It brings us ever closer to the clarity needed ahead of firms seeking new regulatory permissions from the autumn, and our response focuses on the most important questions remaining to ensure a regime which underpins the safe, sustainable introduction and adoption of UK stablecoins.

This includes:

• ensuring that banks, merchants or ancillary service providers within stablecoin payment flows are not required to obtain permissions related to arranging, dealing or safeguarding

• confirming that technical service provision of underpinning infrastructure and software such as APIs is not deemed to be issuing, arranging or dealing in cryptoassets

• removing stablecoin communications such as balance updates or transaction confirmations from the scope of financial promotions activity

We also emphasise the ongoing balance required in the treatment of overseas-issued stablecoins. Whilst industry and regulators share a common ambition to grow the domestic market in GBP stablecoin, the reality today is that overseas-issued stablecoins form the majority of the market and should be included in exemptions e.g. to arranging and dealing where this facilitates adoption, payment flows, productive use cases for businesses, and stricter financial promotions rules subject to an appropriately defined criteria to ensure their stability and redemption.

It must be acknowledged that subsequent to the launch of this consultation, HM Treasury have published a draft SI intended to amend the Cryptoasset Regulations. Throughout our response we have provided feedback on the FCA’s proposals, as well as highlighting their interaction with the proposed legislative amendments as appropriate. Given there is significant potential for the draft SI to materially alter the perimeter position, it is essential that the final guidance and the legislative framework it describes are fully aligned before the application window for firms opens on 30 September 2026.