Clifford Chance

On 26 November 2024, the Financial Conduct Authority (FCA) published a series of pieces on crypto regulation, including its anticipated Crypto Roadmap. In doing so, it has set out key dates for the development of a comprehensive regulatory framework for crypto in the UK and forecasts the publication of all Policy Statements to be completed by 2026, with the regime taking effect shortly thereafter.

Currently, cryptoassets are largely unregulated in the UK. Where there is specific overlap with certain regulatory frameworks, such as in the case of the Anti-Money Laundering regime and the Financial Promotions regime, crypto may be exposed to some regulation, but otherwise cryptoassets fall outside of the regulatory perimeter. (See our article: The developing regulatory landscape for cryptoassets in the EU and UK for discussion of the current regulatory landscape for cryptoassets in the UK).

The Crypto Roadmap

We highlight below some of the key developments contained within the FCA's Crypto Roadmap:

At the end of 2024, we saw:

• The publication of Discussion Paper 24/4, seeking comments until 14 March 2025 on the future Market Abuse Regime for Cryptoassets and the cryptoasset Admissions and Disclosures regime (see our upcoming briefing for further information on this).

In the first half of 2025:

• Publication of a Discussion Paper on specific rules for trading platforms, intermediation, lending, staking and prudential rules.
• Publication of a Consultation Paper including proposed regulation for stablecoins and custody of cryptoassets, as well as the new prudential sourcebook, which will set out stronger regulation for capital, liquidity and risk management in relation to cryptoassets.

In Q3 2025:

• Publication of a Consultation Paper on conduct and firm standards for all Regulated Activities Order (RAO) activities, including draft provisions on systems and controls including operational resilience and financial crime, consumer duty, conduct (COBS) and governance including Senior Managers and Certification Regime (SMCR).
• Publication of a Consultation Paper covering Market Abuse Regime for Cryptoassets and the cryptoasset Admissions and Disclosures regime (as per the Discussion Paper).

By Q1 2026:

• Publication of a Consultation Paper covering trading platforms, intermediation, lending and staking and the remaining material for the prudential sourcebook.

In 2026:

• All Policy Statements are published.
• The Gateway opens before the regime goes live.

FCA Change of Focus

The roadmap is published against the backdrop of change in the FCA's focus and outlook. On 14 November 2024, as is required under section 1JA of FSMA, the UK Chancellor wrote to the FCA providing recommendations about aspects of the government’s economic policy to which the FCA should have regard when advancing its objectives and discharging its duties. The letter emphasised the importance of growth and the important role the FCA has to play in achieving it, including by enabling responsible risk taking and support for innovative new firms entering the market. In its response, the FCA emphasised its commitment to growth in its 2025 -2030 strategy. This emphasis on growth marks a change in tone from the period following the Global Financial Crisis in which the FCA was focused on the importance of preventing and detecting misconduct.

In relation to cryptoassets, the FCA's letter highlighted the choices available. It explained that its objective is to seek to maximise the UK's leading role on international crypto standards at the International Organization of Securities Commissions (IOSCO), while recognising that other jurisdictions might pursue a different approach or not seek to regulate these products at all.

US Approach

The roadmap is also published at a time when the regulatory and political landscape is changing in the US.

Following indications from the Trump administration and the recent appointment of Brendan Carr as Chief Executive of the US Federal Communications Commission, there is a perception that the US regulatory environment will be more pro-crypto. But at a hearing before the Treasury Select Committee on 10 December 2024, the FCA's Chair warned of the dangers in a "race to the bottom" with the US or other countries.

Rather, as noted in the aforementioned remit letter, the FCA "can seek to maximise [its] leading role on international crypto standards at the International Organization of Securities Commissions (IOSCO), while recognising that other jurisdictions might pursue a different approach or not seek to regulate these products at all."

(For more on what might happen under the new Trump Administration see our Briefing: Forecasting the Impact of Trump's Second Administration on the Tech Sector).

The detail in the discussion and consultation papers anticipated in the roadmap will be of critical importance is understanding how this changing backdrop is influencing the future of crypto regulation in the UK.