CryptoUK Response to FCA CP26/32 – Chapter 4: Deferral Arrangements for the Cryptoasset Regime
The Financial Conduct Authority (FCA) published CP26/32, Quarterly Consultation Paper No. 53, setting out proposed amendments to its regulatory framework, including transitional deferral arrangements for the UK’s forthcoming cryptoasset regime.
Chapter 4 focuses on proposed deferrals relating to cryptoasset admissions and disclosures, execution venue requirements and execution policies, ahead of the new regime coming into effect on 25 October 2027.
These arrangements are intended to support an orderly transition into the regulatory framework, recognising the operational and implementation challenges facing firms.
CryptoUK and members’ response
Our response proposes a common nine-month deadline, ending on 25 July 2028, for admission assessments and disclosure documents for eligible assets already trading before a platform’s UK authorisation. Later-authorised firms would receive the remaining period. Relief should end earlier when the relevant operator publishes its disclosure document, with market abuse requirements applying from commencement.
We seek corresponding relief for intermediaries, correction of inconsistent deadlines and an authoritative FCA service showing each asset’s status on each platform. Verified disclosure information should be reusable while firms retain their own responsibilities. The FCA should clarify which documents and warnings clients need where an asset’s status differs between platforms.
For clients, we propose a short warning and acknowledgement before their first trade in each deferred asset, with a prominent status notice and accessible explanation, supported by consumer testing. We also seek clarification on existing holdings where an asset fails to complete admission.
We propose six months for execution venue requirements and detailed execution policies, compared with the FCA’s proposed three. Before expiry, the FCA should assess venue permissions, asset coverage, liquidity and order-routing capacity, granting targeted extensions where necessary. Existing clients would have a separate migration period of up to twelve months, with required prior consent obtained before an affected trade.
Overall position
CryptoUK’s submission, informed by the views and practical experiences of its members, supports targeted transitional arrangements that enable firms to prepare for the new regulatory framework without weakening the obligations that apply from commencement.
The recommendations seek to provide greater consistency in implementation deadlines, clearer regulatory expectations and an evidence-based approach to addressing specific market-readiness challenges.
CryptoUK and its members encourage the FCA to consider these proposals when finalising the transitional arrangements for the UK’s new cryptoasset regulatory regime.
Download our full response
