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UK FCA Consults on Cryptoasset Perimeter Guidance (CP26/13)

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Summary

The UK Financial Conduct Authority (FCA) has published consultation paper CP26/13 proposing changes to the Perimeter Guidance Manual (PERG) within the FCA Handbook to clarify the scope of new regulated cryptoasset activities and when permissions will be required under the Financial Services and Markets Act 2000 (FSMA). The FCA aims to help firms transitioning from the current cryptoasset regime under the MLRs to the new cryptoasset activities. Responses are due by 3 June 2026.

Why this matters

Cryptoasset firms operating or planning to operate in the UK should use this consultation period to review the draft PERG guidance against their current and planned business models. The FCA explicitly anticipates that earlier clarity on required permissions will reduce inadvertent perimeter breaches and reduce the number of firms operating under savings provisions — firms that have been uncertain about their regulatory status should treat this as the window to seek alignment before enforcement risk increases.

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What changed

The FCA has published consultation paper CP26/13 proposing a new chapter in the Perimeter Guidance Manual (PERG) to provide guidance on how to determine whether an activity is within the regulatory perimeter, including guidance on new specified investments and regulated cryptoasset activities, which permissions may be required for certain business models, and how specific exclusions operate. The consultation also clarifies that FSMA-authorised cryptoasset firms will not need to register as cryptoasset exchange providers or custodian wallet providers under the MLRs but will only need to notify the FCA, while still complying with the MLRs.

Cryptoasset firms currently operating under the MLRs regime and those planning to enter the UK market should review the draft Perimeter Guidance (Regulated Cryptoasset Activities) Instrument 2026 in Appendix 1 of the consultation. Firms should assess whether their business models require new permissions under FSMA and submit responses by the 3 June deadline to influence the final guidance expected in September.

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Apr 20, 2026

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April 20, 2026

UK FCA consults on cryptoasset perimeter guidance

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The UK Financial Conduct Authority (FCA) has published consultation paper CP26/13, proposing changes to the Perimeter Guidance Manual (PERG) within the FCA Handbook to clarify the scope of the new regulated cryptoasset activities and when permissions will be required. In addition, the consultation paper aims to provide clarity for firms transitioning from the FCA's current cryptoasset regime (under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017) (MLRs) to the new cryptoasset activities under the Financial Services and Markets Act 2000 (FSMA).

The proposed new chapter in PERG will contain guidance on how to determine whether an activity is within the perimeter, and guidance on the new specified investments and new regulated cryptoasset activities, including which permissions may be required for certain business models and how specific exclusions operate and other related issues. The FCA also clarifies that, as outlined by HM Treasury in the explanatory memorandum accompanying the Cryptoasset Regulations 2026, FSMA authorised cryptoasset firms will not need to register as "cryptoasset exchange providers" or "custodian wallet providers" under the MLRs but instead will only need to notify the FCA. However, these firms will still need to comply with the MLRs. The proposed guidance in full is set out in the draft Perimeter Guidance (Regulated Cryptoasset Activities) Instrument 2026, in Appendix 1 of the consultation paper.

The deadline for responses is 3 June. The FCA will publish its final guidance in September. It confirms that should there be further legislative changes before the finalisation of this proposed guidance, the FCA will reflect the changes, as appropriate. The FCA anticipates the guidance will help firms applying for the right permissions, with fewer inadvertently breaching the perimeter. The FCA also anticipates fewer firms operating under savings provisions, because they will understand which permissions they need to apply for earlier.

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Last updated

Classification

Agency
A&O Shearman
Published
April 20th, 2026
Comment period closes
June 3rd, 2026 (44 days)
Compliance deadline
June 3rd, 2026 (44 days)
Instrument
Notice
Branch
Executive
Legal weight
Non-binding
Stage
Consultation
Change scope
Substantive

Who this affects

Applies to
Financial advisers Investors Technology companies
Industry sector
5239 Asset Management
Activity scope
Cryptoasset regulation Regulatory perimeter FCA authorisation
Geographic scope
United Kingdom GB

Taxonomy

Primary area
Financial Services
Operational domain
Compliance
Topics
Securities Anti-Money Laundering

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