FCA Final Crypto Rules & the UK Stablecoin Framework

Why is it relevant?

The FCA’s final rules represent a major shift in the UK’s approach to crypto regulation. Historically, many cryptoasset activities sat outside the full UK financial services regulatory perimeter, with FCA oversight mainly focused on AML registration and financial promotions.

The new regime brings crypto much closer to traditional financial services regulation. This means firms will need to demonstrate that they have the systems, controls, governance and financial resources expected of regulated financial services businesses.

For stablecoin firms, the changes are especially important. Stablecoins have the potential to play a meaningful role in payments and settlement, but confidence in the model depends on transparency, quality of backing assets, redemption rights, safeguarding and operational resilience.

Who does it affect?

The new requirements are expected to affect a broad range of cryptoasset firms operating in, or targeting, the UK market, including:

• Crypto trading platforms
• Cryptoasset intermediaries
• Crypto custodians
• Stablecoin issuers
• Firms arranging cryptoasset staking
• Overseas firms providing services to UK customers

What do you need to know?

Key themes at a glance:

A move to a fully regulated crypto framework – Crypto firms carrying out activities such as trading, intermediation, custody, stablecoin issuance and arranging staking will need FCA authorisation to operate in the UK.

Greater focus on financial resilience and governance – Firms will need to meet new financial resilience requirements, including capital and stress testing obligations, supported by effective governance and risk management arrangements.

Stablecoins moving into a more structured regime – Stablecoin issuers will be subject to clearer standards around backing assets, redemption arrangements, disclosures and operational controls.

Market integrity and consumer protection – The FCA is introducing rules covering areas such as insider trading, market manipulation and conduct standards, while applying established financial services principles where comparable risks exist.

Increased audit and assurance relevance – As the regime matures, firms will need to evidence robust controls, safeguarding arrangements, reconciliations, financial crime systems, operational resilience and governance frameworks.

Authorisation will be central to the new regime

Crypto firms will need FCA authorisation to operate in the UK. The application gateway will open on 30 September 2026 and close on 28 February 2027, ahead of the regime coming into force on 25 October 2027. Firms should not wait until the application window opens. Authorisation readiness, governance frameworks, policies, systems and control evidence will take time to develop.

Stablecoins will face clearer standards

The FCA has introduced specific rules for stablecoins, reflecting their potential role in payments and wider financial services. The focus will be on ensuring that stablecoins are supported by strong and transparent arrangements, including backing assets, redemption processes, disclosures and appropriate controls.

Financial resilience and stress testing

Firms in scope will need to meet financial resilience expectations, including capital requirements and stress testing. This is a significant step towards treating cryptoasset firms more like other regulated financial services businesses.

Custody and safeguarding

Crypto custodians will need to pay close attention to safeguarding arrangements, private key controls, ownership records, reconciliations and operational resilience. This is likely to be one of the most important areas from an audit and assurance perspective, as firms will need to evidence that client assets are properly protected and that records are accurate, complete and accessible.

What should you do next?

Crypto and stablecoin firms should begin preparing now by:

• Assessing whether their activities fall within the new UK regulatory perimeter;
• Performing a gap analysis against the FCA’s final rules;
• Reviewing governance and senior management accountability;
• Assessing capital, liquidity and stress testing arrangements;
• Mapping key custody, safeguarding and reconciliation controls;
• Reviewing stablecoin backing asset and redemption processes;
• Testing financial crime and market abuse control frameworks;
• Assessing operational resilience and third-party dependencies;
• Preparing early for the FCA authorisation process

Contact us

If you would like to discuss this in further detail, please get in touch with your usual Blick Rothenberg contact or Artur Vorobyev.