FCA Consults on Prudential Regime for UK Cryptoasset Firms Under CP25/15, 2025

The Financial Conduct Authority (FCA) published Consultation Paper CP25/15, "A prudential regime for cryptoasset firms," in 2025. The consultation proposed a bespoke capital and liquidity regime for FCA-authorised cryptoasset businesses operating in the United Kingdom. The FCA issued the consultation under powers conferred by the Financial Services and Markets Act 2000 (FSMA 2000), as amended by the Financial Services and Markets Act 2023 (FSMA 2023), which created the UK cryptoasset regulatory perimeter. The consultation closed in July 2025; the FCA has not yet published final rules as of 9 March 2026.

CP25/15 proposed that cryptoasset firms holding an FCA authorisation under the FSMA 2000 cryptoasset registration regime should be subject to minimum own funds requirements, including a fixed overhead requirement and a K-factor-based formula adapted from the Investment Firms Prudential Regime (IFPR) established by the Financial Services Act 2021 and the UK Investment Firm Prudential Regime rules in the FCA Handbook (MIFIDPRU). The paper also proposed liquidity requirements calibrated to the specific risk profile of cryptoasset business models, including requirements to hold adequate liquid assets against client money and assets held in custody. The proposed rules would apply to firms registered under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 that receive full FCA authorisation under the new UK cryptoasset regulatory perimeter.

UK-based cryptoasset exchanges, custodians, and cryptoasset issuers that seek or hold FCA authorisation must assess their anticipated capital base against the proposed minimum requirements. Firms currently registered with the FCA under the anti-money laundering registration regime that plan to apply for full authorisation under the FSMA 2023 cryptoasset perimeter should begin modelling their capital and liquidity positions against the CP25/15 proposals. Consumer-facing and institutional cryptoasset businesses must also assess client asset segregation obligations and reporting requirements proposed under CP25/15, which aligned the client money treatment with the FCA's existing Client Assets Sourcebook (CASS).

The consultation period closed in July 2025. The FCA has not published a Policy Statement setting out final rules as of 9 March 2026. Until the FCA publishes final rules, the CP25/15 proposals remain proposals only and do not impose binding obligations. The FCA indicated in CP25/15 that transitional provisions would apply to give firms adequate time to meet the new requirements once final rules take effect; no transitional period length had been confirmed as of the consultation stage.

Source: Financial Conduct Authority (FCA), Consultation Paper CP25/15 "A prudential regime for cryptoasset firms," available at https://www.fca.org.uk/publications/consultation-papers/cp25-15-prudential-regime-cryptoasset-firms. Consultation closed July 2025. Confirmed 9 March 2026.

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.