CryptoUK Response to FCA Consultation Paper CP25/41: Regulating cryptoassets: Admissions & disclosures and market abuse regime for cryptoassets
On 16 December 2025, the Financial Conduct Authority (FCA) published a coordinated package of three crypto consultation papers, setting out the next phase of the UK’s digital asset regulatory framework. Following the publication of our first response earlier this week, today we are pleased to share the second of our three responses. This response covers CP25/41: Admissions & Disclosures and the Market Abuse Regime for Cryptoassets, which focuses on how cryptoassets should be admitted to trading, the disclosures firms must make, and the rules designed to prevent unlawful disclosure, insider dealing, and market manipulation. Together, these measures aim to underpin fair, orderly, and transparent UK crypto markets.
In our response, CryptoUK welcomes the proposal to introduce transitional arrangements for disclosure requirements covering cryptoassets already in circulation. A clearly defined transitional period is critical to effective compliance and should apply consistently to both Cryptoasset Trading Platforms (CATPs) and persons applying for admission. Introducing disclosure obligations for CATPs ahead of issuers risks regulatory uncertainty, inconsistent or incomplete disclosures, and additional costs — challenges already observed during the implementation of MiCA.
We also highlight the importance of clarity around the reusability of admission documents. Where a cryptoasset has previously been admitted to trading and documentation has already been filed by an issuer or CATP, other market participants should be able to rely on that documentation, provided the information can be verified and updated where necessary. This approach would reduce duplication, lower costs, and more closely align the UK regime with existing MiCA exemptions.
Finally, our response calls for explicit guidance on the treatment of legacy listings. The industry requires certainty on whether cryptoassets already admitted to trading would be required to relist under the new regime, as has been the case in other jurisdictions.
This second consultation represents another important building block in the UK’s evolving crypto regulatory framework. We look forward to continuing constructive engagement with the FCA as the remaining elements of the regime are developed and finalised.
