FCA Opens Consultations on DeFi Guidance and Cryptoasset Regulatory Perimeter

FCA Opens Consultations on DeFi Guidance and Cryptoasset Regulatory Perimeter

By: WEEX|10/23/2026 03:54:43

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These consultations matter less as immediate rule changes than as signals of how the FCA expects firms to classify activities ahead of key authorisation decisions. FCA-regulated firms using DeFi, as well as UK crypto businesses assessing whether new activities require authorisation, face near-term pressure to map their business models against existing controls and the emerging regulatory perimeter rather than wait for an entirely new DeFi rulebook.

The UK Financial Conduct Authority has opened two crypto-related consultations, identified in the supplied FCA excerpts as GC26/7 and CP26/36. They address separate issues: one examines how existing operational-resilience, financial-crime and anti-money-laundering obligations apply when regulated firms use DeFi, while the other considers how recent legislative changes affect the UK cryptoasset regulatory perimeter. Responses to both consultations are requested by 18 November 2026.

What the FCA’s DeFi consultation covers

The DeFi consultation is presented as guidance on how existing rules apply when regulated firms provide financial services using DeFi, rather than as a separate new DeFi regime. In the supplied FCA excerpt for GC26/7, the exercise is described as non-Handbook guidance intended to help firms comply with operational-resilience and financial-crime rules, as well as the Money Laundering Regulations.

This distinction matters for those asking whether the FCA is introducing new DeFi-specific obligations. Based on the available FCA wording, the exercise is interpretive: it addresses how current requirements apply to more automated, distributed-ledger-based service models. The same excerpt indicates that the consultation is primarily aimed at FCA-regulated firms providing financial services through DeFi, though it is also relevant to firms interacting with DeFi, advisers and industry bodies.

What the cryptoasset perimeter consultation is testing

CP26/36 concerns where UK crypto regulation begins and which activities may sit outside its scope through exclusions, rather than a broad debate on crypto policy. Supplied FCA excerpts describe it as guidance on how recent legislative changes affect the UK cryptoasset regulatory perimeter.

Those excerpts highlight specific boundary issues, including decentralisation, safeguarding exclusions, qualifying stablecoins, proprietary trading and market making, and technical service providers. They also refer to exclusions for temporary settlement arrangements and certain arrangements involving the holding of qualifying stablecoins and backing assets. Put simply, the consultation tests how firms should assess borderline cases when determining whether an activity requires authorisation.

Within the scope of the same consultation, the FCA says it aims to publish final guidance for CP26/36 in January 2027 after considering feedback.

ItemCurrent detail
DeFi consultationGC26/7, described in an FCA excerpt as non-Handbook guidance for firms providing financial services using DeFi.
Perimeter consultationCP26/36, covering how recent legislative changes affect the UK cryptoasset regulatory perimeter.
Response deadline18 November 2026 for both consultations, according to the supplied FCA excerpts.
DeFi guidance focusCompliance with operational-resilience, financial-crime and Money Laundering Regulations requirements in DeFi-related financial services.
Perimeter guidance topicsExclusions and interpretive issues involving decentralisation, safeguarding, qualifying stablecoins, proprietary trading and market making, and technical service providers.
Application-window linkageExisting UK cryptoasset businesses seeking to conduct new regulated activities are told the application window runs from 30 September 2026 to 28 February 2027.

Who may need to act before January 2027

The next formal deadline is 18 November 2026, when responses to both consultations are due. The perimeter consultation is directly relevant to firms preparing authorisation decisions. In the supplied CP26/36 excerpt, the FCA says the application period for existing UK cryptoasset businesses seeking to carry out new regulated cryptoasset activities opened on 30 September 2026 and closes on 28 February 2027. Firms seeking the savings provision must apply during that window.

This makes the perimeter guidance more than a technical paper. It affects how firms classify their business models and permissions while the application process remains open. Meanwhile, the DeFi consultation matters for firms already using DeFi or facilitating access to it as part of regulated activity, as it indicates how the FCA expects existing resilience, financial-crime and AML controls to operate in those settings.

One caveat remains important: the supplied evidence directly states a January 2027 target for final CP26/36 guidance, but the excerpts reviewed do not state the same timetable for GC26/7.

Milestones

2026/10/21
2026/11/18
FCA opens consultation on DeFi guidanceThe supplied FCA excerpt for GC26/7 lists 21 October 2026 as the opening date for the DeFi guidance consultation, marking the start of the current two-consultation process.
Response deadline for both consultationsThe supplied FCA excerpts state that comments on both GC26/7 and CP26/36 are requested by 18 November 2026, making this the next formal deadline for affected firms and industry groups.

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