PS26/11 finalises the conduct rules for: operators of UK qualifying cryptoasset trading platforms (QCATPs); cryptoasset intermediaries (including dealers and arrangers); lending and borrowing; staking; and safeguarding. It also covers the FCA’s interim approach to decentralised finance (DeFi) and its approach to international firms.

The conduct framework proposals, which PS26/11 now finalises, did not all sit in a single FCA consultation paper, but were contained in CP25/14, CP25/40 and CP26/4. We have previously covered the details of these proposals in our recent webinars which can be found here: New UK crypto regime: regulated activities and our blog post on CP25/40 which can be found here: UK future crypto framework: FCA Consultation Paper on Regulating Cryptoasset Activities (CP25/40).

Now, the FCA has made several key changes in its final rules, including the following:

Cryptoasset intermediaries and QCATP operators

The policy statement loosens or cuts back some rules on how cryptoasset trading platforms must be structured and carry out trades. For example:

• pre-trade transparency requirements have been dropped for firms dealing as principal
• post-trade transparency requirements now provide for deferred publication in certain circumstances
• on best execution, the final obligations broadly align with those applied to traditional intermediaries—firms should be able to demonstrate that their execution policy delivers outcomes that are at least as good as execution on UK-authorised execution venues (where accurate comparisons can be made) but won’t be required to execute such orders on a UK-authorised venue
• best execution obligations will not apply to UK QCATPs conducting matched principal trading on their own platform—the FCA further confirmed it will consult on a deferral mechanism with respect to execution policies in September 2026
• UK QCATPs will not be subject to certain pre-trade disclosure requirements when conducting matched principal trading on their own platform
• the FCA confirmed it will not require legal entity separation for principal dealers, but they may not deal on their own platform.

On the retail access perimeter, firms may only deal or arrange cryptoasset trades for UK retail clients where the cryptoasset has been admitted to trading on a retail UK QCATP with a published qualifying cryptoasset disclosure document or supplementary disclosure document. However, a deferral on this and certain other execution-venue requirements will be consulted on in September this year.

Safeguarding

The FCA has: introduced targeted exceptions to trust requirements; clarified the scope of ‘control-based’ application; increased the amount of own funds which can be used to support a settlement float model to 2% of safeguarded cryptoassets; and adopted a technology‑agnostic approach to private key management. The FCA is also planning further engagement on tokenised asset custody and potential future CASS amendments, plus a consultation on resolution of crypto custodians.

The FCA has also decided not to apply CASS 17 to relevant specified investment cryptoasset (RSIC) custody at this stage. This means that firms seeking to become authorised to provide RSIC custody will need to do so as a cryptoasset custodian, but will then apply the CASS 6 requirements (which apply to specified investments today) rather than the CASS 17 rules developed specifically for the tech-specific nuances of safeguarding cryptoassets.

Staking

The rules on staking have been amended to avoid unintended restrictions on auto‑staking arrangements, allowing consent to cover ongoing staking of current and future holdings subject to conditions and annual notification. The FCA has also clarified how record-keeping requirements apply to liquid staking models.

Lending and borrowing

The FCA has made targeted amendments applying to collateral arrangements, including permitting the staking of retail client collateral (subject to CASS 17) and clarifying that limits on automatic collateral top‑ups apply only to firms, without restricting clients’ ability to top up their positions manually.

DeFi

On DeFi, the FCA maintains that it will apply rules where there is an identifiable controlling person, taking a case-by-case approach. Further guidance on decentralised finance will also be the subject of consultation later this year.

International firms

In respect of international firms, the FCA confirms it will not be issuing prescriptive guidance on particular business models, as models will need to be assessed on a case-by-case basis. However, the policy statement does explain when international firms may operate via a UK branch combined with a UK legal entity. Dual-regulated firms may operate in the UK through a bank alone where the Prudential Regulation Authority is satisfied that its threshold conditions and ongoing requirements are met. International QCATP operators will not be required to run a separate UK order book, which apparently was a misconception in some respondents’ feedback.

FCA rules in COBS and DISP which apply to international QCATPs authorised in the UK via a branch will only apply to UK-based users—this is to ensure alignment with the FCA’s commitment on the scope of the consumer duty, which is currently the subject of consultation paper CP26/23. International firms should also note the FCA’s finalised guidance FG26/7 on its approach to international cryptoasset firms.