The FCA recently published their CP26/13 Consultation Paper setting out the upcoming cryptoasset regulatory framework coming into effect from October 2027. The paper proposes the definition of qualifying cryptoassets as well as outlining regulated activities - from issuing stablecoins and safeguarding assets, to trading, dealing and staking arrangements.
The FCA has released its latest Consultation Paper (CP) on Perimeter Guidance (PERG) for cryptoassets. This is the first CP relating to the upcoming cryptoasset regime to be released since January. The cryptoasset regulations will come into force on 25th October 2027, with firms encouraged to apply for relevant permissions between 30th September 2026 and 28th February 2027.
CP26/13 proposes the scope of regulated activities. This is of key importance for firms that need to decide whether they need to apply for Part 4A permissions.
Qualifying Cryptoassets and Stablecoins
CP26/13 proposes to define a qualifying crypto asset as a type of cryptoasset that is fungible and transferable cryptographically, and must function as more than a mere record of value or rights, i.e., a stablecoin maintains a stable value by referencing one or more fiat currencies.
The following assets are excluded from the definition of a qualifying cryptoasset: electronic money, fiat currency, central bank digital currencies and cryptoassets that can only be redeemed with the issuer or used within a limited network.
Regulated Activities
The proposed regulated activities are:
Issuing qualifying stablecoins in the UK
A person, established in the UK, carrying on or arranging for another to: offer a stablecoin, undertake to redeem a stablecoin, and maintain the value of the stablecoin.
Safeguarding and arranging the safeguarding of qualifying cryptoassets and relevant specified investment cryptoassets
The safeguarding of a qualifying cryptoasset or a relevant specified investment cryptoasset on behalf of another person or arranging for a person to carry on that activity. Safeguarding cryptoassets may be carried on regardless of whether the cryptoasset is owned by the customer or the firm, provided it is done on behalf of another person and the firm has the requisite degree of control over the cryptoasset.
Operating a qualifying cryptoasset trading platform
Operating a trading system that brings multiple third-party buying and selling interactions together to result in a contract for the exchange of a qualifying cryptoasset for money (including e-money) or other qualifying crypto assets.
Dealing in qualifying cryptoassets as principal
Dealing in qualifying cryptoassets as principal covers a broad range of transactions relating to buying and selling qualifying cryptoassets, regardless of how they are described, but does not extend to specified investment cryptoassets or linked financial instruments.
Dealing in qualifying cryptoassets as an agent
Dealing in qualifying cryptoassets as an agent covers a broad range of transactions relating to buying and selling qualifying cryptoassets, regardless of how they are described, but does not extend to specified investment cryptoassets or linked financial instruments.
Arranging deals in qualifying cryptoassets
Arranging deals in qualifying cryptoassets includes both bringing about specific transactions and making ongoing arrangements that facilitate trading.
Arranging qualifying cryptoasset staking
Making arrangements on behalf of another person (whether as principal or agent) for blockchain validation using qualifying cryptoassets. This focuses on the intermediation that enables staking to occur, rather than simple introductions or basic communications between parties. This may include pooling customer assets to meet validator thresholds and distributing staking rewards.
Next Steps
The deadline for responses to the CP is 3rd June 2026. Final guidance is expected over the summer in advance of the gateway opening on 30th September.
How Thistle Initiatives Can Help
We can support your firm in preparing for the new cryptoasset regulatory framework by:
- Creating and implementing frameworks so that compliance is built in from day one
- Supporting your application for FCA authorisation
- Assisting with the transition into becoming a fully authorised firm
- Providing technical support for pre- and post- trade reporting
Get in touch today to discuss how we can help your firm navigate the new regime.
Meet the Expert
Melissa Buckingham, Compliance Consultant 
Melissa joined Thistle Initiatives in 2025, bringing with her a strong background in managing conflicts of interest and cross-border regulatory activity from her time at a Tier 1 bank.
With a deep understanding of both the regulatory landscape and operational pressures facing firms, Melissa adopts a thorough and detail-oriented approach to helping clients achieve and maintain compliance. She supports clients across a range of sectors, but primarily in the investments and wealth management space.