Both consultations are open until Nov. 18, 2026, giving firms and other interested parties four weeks to respond.
The DeFi consultation proposes non-handbook guidance for FCA-regulated firms that use decentralized finance. It addresses operational resilience, financial-crime risks and obligations under the UK Money Laundering Regulations, while offering examples of measures firms may consider. The guidance applies to firms within the FCA’s operational-resilience and financial-crime systems, as well as businesses subject to the Money Laundering Regulations, and may also interest unauthorised firms that interact with DeFi protocols.
It says DeFi’s automated, open and interoperable structure, sometimes without a traditional intermediary, can create additional operational and financial-crime risks for firms and their clients. The FCA plans to consider responses and publish final DeFi guidance in January 2027.
The second consultation, CP26/36, explains how draft legislative changes could remove certain activities from regulated cryptoasset activities. Potential exclusions include temporary settlement arrangements, temporary UK qualifying-stablecoin holding arrangements for payment transactions, arrangements involving assets backing a qualifying stablecoin, some proprietary trading and market-making activity, and technical services that merely provide access to a third-party service or decentralized protocol. The proposal is intended to help firms determine whether their business models require authorization under the new perimeter.
The consultations arrive as the FCA’s wider cryptoasset regime moves toward implementation. Applications opened on Sept. 30, 2026, and firms seeking to continue operating under the new framework are expected to apply by Feb. The regime is scheduled to take effect on Oct. 25, 2027, when firms carrying out regulated cryptoasset activities will need FCA authorization or an approved variation of existing permission.
The regulator says authorization will not be automatic. Applications will be assessed against standards covering consumer protection, safeguarding of customer assets, market integrity and financial resilience, while existing firms that apply during the application window may continue providing services during assessment if transitional conditions are met. An industry body welcomed the consultations but urged the FCA to keep the perimeter clear and expectations proportionate so that responsible DeFi activity can develop in the UK.
