Crypto Law Profile

FCA Prudential Regime for Cryptoasset Firms

FCA proposals for capital, liquidity, risk assessment and prudential disclosure rules for UK-authorised cryptoasset firms. Consultations are closed; final rules remain pending, with the broader regime expected to start on 25 October 2027.

United Kingdom Proposed Regulation

At a glance

Status Proposed FCA Handbook rules; both consultations are closed and final policy statements are pending.
Scope Covers stablecoin issuance, custody, trading platforms, staking, arranging, and principal or agency dealing.
Capital model Own funds would be the highest of an activity-based minimum, fixed overheads and K-factor requirement.
Expected start The wider UK cryptoasset regime is expected to commence on 25 October 2027.

Overview

The FCA Prudential Regime for Cryptoasset Firms is a proposed United Kingdom framework for the financial resilience of firms carrying on regulated cryptoasset activities. It is set out across Financial Conduct Authority consultation papers CP25/15 and CP25/42. As of 19 June 2026, both consultations have closed, but the Handbook rules have not been finalised. The FCA intends to publish policy statements in summer 2026, while the wider UK cryptoasset regime is expected to commence on 25 October 2027.

Scope of the FCA prudential regime

CP25/15 introduced proposals for firms issuing qualifying stablecoins and safeguarding qualifying cryptoassets. CP25/42 extended the framework to firms operating qualifying cryptoasset trading platforms, arranging qualifying cryptoasset staking, arranging deals, and dealing in qualifying cryptoassets as agent or principal. Principal dealing includes certain lending and borrowing business models. The statutory perimeter is established by the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026.

The FCA proposes two new sourcebooks. COREPRU would contain common rules on financial adequacy, own funds, fixed overheads, liquidity, concentration risk and the general risk-assessment process. CRYPTOPRU would contain cryptoasset-specific minimum capital, K-factor, issuer-liquidity, risk-assessment and disclosure requirements. The framework is designed for solo FCA-authorised firms, although group risks would still need to be assessed and disclosed.

Proposed capital requirements for cryptoasset firms

A firm’s minimum own-funds requirement would be the highest of three measures: its permanent minimum requirement, fixed overheads requirement and aggregate K-factor requirement. Where a firm has several cryptoasset permissions, the highest applicable permanent minimum would apply.

  • £750,000 for dealing in qualifying cryptoassets as principal.
  • £350,000 for issuing qualifying stablecoins.
  • £150,000 for safeguarding cryptoassets, arranging staking or operating a qualifying cryptoasset trading platform.
  • £75,000 for dealing as agent or arranging deals.

The fixed overheads requirement would generally equal one quarter of the firm’s relevant expenditure in the previous year. It is intended to provide capital linked to the cost of absorbing losses and executing an orderly wind-down.

Activity and exposure-based K-factors

The proposed K-factors scale capital with particular business risks. Stablecoin issuers would calculate K-SII at 2% of average qualifying stablecoins in issuance. Custodians and staking arrangers would calculate K-QCS and K-CCS at 0.04% of average safeguarded or staked client cryptoassets. Client-order and trading-flow measures would each be 0.1% of the relevant average. Firms with trading-book positions would also face net cryptoasset position charges: 40% for assets meeting the proposed Category A conditions and 100% for Category B assets. Separate measures would address counterparty default and concentration risk.

Liquidity, risk assessment and disclosure

All in-scope firms would maintain a basic stock of core liquid assets equal to one third of the fixed overheads requirement plus 1.6% of guarantees provided to clients. Qualifying stablecoin issuers would also calculate an issuer liquid-assets requirement linked to the composition and maturity of backing assets.

Each firm would complete an overall risk assessment covering material harms, stress testing, recovery options, ongoing operations and orderly wind-down. That assessment could produce own-funds and liquid-assets thresholds above the formulaic minimums. The governing body would approve it at least annually, and the firm would review it after a material change to its business or operating model.

The FCA also proposes public prudential disclosures at least annually. These would cover risk management, the composition of own funds, minimum and K-factor requirements, firm-specific threshold requirements and relevant group arrangements. Firms dealing as principal would provide additional financial information about their ultimate parent.

Status and implementation timeline

The underlying Cryptoassets Regulations were made on 4 February 2026 and permit preparatory FCA rulemaking before full commencement. The FCA says its authorisation gateway for cryptoasset permissions will open on 30 September 2026. The prudential proposals themselves remain subject to consultation feedback and final policy statements, so the figures and methods in this profile should be checked against the final Handbook instruments before the regime takes effect.

This profile is a neutral legal reference and does not provide legal, tax, investment or trading advice.

Key provisions

Two-sourcebook structure

COREPRU would contain common prudential rules, while CRYPTOPRU would add cryptoasset-specific capital, liquidity, risk and disclosure requirements.

Prudential framework Source

Highest-of own funds requirement

A firm would maintain own funds at least equal to the highest of its permanent minimum, fixed overheads and aggregate K-factor requirements.

Capital Source

Activity-based capital floors

Proposed PMRs range from £75,000 for agency dealing or arranging to £750,000 for principal dealing; issuance is £350,000 and custody, staking and CATPs are £150,000.

Capital Source

Fixed overheads requirement

The FOR would generally equal one quarter of relevant annual expenditure, creating a capital buffer linked to the cost of an orderly wind-down.

Capital Source

Operational K-factors

Proposed charges include 2% of average stablecoins in issuance, 0.04% of safeguarded or staked client cryptoassets, and 0.1% of client orders or trading flow.

Activity risk Source

Trading and counterparty exposure

Principal-dealing firms would face net-position, counterparty-default and concentration requirements; proposed net-position charges are 40% for Category A and 100% for Category B assets.

Market risk Source

Liquidity and wind-down resources

All firms would hold core liquid assets equal to one third of the FOR plus 1.6% of client guarantees; stablecoin issuers would face an additional issuer liquidity requirement.

Liquidity Source

Overall risk assessment

Firms would assess capital and liquidity needed for ongoing operations and orderly wind-down, with annual governing-body approval and reviews after material changes.

Risk management Source

Public prudential disclosure

At least annually, firms would publish risk management, own-funds, capital requirement, threshold and group-arrangement information.

Disclosure Source

Timeline

  1. CP25/15 published

    FCA opened consultation on prudential rules for qualifying stablecoin issuers and cryptoasset custodians.

    Under consultation Source
  2. CP25/15 consultation closed

    The first-stage prudential consultation closed; feedback was to inform final rules.

    Proposed Source
  3. CP25/42 published

    FCA extended the prudential proposals to trading platforms, staking, arranging, and principal or agency dealing.

    Under consultation Source
  4. Cryptoassets Regulations made

    SI 2026/102 was made, enabling preparatory FCA rulemaking and setting full commencement for 25 October 2027.

    Enacted Source
  5. CP25/42 consultation closed

    The second-stage consultation closed; the framework remained proposed pending policy statements.

    Proposed Source

Who it affects

Actors

Financial Conduct Authority

Asset classes

Cryptoassets, Stablecoins

Official sources

Editorial note

This profile consolidates CP25/15 and CP25/42 because the FCA presents them as two stages of one prudential regime. It describes proposals, not final Handbook rules.