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  • Luxembourg CSSF Updates Crypto-Asset FAQ for Retail Funds, February 2026

    On February 4, 2026, the Commission de Surveillance du Secteur Financier (CSSF) of Luxembourg published Version 7 of its FAQ Crypto-Assets — Undertakings for Collective Investment, updating guidance that was first published in November 2021 under the title FAQ Virtual Assets — Undertakings for Collective Investment. The FAQ update is a supervisory guidance document; it does not constitute binding regulation but reflects the CSSF's current supervisory expectations and the application of existing legal requirements to crypto-asset exposures held by Luxembourg-domiciled investment funds, including UCITS. The controlling legal authority for Luxembourg-domiciled UCITS is the Law of 17 December 2010 relating to undertakings for collective investment, as amended, and the underlying EU UCITS Directive 2009/65/EC. The CSSF FAQ interprets these provisions in the context of crypto-asset exposures, including direct and indirect holdings in crypto-assets as defined under Regulation (EU) 2023/1114 (MiCA). The CSSF renamed the FAQ from "virtual assets" to "crypto-assets" to align with MiCA terminology, which entered into application across the EU in stages through 2024 and 2025. Luxembourg-domiciled UCITS fund managers, alternative investment fund managers (AIFMs) supervised by the CSSF, and Part II UCIs holding or contemplating exposure to crypto-assets must review the updated FAQ to determine whether their current risk management processes, prospectus disclosures, and investment restrictions comply with the CSSF's updated supervisory expectations. Swiss funds wishing to gain similar crypto-asset exposure operate under a distinct national legal framework and must apply to their own competent authority; the CSSF FAQ does not apply to them directly. The FAQ is non-binding and represents only the CSSF's current supervisory position, which may change as MiCA implementation progresses and as ESMA publishes further guidance on crypto-asset classification. Fund managers should confirm that their service providers, including depositary banks and custodians, have the operational capability to hold crypto-assets before making any changes to investment mandates. Source: CSSF FAQ Crypto-Assets — Undertakings for Collective Investment, Version 7, published February 4, 2026 (originally published November 29, 2021). Official URL: https://www.cssf.lu/en/document/faq-crypto-assets-undertakings-for-collective-investment/ — Confirmed March 12, 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.

  • OCC Issues NPRM to Implement GENIUS Act Stablecoin Standards, March 2026

    On March 2, 2026, the Office of the Comptroller of the Currency (OCC) published a Notice of Proposed Rulemaking (NPRM) in the Federal Register (document number 2026-04089) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) regarding the issuance of payment stablecoins and related activities by entities subject to the OCC's jurisdiction. The rule is at the proposed stage and subject to public comment before any final action. The GENIUS Act, enacted into law prior to the publication of this NPRM, directs the OCC to establish federal standards for the issuance and oversight of payment stablecoins by national banks and other OCC-supervised entities. The proposed rule operationalizes this statutory mandate by setting out requirements governing reserve assets, redemption rights, disclosures, and risk management for payment stablecoin issuers. The OCC acts as the primary federal supervisor for national banks and federal savings associations under 12 U.S.C. Chapter 1. National banks, federal savings associations, and federal branches of foreign banks that issue or plan to issue payment stablecoins must assess their current practices against the proposed standards. Issuers will face requirements to maintain high-quality, liquid reserve assets backing outstanding stablecoin balances, provide holders with clear redemption rights, and implement robust internal controls. Non-bank stablecoin issuers not chartered under the National Bank Act fall outside the OCC's direct jurisdiction and are not covered by this proposed rule. The proposed rule is subject to a public comment period. Interested parties should monitor the Federal Register for the official comment deadline. The OCC may revise the proposed standards materially before issuing a final rule. Questions remain open regarding the treatment of stablecoins issued by state-chartered institutions, the interplay with Federal Reserve and FDIC oversight, and whether Congress will enact companion legislation applicable to non-bank issuers. Source: Federal Register, "Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency," document 2026-04089, published March 2, 2026. Official URL: https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the — Confirmed March 12, 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.

  • IRS Proposes Rules for Electronic 1099-DA Delivery by Digital Asset Brokers, March 2026

    On March 5, 2026, the U.S. Department of the Treasury and the Internal Revenue Service issued proposed regulations (IR-2026-29) establishing an alternative, optional process for digital asset brokers to furnish Form 1099-DA statements to customers electronically, without first offering paper delivery. The proposed regulations are at the notice-and-comment stage and carry no immediate compliance obligations. The authority for the proposed rules derives from the Infrastructure Investment and Jobs Act of 2021, which amended the Internal Revenue Code to treat digital asset intermediaries as brokers required to file information returns and furnish payee statements. Under existing Treasury Regulation Section 31.6051-1 and the electronic-furnishing rules of Section 1.6050W-2, a broker must obtain affirmative consent before substituting electronic delivery for paper. The proposed regulations would create a separate pathway under which brokers meeting enhanced notice-and-access requirements need not offer paper at all and need not preserve the right to withdraw consent. Digital asset brokers — including centralized cryptocurrency exchanges, custodial wallet providers, and certain DeFi platforms classified as brokers under the 2021 amendments — face Form 1099-DA reporting obligations for transactions occurring on or after January 1, 2025. Under the proposed rules, a qualifying broker may deliver 1099-DA statements solely in electronic form for statements required on or after January 1, 2027. The broker must notify each customer that an important tax document has been furnished electronically, provide continuous access to that document, and meet specified format and delivery-confirmation standards. The IRS also issued Notice 2026-4 alongside the proposed regulations, seeking public comment on extending analogous electronic-furnishing relief to Form 1099-B and other payee statements. The comment period closes sixty days after Federal Register publication. Brokers that do not use the new optional process may continue to rely on existing consent-based electronic-furnishing procedures or deliver paper statements. Source: IR-2026-29, Internal Revenue Service, "Treasury, IRS issue proposed regulations to make it easier for digital asset brokers to provide 1099-DA statements electronically" (March 5, 2026); Federal Register, "Electronic Furnishing of Payee Statements Regarding Digital Asset Sales by Brokers," published March 6, 2026. Official URL: https://www.irs.gov/newsroom/treasury-irs-issue-proposed-regulations-to-make-it-easier-for-digital-asset-brokers-to-provide-1099-da-statements-electronically — Confirmed March 12, 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.

  • Central Bank of Ireland Launches DLT and Tokenisation Discussion Paper, March 2026

    On 5 March 2026, the Central Bank of Ireland (CBI) published Discussion Paper 12 (DP12) on Distributed Ledger Technology (DLT) and Tokenisation in Financial Services. The paper is at the consultation stage; the CBI invites written submissions via an online form, with responses due by 5 June 2026. The paper does not impose obligations on regulated entities but signals the CBI's supervisory priorities as MiCA implementation deepens across the EU and as Irish-authorised fund managers and payment firms begin deploying tokenised products. The paper is issued under the CBI's general supervisory mandate and its role as national competent authority under Regulation (EU) 2023/1114 (MiCA) and the EU DLT Pilot Regime (Regulation (EU) 2022/858). DP12 poses questions in three areas: (1) how DLT can transform the underlying infrastructure of finance and create new financial services; (2) the opportunities, challenges, enablers, and risks of these technologies; and (3) how tokenisation interacts with existing financial infrastructure, intermediaries, legal frameworks, forms of money, settlement, and market practices. Crypto exchanges, tokenised asset platforms, custodians, fund administrators, and payment service providers authorised or registered in Ireland — or planning to passport services into Ireland under MiCA — should respond to DP12. The paper directly signals areas where the CBI intends to develop supervisory expectations, particularly on consumer protection, monetary stability, and market integrity. Entities already operating under the EU DLT Pilot Regime should pay close attention to questions on settlement infrastructure. The consultation closes 5 June 2026. The CBI stated it will use responses to inform future supervisory guidance and feed into European-level discussions at the EBA, ESMA, and ECB. Entities seeking to establish tokenisation programmes or issue digital representations of assets to Irish retail clients should treat DP12 as an early indicator of incoming supervisory expectations. No transitional provisions apply at this stage because DP12 is a consultation document, not a binding instrument. Source: Central Bank of Ireland, Discussion Paper 12 — Distributed Ledger Technology (DLT) & Tokenisation in Financial Services (DP12), published 5 March 2026, closing date 5 June 2026. Official URL: https://www.centralbank.ie/publication/discussion-papers/discussion-paper-detail/discussion-paper-12-dlt-tokenisation-in-financial-services . Confirmed 11 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.

  • Council of Europe Ministers Discuss Crypto-Asset Regulation and Democratic Risks, February 2026

    On 23 February 2026, the Ministers' Deputies of the Council of Europe held an informal meeting to address the regulatory, compliance, and security challenges posed by the rapid expansion of crypto-assets and decentralised digital finance. The meeting examined how crypto-assets are misused for illicit activities — including sabotage, unlawful political financing, terrorism, and money laundering — and how they enable covert financing of foreign operations that threaten European democratic institutions. The meeting is a non-binding deliberative event; it does not produce legislation or binding Council of Europe decisions. The meeting was chaired by Ambassador Daniela Cujbă, President of the Ministers' Deputies, and held under the Council of Europe's broader Roadmap towards a New Democratic Pact for Europe. The Council of Europe's relevant instruments in this space include the Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism (Warsaw Convention) and the work of MONEYVAL, the Council of Europe's AML/CFT monitoring body. The Directorate General of Human Rights and Rule of Law (DGI) presented a scene-setting contribution on the Council of Europe's existing tools for addressing crypto-related crime. The meeting carries direct implications for crypto-asset service providers, exchanges, wallet providers, and DeFi protocols with users in Council of Europe member states. The discussions specifically addressed whether existing regulatory regimes — including the EU's Markets in Crypto-Assets Regulation (MiCA) — are sufficient to counter crypto-enabled illicit finance and foreign interference. MONEYVAL, which monitors member states' compliance with FATF standards, was identified as a key existing tool. The meeting's outcome may influence Council of Europe guidance to its 46 member states on tightening AML/CFT supervision of crypto-asset service providers and updating national frameworks to address crypto-enabled foreign interference. Source: Council of Europe, Committee of Ministers, "Crypto: regulations, compliance and measures for digital assets — combating crime and foreign interference," Informal Meeting of the Ministers' Deputies, 23 February 2026. Official URL: https://www.coe.int/en/web/cm/-/crypto-regulations-compliance-and-measures-for-digital-assets-combating-crime-and-foreign-interference . Confirmed 11 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.

  • UK House of Lords Launches Stablecoin Inquiry, February 2026

    The House of Lords Financial Services Regulation Committee opened an inquiry into the growth and proposed regulation of stablecoins in the United Kingdom in early 2026. The inquiry is at the evidence-gathering stage. The Committee took oral evidence from Bank of England Deputy Governor Sarah Breeden and Executive Director Sasha Mills on 11 March 2026, and from industry representatives on earlier dates in February 2026. The Committee invited written submissions until 11 March 2026. The inquiry operates under the authority of the House of Lords Financial Services Regulation Committee. The Committee's mandate derives from its standing terms of reference to scrutinise financial regulation policy in the United Kingdom. The inquiry does not cite a single controlling statute because the UK's stablecoin regulatory regime is still under construction: the Financial Services and Markets Act 2023 granted HM Treasury powers to bring stablecoins within the regulatory perimeter, and the FCA is developing implementing rules through separate consultation papers. The Committee's call for evidence asked respondents to address questions including market structure, consumer protection, systemic risk, and the adequacy of the proposed regulatory regime. Stablecoin issuers, payment system operators, custodians, and crypto-asset exchanges operating or seeking to operate in the UK market are the entities most directly affected by the inquiry's potential recommendations. The Committee's report, once published, may inform HM Treasury's stablecoin policy and the FCA's final rules. Coinbase, Innovate Finance, Global Digital Finance, UK Finance, Chainalysis, and two academic experts gave oral evidence across earlier sessions. The Bank of England's participation on 11 March 2026 indicates that the inquiry will examine systemic and monetary policy dimensions of stablecoin adoption, including the treatment of stablecoin deposits relative to central bank money. The inquiry is ongoing; no report or recommendations have been published yet. Oral evidence sessions continue, with the next session scheduled for 18 March 2026. The Committee's findings will be non-binding recommendations to the UK government; implementation would require separate action by HM Treasury or the FCA. The FCA's stablecoin authorisation regime is expected to go live in 2026 under powers in the Financial Services and Markets Act 2023. Source: House of Lords Financial Services Regulation Committee, Inquiry: "Growth and proposed regulation of stablecoins in the UK," opened February 2026, evidence session 11 March 2026. Official URL: https://committees.parliament.uk/work/9590/growth-and-proposed-regulation-of-stablecoins-in-the-uk . Confirmed 11 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.

  • Central Bank of Ireland Publishes Discussion Paper on DLT and Tokenisation, March 2026

    On 5 March 2026, the Central Bank of Ireland (CBI) published Discussion Paper 12 (DP12), titled "Distributed Ledger Technology (DLT) & Tokenisation in Financial Services." The paper is at the consultation stage: the CBI invites written submissions from market participants, technology providers, academics, and policymakers until 5 June 2026. The CBI will publish a feedback statement after the consultation period closes. No rule changes take effect at this stage. DP12 sits within the CBI's broader Innovation Hub engagement programme and is issued under the CBI's general supervisory mandate. It operates across multiple existing EU instruments: Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), the DLT Pilot Regime under Regulation (EU) 2022/858, the Markets in Financial Instruments Directive II (MiFID II), and the Payment Services Directive 2 (PSD2). The paper examines how DLT and tokenisation interact with each of these instruments at their current boundaries and asks respondents to identify where those boundaries create friction. DP12 covers four thematic areas: tokenisation in capital markets and securities settlement, tokenisation in investment funds, forms of tokenised money and payments infrastructure, and the enabling conditions for adoption (legal clarity, operational resilience, scalability, and interoperability). Token issuers operating under MiCA authorisation, trading venues that have applied for or obtained a DLT Pilot Regime licence, investment fund managers exploring tokenised fund units, and payment institutions evaluating stablecoin integration are the primary addressees of the CBI's questions. The paper also covers central bank money in a tokenised environment, which carries implications for participants in wholesale settlement and collateral management. DP12 imposes no obligations and creates no safe harbours. Submissions must be made exclusively through the CBI's online form; the CBI will not accept responses by other means. The consultation deadline is 5 June 2026. The paper forms part of the EU's broader Savings and Investment Union agenda and the CBI's feedback statement may inform future legislative proposals at both the Irish and EU level. No transitional provisions or carve-outs apply at this stage. Source: Central Bank of Ireland, Discussion Paper 12 — Distributed Ledger Technology (DLT) & Tokenisation in Financial Services, DP12, published 5 March 2026, consultation closing 5 June 2026. Official URL: https://www.centralbank.ie/publication/discussion-papers/discussion-paper-detail/discussion-paper-12-dlt-tokenisation-in-financial-services . Press release: https://www.centralbank.ie/news/article/press-release-discussion-paper-tokenisation-and-distributed-ledger-technology-in-financial-services-5-march-26 . Confirmed 11 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.

  • UK ICO Fines Reddit £14.47 Million for Children's Privacy Failures, February 2026

    The UK Information Commissioner's Office issued a monetary penalty notice against Reddit, Inc. on 24 February 2026, imposing a fine of £14,470,000 under the UK General Data Protection Regulation and the Data Protection Act 2018. The ICO found that Reddit had processed personal data of children under the age of 13 without a lawful basis and had failed to conduct a Data Protection Impact Assessment before January 2025, when Reddit began operating an age assurance mechanism on its platform. The enforcement action rests on Article 5(1)(a) of UK GDPR, which requires personal data to be processed lawfully, fairly, and transparently, and on Article 6, which sets out the exhaustive list of lawful bases for processing. The ICO determined that Reddit lacked a valid lawful basis under Article 6 for the personal data it collected from users who were or appeared to be under 13. The penalty notice also invokes Article 35 of UK GDPR, which requires a DPIA before processing that is likely to result in high risk to individuals, including children. Reddit did not complete a DPIA covering its UK operations until January 2025. The ICO's enforcement applies the Children's Code (Age Appropriate Design Code), issued under section 123 of the Data Protection Act 2018, which sets 15 standards that online services likely to be accessed by children must meet. Reddit's failure to deploy age assurance before July 2025 meant that children could access the platform and have their data processed without the protections the Children's Code requires. Operators of online platforms, social media services, and user-generated-content sites accessible to UK users must maintain a DPIA, implement age assurance proportionate to the risk, and identify a lawful basis before collecting data from users who may be under 13. Reddit introduced age assurance in July 2025 and has been cooperating with the ICO's review. The ICO confirmed it continues to review Reddit's compliance practices. The fine will be paid into the UK Consolidated Fund in accordance with section 157 of the Data Protection Act 2018. Reddit retains the right to appeal the penalty notice to the First-tier Tribunal (Information Rights). Source: Information Commissioner's Office, "Reddit issued with £14.47m fine for children's privacy failures," ICO Media Centre, 24 February 2026, available at: https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2026/02/reddit-issued-with-1447m-fine-for-children-s-privacy-failures/ ; UK General Data Protection Regulation, Articles 5(1)(a), 6, and 35; Data Protection Act 2018, sections 123 and 157. Verified 10 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.

  • EU Digital Omnibus Proposes to Simplify AI Act Implementation Timeline, November 2025

    On 19 November 2025, the European Commission adopted the Digital Omnibus legislative package, which includes proposed amendments to Regulation (EU) 2024/1689 (the AI Act). The legislative proposal is at the European Parliament and Council negotiation stage. The Commission adopted the package to simplify the AI Act's implementation and preserve its innovation-friendly character while maintaining its risk-based architecture. The AI Act entered into force on 1 August 2024 under Regulation (EU) 2024/1689, with the bulk of its obligations applying two years later on 2 August 2026. Within the existing AI Act structure, prohibited AI practices and AI literacy obligations applied from 2 February 2025, governance and GPAI model rules applied from 2 August 2025, and high-risk AI rules embedded in regulated products carry an extended transition period until 2 August 2027. The Digital Omnibus proposal, adopted by the Commission under its right of legislative initiative, proposes to adjust the timeline for the application of high-risk AI rules to a maximum of 16 months from the date when relevant harmonised standards become available, rather than applying them on a fixed date. Beyond the timeline adjustment, the Digital Omnibus proposes five categories of targeted amendments: reinforcing the AI Office's powers and centralising oversight of AI systems built on GPAI models; extending simplified technical documentation requirements currently available to SMEs and startups (SMCs) to a broader class of operators; requiring the Commission and Member States to promote AI literacy while maintaining training obligations for high-risk AI deployers; broadening access to regulatory sandboxes from 2028 and extending real-world testing provisions; and adjusting the AI Act's procedures to clarify its interplay with sector-specific laws. AI providers, deployers, and importers operating GPAI models or high-risk AI systems in the EU should monitor the co-legislative process between the European Parliament and the Council, as the Omnibus amendments, if adopted, will modify their compliance timelines and documentation obligations. The Digital Omnibus proposal does not alter the existing compliance obligations that are already in force under the AI Act. Prohibited practices banned from 2 February 2025 and GPAI model obligations that applied from 2 August 2025 remain in effect. The Omnibus has not yet been formally adopted by the co-legislators; until the European Parliament and Council reach a political agreement and the final text is published in the Official Journal, the current AI Act deadlines continue to apply. Source: European Commission, "AI Act" page, digital-strategy.ec.europa.eu , updated 27 January 2026, available at: https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai (confirming Digital Omnibus adoption on 19 November 2025 and application timelines); Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence (Artificial Intelligence Act), OJ L, 2024/1689, 12 July 2024. Verified 10 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.

  • FCA Selects Four Firms to Test Stablecoin Services in Regulatory Sandbox, February 2026

    On 25 February 2026, the Financial Conduct Authority (FCA) announced the selection of four firms — Monee Financial Technologies, ReStabilise, Revolut, and VVTX — to participate in a dedicated stablecoin cohort of its Regulatory Sandbox programme. The action is at the testing stage; it does not constitute authorisation or approval of any stablecoin product. Testing began in Q1 2026, and findings will inform the FCA's final stablecoin policy rules, which the FCA expects to publish later in 2026. The FCA operates the Regulatory Sandbox under its innovation mandate derived from the Financial Services and Markets Act 2000 (FSMA 2000), Section 3D (as amended), which requires the FCA to have regard to the desirability of promoting innovation in financial services. The sandbox programme allows firms to test products in real-world conditions with regulatory safeguards applied. The stablecoin cohort complements the Digital Securities Sandbox (DSS), a joint FCA-Bank of England initiative running in parallel to test tokenised securities infrastructure. The FCA's final stablecoin rules will be set out in the Policy Statement following Consultation Paper CP25/14, which covers stablecoin issuance and cryptoasset custody. The four selected firms' stablecoin proposals cover a range of use cases: payments, wholesale settlement, and crypto trading. Each firm receives feedback from FCA specialists during testing. The FCA received 20 applications for the stablecoin cohort. Stablecoin issuers and firms developing payment infrastructure using stablecoins should monitor the sandbox findings; the results will directly shape the final UK stablecoin issuance rules expected in summer 2026, ahead of the new cryptoasset regime going live in October 2027. Firms not selected for the sandbox may still seek pre-application support from the FCA prior to the authorisation gateway opening in September 2026. The FCA noted that UK issuers of stablecoins will not pass interest from their own backing assets to holders. The FCA is still considering how further financial incentives could be shared with holders when UK-issued stablecoins are used in transactions. This constraint distinguishes UK-issued stablecoins from some overseas models and has direct implications for yield-bearing stablecoin designs targeting UK users. Source: Financial Conduct Authority, Press Release, "FCA selects 4 firms to test stablecoin innovation in its Regulatory Sandbox," 25 February 2026, available at: https://www.fca.org.uk/news/press-releases/4-firms-selected-test-stablecoin-regulatory-sandbox . Verified 10 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.

  • FCA Consults on Applying Handbook Rules to Cryptoasset Firms Under CP26/4, January 2026

    On 23 January 2026, the Financial Conduct Authority (FCA) published Consultation Paper CP26/4, "Application of FCA Handbook for Regulated Cryptoasset Activities – Part 2." The consultation is open; comments are due by 12 March 2026. CP26/4 is a proposed, not final, rule set. The FCA plans to open its authorisation gateway for cryptoasset firms in September 2026, with the new cryptoasset regime going live in October 2027. The FCA published CP26/4 under the 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. CP26/4 is the second part of the FCA's Handbook application series, building on CP25/25 (Part 1, published in 2025). It cross-references the UK cryptoasset statutory instrument laid by HM Treasury, which defines the regulated cryptoasset activities subject to FCA authorisation. CP26/4 sets out proposed requirements across ten subject areas for firms planning to hold FCA cryptoasset authorisation: Consumer Duty (including companion guidance paper GC26/2); Redress and Dispute Resolution (DISP); Conduct of Business Standards (COBS); Credit for Crypto Purchases; Training and Competence; Senior Managers and Certification Regime (SM&CR); Regulatory Reporting (SUP 16); Cryptoasset Safeguarding; Retail Collateral Treatment in Cryptoasset Borrowing; and Location Policy Guidance. Cryptoasset exchanges, custodians, stablecoin issuers, crypto lending platforms, and intermediaries seeking FCA authorisation from September 2026 must assess whether their existing compliance programmes satisfy each of those proposed standards before the authorisation gateway opens. CP26/4 does not constitute final rules; the FCA will publish a Policy Statement after the consultation closes. The FCA stated it will publish all Policy Statements for the cryptoasset consultations substantively in summer 2026. CP26/4 reflects feedback from earlier consultations including CP25/14 (stablecoin and custody), CP25/15 (prudential Part 1), and CP25/25 (Handbook Part 1). Firms responding to CP26/4 may submit comments via the FCA online form or by email to cp26-4@fca.org.uk by 12 March 2026. Source: Financial Conduct Authority, CP26/4: "Application of FCA Handbook for Regulated Cryptoasset Activities – Part 2," 23 January 2026, available at: https://www.fca.org.uk/publications/consultation-papers/cp26-4-application-handbook-regulated-cryptoasset-activities-II ; FCA Cryptoassets information page confirmed at: https://www.fca.org.uk/firms/cryptoassets-information . Verified 10 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 oown 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.

  • Central Bank of Ireland Launches DLT and Tokenisation Discussion Paper, March 2026

    On 5 March 2026, the Central Bank of Ireland published Discussion Paper 12 (DP12), titled "Distributed Ledger Technology and Tokenisation in Financial Services." The paper is at the consultation stage; it does not constitute proposed rulemaking and carries no binding legal effect. The Central Bank invites written submissions by 5 June 2026, after which it will publish a feedback statement. The Central Bank issued DP12 under its mandate to maintain monetary and financial stability and to ensure the financial system operates in the best interests of consumers, as set out in the Central Bank Act 1942 (as amended). The paper uses the discussion paper mechanism to solicit public input before any formal regulatory or legislative proposal is developed. The Central Bank has aligned DP12 with the EU Savings and Investment Union agenda, within which DLT and tokenisation serve a stated policy function. DP12 addresses four subject areas relevant to crypto and Web3 market participants. It examines DLT's potential to transform financial infrastructure and enable new financial services products. It assesses opportunities, challenges, and risks from tokenisation, including legal and regulatory clarity, operational resilience, scalability, and interoperability. It also examines how DLT and tokenisation interact with existing financial intermediaries — investment funds, payment systems, and securities settlement — and asks whether those innovations deliver efficiency, transparency, and accessibility for users. Issuers of tokenised securities, DeFi protocol operators, custodians, and fund administrators operating in or targeting Irish or EU markets should treat DP12 as an early indicator of supervisory priorities and respond before 5 June 2026. DP12 raises open questions rather than prescribing outcomes. The Central Bank has not proposed specific rules, set authorisation requirements, or committed to a timeline for formal rulemaking. The Central Bank's Deputy Governor stated that central bank money must remain at the heart of any future tokenised financial system, signalling a supervisory preference likely to influence future rulemaking on settlement assets and stablecoin design within the Irish and EU perimeter. The feedback statement following the consultation period will indicate whether the Central Bank proceeds to formal rulemaking or further policy development. Source: Central Bank of Ireland, Press Release, "Central Bank of Ireland Launches Discussion Paper on Tokenisation and Distributed Ledger Technology in Financial Services," 5 March 2026, available at: https://www.centralbank.ie/news/article/press-release-discussion-paper-tokenisation-and-distributed-ledger-technology-in-financial-services-5-march-26 ; Discussion Paper 12 (DP12), available at: https://www.centralbank.ie/docs/default-source/publications/discussion-papers/discussion-paper-12/dp12-dlt-tokenisation-in-financial-services.pdf . Verified 10 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.

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