restate that every regulated activity needs an accountable person, and they see no case to change the perimeter for DeFi. Until new rules are made, firms safeguarding RSICs will be assessed under CASS 6.
For payments firms, the relevance is the settlement leg: stablecoins as settlement assets, the Bank's synchronisation service for settlement in central bank money, and the move towards near-24/7 RTGS/CHAPS hours.
Key dates
- 14 September 2026: FS26/1 published, alongside the FCA's Call for Input on tokenised gold (confirmed)
- 23 October 2026: Tokenised gold Call for Input closes (confirmed; see companion entry)
- Later in 2026: Joint FCA–Bank Tokenisation Roadmap published, with target dates for each workstream (expected)
- Later in 2026: Bank consultation on a supervisory statement, plus a discussion paper, on CCPs accepting tokenised collateral (expected)
- H1 2027: FCA consultation on rules for safeguarding RSICs (expected)
- Date TBC: FCA consultation on resolution and insolvency for stablecoin issuers and cryptoasset custodians
Potential impact
The proposals apply only to firms recognised by HM Treasury as systemic, but firms expecting to scale should assess the impact of the more demanding prudential, capital, liquidity and safeguarding requirements. As the Code of Practice is still in draft form, firms should expect further refinement before implementation.
Next steps
- You can respond to the consultation questions (Section 3.2 here) using the web form or via email at: CP-systemicstablecoin@bankofengland.co.uk You can also respond via post at: FMID Payments Policy Team, Bank of England, 20 Moorgate, London, EC2R 6DA
- Assess whether your stablecoin activities could become systemic and model the impact of the proposed prudential requirements.
- Review the draft Code of Practice against your operating model, including backing assets, redemption, safeguarding and capital arrangements.
- Monitor publication of the final Code and related FCA guidance.
🟧 Important, uncertain timing/impact
GC26/7: Decentralised finance guidance (DeFi)
FCA guidance consultation on how existing operational resilience and financial crime rules apply to firms that provide financial services using DeFi or interact with it.
GC26/7 consults on non-Handbook guidance on how existing operational resilience (SYSC 15A) and financial crime (SYSC 6, MLRs) requirements apply when FCA-regulated firms use DeFi or interact with it. It creates no new requirements. The FCA’s position is that firms must meet the same outcomes whatever technology they use, and that calling a business model decentralised does not on its own decide whether it needs authorisation.
The operational resilience chapter applies SYSC 15A to DeFi-specific risks. These include smart contract and bridge vulnerabilities, oracle failure, protocol governance and dependence on third parties such as RPC node providers. It covers important business services, impact tolerances, mapping, scenario testing and communications, with worked examples of a staking firm and a non-custodial wallet provider.
The financial crime chapter covers business-wide risk assessments and CDD/EDD triggers (mixers, privacy coins, flows across several protocols). It also covers ongoing monitoring, SARs and the Travel Rule for transfers involving non-custodial wallets. Six case studies, including the 2026 KelpDAO/LayerZero and Drift exploits, illustrate the risks.
The scope goes beyond crypto-native firms. It includes firms that receive cryptoassets from clients or partner with firms that use DeFi. The FCA also names tokenised markets and agentic payments as emerging DeFi use cases.
Key dates
- 14 September 2026: Call for Input published (confirmed)
- 23 October 2026: Call for Input closes (confirmed)
- Date TBC: FCA to set out its policy approach. The paper gives no date for feedback or next steps
- 30 September 2026 to 28 February 2027: FCA authorisation application window
- 18 November 2026: Consultation closes
- Q1 2027: Final guidance published (expected)
- 25 October 2027: Cryptoasset regime comes into force; SYSC 15A applies to all cryptoasset firms (confirmed)
Potential impact
- No new obligations arise; however, the guidance sets out how the FCA reads existing SYSC 15A, SYSC 6 and MLR duties in a DeFi context. That reading is likely to shape supervisory expectations and the assessment of applications made in the gateway window.
- Firms stay accountable for dependencies they do not control, such as protocols, bridges, oracles and node providers. SYSC 15A applies to third-party arrangements whether or not they count as outsourcing.
Next steps
- Consider responding to the consultation by 18 November 2026, either through the form on the FCA's website or by email to: GC267@fca.org.uk
- Inventory all DeFi touchpoints: direct protocol use, receipt of client cryptoassets, and partners that use DeFi. Reflect them in the business-wide risk assessment.
- Extend important business service mapping to cover DeFi dependencies, including oracles, bridges, RPC nodes and admin key or upgrade controls. Add DeFi failure scenarios to resilience testing.
- Review EDD triggers and blockchain analytics for privacy-enhancing technologies and multi-protocol flows. Review Travel Rule procedures for non-custodial wallets against JMLSG guidance.
- Track publication of the final guidance, expected in Q1 2027.
🟩 Long-term/indicative
Tokenised gold: Call for input on opportunities and risks for UK wholesale markets
The FCA is asking whether tokenised gold could work as wholesale collateral and a retail product, and whether gold tokens need clearer treatment under the collective investment scheme (CIS) and alternative investment fund (AIF) regulatory perimeter.
The FCA has published a call for input on whether tokenisation could improve how gold is traded, transferred, pledged and held in UK markets, while keeping market integrity and consumer protection intact. The paper follows the May 2026 joint FCA–Bank of England Call for Input on wholesale tokenisation. Respondents to that paper raised gold, given London's position as the largest spot gold market. The scope covers only tokens that confer ownership of underlying physical gold and have evidenced backing and reliable redemption.
On wholesale use, the FCA looks at tokenised gold as collateral in repo, securities lending and derivatives, and at delivery-versus-payment against tokenised cash. For payments firms, this is where stablecoins and tokenised deposits come in. Open questions include holder rights, insolvency treatment, collateral enforcement, settlement finality, reconciliation and prudential treatment. On retail, the FCA sets minimum disclosure expectations.
The paper also asks whether gold tokens fall within the CIS/AIF perimeter. The FCA lists possible responses, which it says are not firm proposals. They range from a good and poor practice note, through guidance, an 'eligible gold token' classification and targeted HMT exemptions, to a bespoke regime for tokenised commodities.
Key dates
- 14 September 2026: Call for Input published (confirmed)
- 23 October 2026: Call for Input closes (confirmed)
- Date TBC: FCA to set out its policy approach. The paper gives no date for feedback or next steps
Potential impact
- The paper creates no new obligations
- A gold token that meets the three limbs of the statutory CIS definition is a CIS. A CIS dedicated to gold may be an unregulated CIS, which restricts marketing to consumers. CIS or AIF classification would also bring authorisation, distribution, disclosure and supervisory requirements for the operator. The FCA says fractional interests in a bar that is managed or disposed of collectively point towards pooling
- Even if a CIS/AIF exemption is introduced, a token may still be a "qualifying cryptoasset" under article 88F RAO. That would bring it into the new cryptoasset regime and its authorisation window
Next steps
- Respond by 23 October 2026 to tokenisedsecurities@fca.org.uk. For payments firms, Q2 (interoperability and collateral) and Q5 (fit with other tokenisation initiatives) are the most relevant questions
- Firms issuing, distributing or settling against gold tokens should test their structures against the CIS/AIF definitions (allocated bar vs pooled fractional interest). They should also check whether the qualifying cryptoasset definition applies, and if so, whether they need to apply within the window closing 28 February 2027
- Track the FCA/Bank of England Tokenisation Roadmap and any FCA feedback on this paper