CryptoUK Response to FCA Consultation Paper 25/28 – Progressing Fund Tokenisation (the “Consultation Paper”)
CryptoUK and its members welcome the opportunity to respond to the FCA’s Consultation Paper on fund tokenisation, which sets out the regulator’s approach to enabling innovation within the UK’s authorised funds sector.
As the UK’s self-regulatory trade association for the cryptoasset industry, CryptoUK represents more than 100 leading firms across the digital assets ecosystem — including many with international reach and deep expertise in regulation, technology, and policy.
Our Position
CryptoUK and our members strongly support the FCA’s efforts to accelerate tokenisation across the authorised funds industry. With its established strengths in both financial services and digital assets, the UK is well positioned to lead globally in the development of tokenised fund models and to help shape emerging international standards.
We agree that many of the FCA’s existing COLL rules already provide a sound basis for tokenisation. However, certain areas — including provisions relating to cash-based payments, asset safekeeping, and the operational realities of tokenised portfolios — may require refinement to ensure they remain fit for purpose as the market evolves.
Our response also builds on these themes in addressing Chapter 5 of the Consultation Paper, which explores the future vision of tokenised portfolio management. We highlight the importance of interoperability and programmability, the need for proportionate safeguards around tokenised cashflows, and the opportunities and risks presented by more composable investment models. These considerations are essential to ensuring that innovation enhances, rather than compromises, consumer outcomes, market integrity, and operational resilience.
Key Themes from Our Response
Collaboration and Engagement:
We encourage the FCA to deepen its engagement with the digital assets sector, whose technical and operational expertise will be critical to delivering effective tokenised solutions. Many authorised fund managers will rely on specialist providers as the market develops.
Visibility and Awareness:
We remain concerned that consultation on these important changes has received limited visibility among crypto and fintech stakeholders. Broader engagement would help ensure a more inclusive, representative, and technically informed response base.
Future Consultation and Alignment:
We welcome the FCA’s intention to consult on eligible assets for authorised funds and urge that this process fully involves the digital assets industry. International regulatory alignment will also be vital for supporting cross-border innovation and growth.
Evolving Tokenisation Models:
Our Chapter 5 response reflects member insights into tokenised cashflows, composability, liquidity considerations, and the potential reshaping of operating models in portfolio management. These developments offer significant opportunities for efficiency and transparency, but also introduce new complexities that must be appropriately addressed through proportionate regulation.
Next Steps
With the submission of our responses to Chapters 2–4 and to Chapter 5, CryptoUK and its members look forward to continued dialogue with the FCA and other stakeholders. We remain committed to supporting a regulatory environment that enables responsible innovation and strengthens the UK’s position as a global leader in digital assets and tokenised finance.
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