CryptoUK Response to FCA Consultation Paper 25/28 – Progressing Fund Tokenisation (the “Consultation Paper”) – Chapters 2-4
Regulatory Engagement & Advocacy
  • 14 November, 2025

CryptoUK and its members welcome the opportunity to respond to the FCA’s Consultation Paper on fund tokenisation, which outlines 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 and policy.

Our Position

CryptoUK and our members strongly support the FCA’s efforts to accelerate tokenisation within the UK’s authorised funds industry. With its established strength in both financial services and digital assets, the UK is uniquely positioned to lead in this area and shape global standards for tokenised funds.

We agree that many of the FCA’s existing COLL rules already provide a sound foundation for tokenisation. However, certain areas — such as cash-based payment provisions and rules on asset safekeeping — may need to be refined to reflect the operational realities of digital assets.

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 essential to the success of tokenised fund models. Many authorised fund managers will initially depend on digital asset service providers to deliver these solutions effectively.

Visibility and Awareness:
We are concerned that the consultation has received limited visibility and engagement among crypto and fintech stakeholders. Greater outreach would ensure a more inclusive, representative, and technically informed response process.

Future Consultation and Alignment:
We welcome the FCA’s plans to consult on eligible assets for authorised funds, and urge that this process fully involves the digital assets industry.
We also recommend continued collaboration with international regulators to promote alignment and consistency across jurisdictions — supporting cross-border innovation and growth.

Next Steps

CryptoUK will submit a further response to Chapter 5 of the Consultation Paper before the 12 December deadline. We thank our members for their input and CMS for their support in preparing this submission.

We look forward to ongoing dialogue with the FCA and other stakeholders to ensure that the UK continues to lead globally in the adoption and regulation of digital assets.

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