FCA Publishes Further Consultation on Application of the FCA Handbook to Cryptoasset Activities

The UK Financial Conduct Authority (FCA) has published a consultation on proposed rules and guidance for firms conducting regulated cryptoasset activities (CP26/4), together with a guidance consultation on the application of the Consumer Duty to cryptoasset firms (GC26/2). CP26/4 is the second part of an earlier consultation on the application of the FCA’s rules to cryptoasset activities, published in September 2025 (CP25/5), and reflects feedback to CP25/5 and other related consultations.

The FCA is currently completing its programme of consultations under its “crypto roadmap”, which includes CP26/4 and GC26/2. While CP26/4 sets out proposals to apply the FCA Handbook to cryptoasset activities, GC26/2 proposes specific guidance on how cryptoasset firms should apply the Consumer Duty.

CP26/4

CP26/4 proposes how core FCA frameworks will apply to authorised cryptoasset firms, alongside targeted crypto‑specific guidance. 

In CP26/4, the FCA is consulting on, among other things:

• applying the Consumer Duty to cryptoasset firms, supported by additional non-Handbook guidance to ensure firms deliver good outcomes for retail customers;
• extending the Conduct of Business sourcebook to cryptoasset activities – e.g., amending the definition of “designated investment business” to include the cryptoasset regulated activities;
• the application of complaints handling and redress rules, ensuring consumers have clear routes to resolve issues – e.g., proposing that cryptoasset firms follow the Redress and Dispute Resolution sourcebook (including consumer access to the Financial Ombudsman Service);
• restricting the use of credit for crypto purchases to reduce harm from borrowing to invest;
• applying the Senior Managers and Certification Regime proportionately across cryptoasset firms and categorising such firms as “enhanced firms” under such regime;
• implementing cryptoasset safeguarding rules for firms holding client cryptoassets; and
• publishing location policy guidance for international cryptoasset firms. 

GC26/2

GC26/2 sets out the FCA’s proposed guidance on how the Consumer Duty will apply to cryptoasset firms. 

GC26/2 addresses how the Consumer Duty applies to different cryptoasset firms and business models, including manufacturers and distributors, UK Qualifying Cryptoasset Trading Platform Operators, and the Admissions and Disclosures regime for UK-issued qualifying stablecoins. 

GC26/2 outlines how cryptoasset firms should comply with:

• the consumer duty principle (i.e., Principle 12 of the Principles for Businesses);
• the three cross‑cutting rules (i.e., act in good faith towards retail customers, avoid causing foreseeable harm to retail customers, and enable and support retail customers to pursue their financial objectives); and
• the four outcomes relating to products and services, price and value, consumer understanding, and consumer support. 

Next steps

The comment periods for CP26/4 and GC26/2 close on 12 March 2026. 

The FCA intends to open its authorisation application gateway for firms to apply for cryptoasset permission on 30 September 2026, with the gateway remaining open until 28 February 2027. Firms that have not applied within that period may not be authorised by the FCA when the new rules come into force. The FCA also expects to publish policy statements setting out final rules and guidance later in 2026.

The FCA’s new cryptoasset regime is expected to come into force on 25 October 2027. Firms wishing to undertake any of the new cryptoasset regulated activities in the UK will need to be authorised by the FCA at that date, when the new regulatory regime commences.

CP26/4 and GC26/2 are available here and here, respectively. 

For further information on recent developments in this area, please see our previous articles on CP25/2 and the wider cryptoasset regulatory framework available here and here, respectively.