Trylogia konsultacji FCA w sprawie kryptowalut od środka: praktyczny przewodnik

If the UK government's December 2025 announcement was the headline, the three consultation papers published by the Financial Conduct Authority are the fine print. Together, CP25/40, CP25/41 and CP25/42 form the most detailed regulatory blueprint for cryptoassets ever produced by a major financial regulator — and firms operating in the UK market need to understand exactly what these documents contain.

CP25/40: The Activities Framework

The first paper tackles the broadest question: which crypto activities will require FCA authorisation? The answer is essentially all of them. The scope covers trading platforms, intermediaries, lending and borrowing services, staking providers, and even certain decentralised finance activities. Larger platforms — those exceeding GBP 10m in average annual revenue — face additional obligations, including non-discriminatory access rules and stricter transparency requirements.

For retail lending specifically, the FCA proposes mandatory over-collateralisation requirements. This is a direct response to the wave of crypto lending platform failures in 2022–2023 and a signal that the regulator has closely examined how insolvencies unfold in this sector.

CP25/41: Disclosure and Market Abuse

The second paper introduces requirements that will be familiar to anyone who has worked in traditional securities markets. Issuers seeking admission to UK trading platforms must prepare qualifying cryptoasset disclosure documents — effectively prospectuses — including a two-page summary highlighting the key risks. The market abuse regime prohibits insider dealing and market manipulation, and large platforms are required to monitor on-chain activity for suspicious patterns.

This is where the regulation becomes genuinely groundbreaking. Monitoring on-chain activity for market abuse is a technical challenge that has no direct precedent