FCA consults on admissions & disclosures regime for cryptoassets

CP25/41: Regulating cryptoassets: Admissions & disclosures for cryptoassets

The FCA’s Consultation Paper 25/41 (CP 25/41) sets out detailed proposals in relation to Admissions & disclosures and market abuse regime for cryptoassets. Building on the draft Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 (the Cryptoasset Regulations) and feedback from DP 24/4, the FCA aims to introduce a proportionate and adaptable framework that addresses the unique risks of cryptoassets while supporting market integrity and consumer protection.

The proposed Admissions & Disclosures (A&D) regime is designed to be proportionate and adaptable, recognising the unique risks of cryptoassets compared to traditional markets. It applies to the admission of qualifying cryptoassets on retail-facing Cryptoasset Trading Platforms (CATPs) and to certain public offers to retail investors. The FCA expects to refine the regime over time as the market evolves.

Below, we provide an overview of the FCA’s key proposals and what they could mean for market participants.

Admission and due diligence

UK-issued qualifying stablecoins

A Cryptoasset Trading Platforms (CATP) can admit a UK-issued qualifying stablecoin to trading by using the issuer’s Qualifying Cryptoasset Disclosure Document (QCDD) from the FCA’s central repository, without needing further amendments. The CATP may conduct additional due diligence or request more information, but cannot charge the issuer or a third party for this. While CATPs can reject an application, they cannot do so based on the quality or accuracy of the QCDD, and must notify both the issuer and the FCA with reasons for rejection. Third parties can also request admission using the issuer’s QCDD, and issuers have the right to make representations if they object, with at least five business days to respond. This process is designed to ensure both broad access and adequate disclosure for UK-issued qualifying stablecoins.

Other qualifying cryptoassets

Assessing eligibility for admission: The FCA proposes that CATPs establish clear, risk-based criteria for admitting cryptoassets. These criteria must be approved by the CATP’s governing body, published on the CATP’s website, and subject to regular review. CATPs are required to reject applications where the cryptoasset presents a risk to retail investors, taking into account factors such as the identity and credibility of those behind the cryptoasset, the quality of disclosures, the features of the asset, and the ability of responsible parties to provide compensation if necessary.

CATPs must apply these standards objectively, including in cases where they or their group has an interest, and must manage conflicts of interest in accordance with FCA rules.

Due diligence: The FCA is proceeding with its proposal in DP 24/4 to require CATPs to conduct due diligence before admitting a qualifying cryptoasset to trading. CATPs must review the QCDD (see below) prior to admission and must not admit a cryptoasset unless they are reasonably satisfied that the QCDD contains all information required by the Cryptoasset Regulations and the CATP’s own disclosure requirements, and that the information is accurate and not misleading.

Disclosure Requirements (QCDDs and SDDs)

UK-issued qualifying stablecoins

Disclosure: Issuers must provide two types of disclosure: (1) up-to-date information on their website, and (2) a QCDD published both on their website and in the FCA’s central repository. Unlike other cryptoassets, a summary QCDD and voluntary protected forward-looking statements are not required for UK-issued stablecoins.

Publication and filing: The QCDD must be available before purchase or subscription, both on the issuer’s website and the FCA’s repository.

Other qualifying cryptoassets

Requirement for a QCDD: Generally, a CATP can only list a new cryptoasset if a QCDD has been prepared and published. Exceptions include further issuances of cryptoassets already listed with a QCDD on the same CATP, or where only professional investors can trade. For public offers under certain exemptions, a QCDD must still be published to protect retail investors. This requirement applies to CATPs authorised in the UK, though platforms may choose to require a QCDD in other cases.

Requirement for a SDD: If, after a QCDD is published but before trading begins, any significant new information, mistake, or inaccuracy arises that could affect investment decisions, a Supplementary Disclosure Document (SDD) must be published. Investors who have already agreed to buy the cryptoasset will have withdrawal rights if an SDD is issued.

Format: Reflecting DP24/4 feedback, the FCA favours an outcomes-based, flexible approach to disclosure. QCDDs must be concise, clear, in English, and suitable for retail investors, with content tailored to the risk and type of cryptoasset.

Content: QCDDs must highlight who is liable for misleading statements or omissions, the possibility of SDD publication, and any conflicts of interest involving the CATP. For stable-value cryptoassets, disclosures must cover features supporting stability, associated risks, and redemption policies. Each QCDD must also include a short summary of key information, such as the asset’s name, DTI, the responsible person, and references to further details, to improve accessibility for investors.

Publication and filing: Most respondents to DP 24/4 supported the proposal to use the FCA’s National Storage Mechanism (NSM) as a central repository for QCDDs, recognising benefits for transparency and accessibility. The FCA now proposes that CATPs must file approved QCDDs (and SDDs, if any) with the NSM before trading starts and also publish them on their own websites. There is currently no requirement for a specific machine-readable format, but this may be considered in the future.

Responsibility and Liability of QCDDs and SDDs

UK-issued qualifying stablecoins

Issuers of UK-issued qualifying stablecoins are responsible for the accuracy of their disclosures and can be held liable for any misleading, inaccurate, or incomplete information under the Cryptoasset Regulations and FCA rules.

Other qualifying cryptoassets

The persons who are responsible for a QCDD or SDD will be subject to the statutory liability and compensation provisions in the Cryptoasset Regulations. The FCA’s proposed rules are designed to ensure clear accountability for QCDDs and SDDs.

• If the applicant prepares the document, they are responsible for its content, along with any other parties expressly named as accepting responsibility.
• Where the applicant uses a third-party QCDD or SDD, they remain responsible unless the third party is explicitly identified in the document as accepting responsibility. All responsible parties must be clearly and prominently disclosed within the QCDD or SDD.
• For intermediaries offering qualifying cryptoassets to consumers, the responsibility for the QCDD rests with the party that prepares it.

Withdrawal Rights

UK-issued qualifying stablecoins

Prospective holders of UK-issued qualifying stablecoins have withdrawal rights if, after agreeing to buy or subscribe and before trading begins, a material change leads to a new QCDD being published. These rights apply only if the agreement was made after the original QCDD was published and before the stablecoin is admitted to trading on a CATP.

Other qualifying cryptoassets

The FCA proposes that if a SDD is published before a cryptoasset is admitted to trading, consumers who agreed to buy after the QCDD was published can withdraw their acceptance within two working days. This right ensures investors can reconsider their decision in light of new, material information.

Consumer Duty

UK-issued qualifying stablecoins

The FCA does not propose to exclude UK-issued stablecoin QCDDs from the Consumer Duty at this stage. While the Consumer Duty will not apply to public offers and admissions of other qualifying cryptoassets (which will instead be covered by bespoke A&D rules), the position for UK-issued stablecoins will be reviewed and confirmed in a consultation in January 2026.

Other qualifying cryptoassets

Feedback to DP24/4 and CP25/25 showed strong support for using bespoke Admissions & Disclosures (A&D) rules, rather than the general Consumer Duty, to protect consumers in the cryptoasset market. Respondents felt that sector-specific A&D requirements would better address cryptoasset risks, ensure consumers receive the material information they need, and improve comparability across disclosures. As a result, the FCA proposes that Consumer Duty will not apply to public offers and admissions of qualifying cryptoassets; instead, tailored A&D rules, incorporating key consumer understanding principles from the Consumer Duty, will apply. These rules will require QCDDs to be clear, fair, and easy for consumers to understand, with guidance on logical structure, plain language, and highlighting key information. The Consumer Duty will still apply to UK-issued qualifying stablecoin disclosures.

Financial Promotion

The Cryptoasset Regulations will exempt QCDDs and SDDs from financial promotion restrictions under section 21 FSMA. This mirrors the position in traditional finance, for example, a prospectus will be considered a regulatory disclosure rather than a marketing document. However, all other promotional materials, such as advertisements, will still be subject to these rules. The FCA is considering further amendments for advertisements linked to admissions where a QCDD exists, with more details to be consulted on in 2026. For public offers without a QCDD, the usual financial promotion requirements will continue to apply. CATPs and other firms may need to seek approval to make financial promotions.

What this means

For crypto firms, the FCA’s proposals mean stricter requirements for asset admission, disclosure, and due diligence, with a strong emphasis on clear, risk-based criteria and accurate, up-to-date investor information. Overall, firms will need stronger governance, clearer documentation, and more robust internal processes to meet the FCA’s new admissions and disclosure expectations.

Next steps

The FCA is inviting feedback on these proposals until 12 February 2026.