FCA Consults on UK Cryptoasset Perimeter Guidance in April 2026

The Financial Conduct Authority (FCA) published Consultation Paper CP26/13 on 16 April 2026, proposing draft perimeter guidance for the United Kingdom's forthcoming cryptoasset regulatory regime. The consultation is open for responses until 3 June 2026 and is at the proposed-guidance stage; the FCA intends to publish final perimeter guidance in autumn 2026, with final policy statements expected in summer 2026.

The controlling authority is the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, SI 2026/102, which Parliament made in February 2026. That instrument extended the Financial Services and Markets Act 2000 to bring seven new regulated cryptoasset activities within the FCA's regulatory perimeter. CP26/13 proposes guidance on the scope of those activities, covering: issuing qualifying stablecoins in the UK; safeguarding or arranging safeguarding of qualifying cryptoassets and relevant specified investment cryptoassets; operating a qualifying cryptoasset trading platform; dealing in qualifying cryptoassets as principal; dealing in qualifying cryptoassets as agent; arranging deals in qualifying cryptoassets; and arranging qualifying cryptoasset staking.

Firms carrying on any of the above activities without authorisation after the regime comes into force on 25 October 2027 will commit a criminal offence under section 19 FSMA 2000. Cryptoasset businesses operating in the UK or providing services to UK consumers, stablecoin issuers, traditional finance firms entering digital-asset markets, DeFi protocols and Web3 wallet providers whose interfaces could constitute "arranging," and professional advisers acting in cryptoasset transactions all need to assess whether their activities fall within one or more of the seven regulated categories before the application window opens on 30 September 2026.

The FCA's proposed guidance addresses a persistent open question: whether certain DeFi interfaces and non-custodial wallet applications constitute "arranging deals in qualifying cryptoassets." CP26/13 flags that the perimeter for arranging may reach further than market participants assumed, placing onerous authorisation obligations on actors who facilitate transactions without directly holding client assets. Firms engaged in staking-arrangement services face particular uncertainty, as the guidance for that activity is still developing. The FCA also notes that pre-application support opens on 1 July 2026, giving firms a defined window to test their regulatory status before the formal application period.

Prokopiev Law Group advises on cryptoasset regulatory compliance, FCA authorisation strategy, and multi-jurisdictional digital-asset structuring; our dedicated partner network spans crypto-native counsel and regulatory specialists across the UK and EU. We welcome enquiries from exchanges, custodians, stablecoin issuers, DeFi developers, and Web3 infrastructure providers. Our work includes: cryptoasset regulatory analysis, FCA authorisation applications, stablecoin legal frameworks, DeFi perimeter assessment, crypto custody compliance, qualifying cryptoasset classification, FSMA regulated-activities mapping.

Source: Financial Conduct Authority, CP26/13: Cryptoasset perimeter guidance (16 April 2026), https://www.fca.org.uk/publications/consultation-papers/cp26-13-cryptoasset-perimeter-guidance. Confirmed 28 April 2026.

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