The UK’s Financial Conduct Authority (FCA) today published final rules for the regulation of cryptoassets and stablecoins, covering trading platforms, custody, disclosure and issuance. The UK’s crypto regime comes into force in October 2027 with applications opening on 30 September 2026. Alongside the FCA policy statements, the Bank of England and FCA jointly set out how they will share oversight of stablecoin issuers deemed systemically important.
The result is a two tier framework in which the FCA regulates all stablecoin issuers while the Bank sets stricter requirements for systemic ones, covering reserves, custody, failure arrangements and initial volume caps
Unlike some other jurisdictions, the UK does not have a clear hurdle for a stablecoin to be classified as systemic. Instead it is a judgment call made by HM Treasury based on input from the Bank and FCA. The decision is driven by whether deficiencies or disruption to the stablecoin issuer could undermine financial stability or have serious consequences to UK business or other interests. By contrast, the US GENIUS Act mandates federal oversight once an issuer exceeds $10 billion in outstanding issuance, and Europe’s MiCA has set of seven specific criteria, where a significant issuer matches at least three of them. Only three of those criteria are size related, including €5 billion issuance or 10 million users or daily transaction volumes above €500 million.
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