PS26/9: An Admissions and Disclosures Regime for Cryptoassets

On 25 June 2026, the FCA published Policy Statement 26/9 (PS26/9), setting out the final rules for the market abuse regime for cryptoassets (MARC) and the regime for Admissions & Disclosures (A&D) under the Designated Activities Regime (DAR).

PS26/9 consolidates the proposals set out in the FCA's Consultation Paper 25/41 (CP25/41), keeping the main framework of the consulted regime and adding targeted changes to address feedback received. In this article we look specifically at the A&D regime and the changes compared with the regime proposed in CP25/41.

Purpose of the regime

The A&D regime governs the process by which a cryptoasset is admitted to trading under the new cryptoasset framework introduced by the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 (the Cryptoasset Regulations). As well as admission and disclosure requirements, the A&D regime touches on Consumer Duty, financial promotions, and responsibility and liability for due diligence.

Feedback received

As with the MARC regime, consultation feedback was broadly supportive of the FCA's proposals in CP25/41. As such, the broad framework has been copied into the final rules, with a few key changes relating to, among other things, the trigger for supplementary disclosure documents (SDDs), a new mandatory digital token identifier standard (also applicable to MARC), strengthened withdrawal rights notifications, and rules requiring more qualifying cryptoassets to obtain a qualifying cryptoasset disclosure document (QCDD) before being admitted to trading.

Admission and due diligence

UK-issued qualifying stablecoins

As discussed in our article on CP25/41, a Cryptoasset Trading Platform (CATP) can admit a UK-issued qualifying stablecoin to trading by using the issuer's QCDD from the FCA's central repository, without needing further amendments.

Other qualifying cryptoassets

Assessing eligibility for admission: The FCA views UK QCATPs as key gatekeepers and, as such, requires them to establish and publish admission criteria as part of the A&D regime. In the final rules, the FCA has made it clear that the initial pre-admission assessment is whether a retail UK QCATP operator is "reasonably satisfied the admission to trading of the qualifying cryptoasset is not likely to be detrimental to the interests of retail investors". Operators must take into account - at the minimum - the non-exhaustive factors in CRYPTO 3.2. As the FCA proposed in its consultation, UK QCATPs must establish clear, risk-based criteria for admitting cryptoassets.

A number of other changes have been made to the requirements for such criteria:

• the reference to "fitness and proprietary" has been replaced with "integrity and reputation";

• admission criteria no longer needs to take into account the "quality" of QCDDs, but should instead consider information that cannot be obtained or verified when applying the criteria;

• the minimum factors that UK QCATPs need to take into account have been clarified, and a reference to "sustainability" in the consultation has been replaced with "continuing viability"; and

• new guidance has been introduced on other relevant matters including legal proceedings, regulatory action and adverse public information.

As before, these criteria must be approved by the CATP's governing body, published on the CATP's website and subject to regular review.

The new rules require QCATPs to apply their admission criteria in a way that is proportionate, risk-based and objective. Note that UK CATPs must publish their admission criteria to support transparency but aren't required to publish highly detailed methodologies or individual rejection decisions.

Due diligence: In CP25/41, the FCA proposed that UK QCATPs should conduct due diligence before admitting a qualifying cryptoasset to trading and to keep records. This was intended to support UK QCATPs' assessments of whether admission would likely be detrimental to the interests of retail investors and whether the QCDD met the relevant requirements. While this provision remains, the final rules have clarified the FCA's expectations on proportionate due diligence. For example:

• when assessing whether admission is likely to be detrimental to the interests of retail investors, UK QCATPs' are subject to a reasonableness standard when identifying and obtaining the relevant information and assessing whether the admission will be detrimental to the interests of retail investors; and

• when judging whether a UK QCATP has complied with the requirements, the FCA will consider whether it has followed a "robust and documented process", although following this process alone will not be determinative. Where information cannot be obtained or verified, the UK QCATP must be reasonably satisfied that the information is "true and not misleading".

Disclosure requirements (QCDDs and SDDs)

UK-issued qualifying stablecoins

As set out in our article on CP25/41, 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 (available before purchase or subscription). A summary QCDD and voluntary protected forward-looking statements are not required for UK-issued stablecoins.

Other qualifying cryptoassets

Unless an exception applies, a UK QCATP can only list a new cryptoasset if a QCDD has been prepared and published both on its website and the FCA's central repository. If, after this is published but before admission to trading, (1) the person who produced the QCDD becomes aware of new information, a mistake, or an inaccuracy relating to the information included in the QCDD (or any SDD) and (2) the relevant matter may be material to a person considering buying or subscribing for the qualifying cryptoasset, an SDD needs to be published with this new information. However, the final rules have confirmed that there is no general ongoing obligation to update disclosures after admission to trading.

In CP25/41, the FCA outlined a number of exemptions to preparing a QCDD, including a "fungibility exemption", which has now been removed from the final version of the rules. As such, where qualifying cryptoassets are fungible with those already admitted to trading on the relevant platform, a QCDD will still be required.

A number of other changes have also been made:

• the use of a specified DTI standard is now required;

• a clear disclaimer is needed on QCDDs and SDDs that these do not require FCA approval and have not been approved by the FCA; and

• where the person who produces the QCDD or SDD is not the issuer, guidance has confirmed that they may draw on publicly available / reasonably accessible information when preparing this.

Responsibility and liability for due diligence

UK-issued qualifying stablecoins

As set out in CP25/41, issuers of UK-issued qualifying stablecoins are responsible for the accuracy of their disclosures under the final rules and can be held liable for any misleading, inaccurate, or incomplete information under the Cryptoasset Regulations and FCA rules.

Other qualifying cryptoassets

In PS26/9, the FCA reported that a number of respondents had been concerned that the due diligence obligation could expose UK QCATPs to open-ended private liability. As such, the final rules have addressed the scope of the obligation on UK QCATPs, namely that they must take reasonable steps to identify and obtain sufficient information for their pre-admission assessment, and to be reasonably satisfied that admission is not likely to be detrimental to the interests of retail investors.

Record keeping

These obligations only apply to UK QCATPs. In the final rules, record-keeping requirements have been aligned with the changes made to the due diligence and admission requirements. Most notably, there is now a requirement to keep records of information that could not be obtained or verified for the purposes of the investor detriment assessment.

Note that UK QCATPs must also now retain relevant CRYPTO 3 records for up to 7 years, which include records relating to due diligence, admission decisions, QCDD and SDD assessments, and publication decisions.

Withdrawal rights

Withdrawal rights arise only in limited situations, namely where there is a relevant public offer and a summary disclosure document is made available prior to admission to trading. They are not intended to function as an ongoing cancellation, redemption or put option once admission has taken place.

Under the final rules, the notification requirements are amended so that an equivalent day-of-publication notification applies to both direct-offer and intermediary distribution channels. Additional guidance clarifies that any information emerging prior to admission, or any failure to comply with withdrawal rights notification requirements, may impact a UK QCATP operator's pre-admission assessment.

Consumer Duty

UK-issued qualifying stablecoins

In CP25/41, the FCA had not decided whether the Consumer Duty would apply to UK-issued qualifying stablecoins. It has now confirmed that the Consumer Duty will apply to all persons involved in activities relating to UK-issued qualifying stablecoins.

Other qualifying cryptoassets

As the FCA proposed in its consultation, bespoke A&D rules apply to QCDDs and SDDs. As such, these are exempt from the Consumer Duty. Any other advertisements or communications, however, will be subject to the Consumer Duty if they involve a firm's communication or approval of a financial promotion that is addressed to or disseminated in such a way that it is likely to be received by a retail customer.

Financial Promotion

As discussed in our article on CP25/41, QCDDs and SDDs are exempt from financial promotion restrictions under section 21 FSMA. As such, they do not require approval when communicated by someone that is not FCA-authorised.

However, as the FCA proposed in 2025, all other communications, including advertisements, relating to public offers and admissions of qualifying cryptoassets will be subject to the financial promotion restriction. While the final rules are therefore largely the same, CRYPTO 3.12 does not now have separate requirements for communications with retail investors: they apply equally to all in-scope advertisements. In addition, hyperlinks to the relevant QCDD or SDD are now only required on written electronic requirements, and advertisements only need to be updated after an SDD is published if they become misleading. Any amendments to an oral advertisement do not need to be disseminated in the same way as the original advertisement.

What this means

While the final rules are similar to those consulted on, there are several changes that firms need to review to inform their immediate next steps. In particular, the removal of the "fungibility" exemption for preparing a QCDD will impact a number of issuers, as will the changes to the admissions and disclosure processes.

Next steps

At present, the FCA plans to consult on proposed deferral arrangements under the A&D regime in September 2026, when the wider crypto regime comes into force. This will likely include a six-month deferral period for the application of A&D requirements to help mitigate operational disruption for firms and wider disruption in the market, although this is subject to change.