On 30 April 2026, the FCA published PS 26/7 (the PS), which sets out its policy decisions in respect of a Direct 2 Fund (D2F) dealing model as well as wider issues around the use of tokenisation by authorised funds.
The PS sets out
guidance as to how firms can use distributed ledger technology (DLT) within the FCA's rules
rules intended to make fund dealing more efficient - this includes an optional D2F model, which would allow investors to deal directly with the fund (regardless of whether the fund is traditional or tokenised)
the FCA's thoughts as to how fund tokenisation could develop over time as part of its roadmap for digital assets.
We will be publishing more detailed articles in due course on the main points arising from the FCA's decisions as they affect managers.
Background to the PS
In Discussion Paper 23/3, "Updating and improving the UK regime for asset management", the FCA sought views on a number of different ways in which it can support technological innovation.
This included (among other things) new dealing models such as D2F, the tokenisation of fund units and investment in tokenised assets.
D2F is a dealing model for UK authorised funds which would simplify the dealing process by allowing investors to transact directly with the fund when buying/selling units, rather than via the authorised fund managers as principal.
Since it was felt that existing rules on creation, transfer, registration and cancellation of units may not be sufficiently flexible to allow a "digital register", the FCA consulted in CP 25/28, "Progressing Fund Tokenisation" on:
guidance for operating a tokenised fund under the Blueprint model developed by the Technology Working Group of the Government's Asset Management Taskforce
rules and guidance for an alternative, streamlined D2F model for conventional and tokenised authorised funds
a roadmap to advance fund tokenisation and address key barriers
a discussion on future tokenisation models that use DLT to provide tokenised portfolio management at retail scale and how regulation may need to change in order to be fit for the future.
The FCA's PS sets out its policy decisions on the above, reflecting feedback received to the CP.


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