Ursprungligen publicerad av Taylor Wessing den 2026-01-12
Inuti FCA:s konsultationstrilogi om krypto: en praktisk guide
Tre samrådsdokument från FCA som offentliggjordes i slutet av 2025 fastställer detaljerade regler för brittiska kryptoföretag — från handelsplattformar till marknadsmissbruk. Vi går igenom de viktigaste förslagen och de avgörande tidsfristerna.
If the UK government's December 2025 announcement was the headline, the three consultation papers published by the Financial Conduct Authority are the fine print. Together, CP25/40, CP25/41 and CP25/42 form the most detailed regulatory blueprint for crypto-assets ever produced by a major financial regulator — and firms operating in the UK market need to understand what they contain.
CP25/40: The Framework for Activities
The first paper tackles the broadest question: which crypto activities will require FCA authorisation? The answer is essentially all of them. Trading platforms, intermediaries, lending and borrowing services, staking providers and even certain decentralised finance activities fall within scope. Larger platforms — those exceeding £10 million in average annual revenue — face additional obligations, including rules on non-discriminatory access and enhanced transparency requirements.
For consumer lending specifically, the FCA proposes mandatory over-collateralisation requirements. This is a direct response to the wave of crypto lending platform collapses in 2022-2023, and it signals that the regulator has carefully studied the industry's failure patterns.
CP25/41: Disclosure and Market Abuse
The second paper introduces requirements that will feel familiar to anyone who has worked in traditional securities markets. Issuers seeking admission to UK trading platforms must produce qualified crypto-asset disclosure documents — essentially prospectuses — including a two-page summary highlighting the key risks. The market abuse framework prohibits insider dealing and market manipulation, and large platforms are required to monitor on-chain activity to detect suspicious patterns.
This is where the regulation becomes genuinely pioneering. Monitoring on-chain activity for market abuse poses a technical challenge with no direct equivalent in traditional finance. In practice, the FCA is requiring platforms to develop blockchain analytics capabilities that go well beyond today's industry standards.
CP25/42: Prudential Requirements
The third paper sets out the financial buffers crypto firms must maintain. The own funds requirements
Source: Taylor Wessing