FCA publishes Consultation Paper for proposed rules regarding admissions & disclosures for cryptoassets

On 16 December 2025, the Financial Conduct Authority (the “FCA”) published a consultation paper on Regulating Cryptoassets: Admissions & Disclosures and Market Abuse Regime for Cryptoassets. This Consultation Paper follows on from the discussion paper (DP24/4) published in December 2024 (which we covered here). In this Consultation Paper, the FCA sets out its proposed rules and guidance for admissions & disclosures (“A&D”) and the market abuse regime for cryptoassets.

The Consultation Paper is part of the FCA’s push to publish its final rules for the cryptoasset industry before the new cryptoasset regulatory regime comes into force on 25 October 2027. The Consultation Paper has been published alongside two other consultation papers, one on the approach to regulating cryptoasset activities (CP25/40), and another on prudential requirements for cryptoasset firms (CP25/42).

The FCA is welcoming feedback on the Consultation Paper by 12 February 2026. Below, we summarise some of the key changes introduced by the Consultation Paper in relation to the A&D regime and how they may impact businesses operating within this space. We will summarise the changes to the market abuse regime for cryptoassets in a future article.

The A&D Regime

As expected, the A&D regime will apply to the admission to trading of qualifying cryptoassets on cryptoasset trading platforms (“CATPs”) that allow retail participation, and to public offers to retail investors made under the new cryptoasset regulations proposed by the FCA (see our summary here). The regime will apply to the following designated activities:

• Offering a qualifying cryptoasset to the public in the UK;
• Disclosing information about an offer of a qualifying cryptoasset;
• Disclosing information relating to a qualifying stablecoin offered to the public in the UK;
• Requesting or obtaining the admission of a qualifying cryptoasset to trading on a CATP;
• Disclosing information about an admission, or proposed admission, of a qualifying cryptoasset to trading on a CATP; and
• Admitting a qualifying cryptoasset to trading on a CATP.

The majority of A&D rules will apply directly to the operators of CATPs which are authorised in the UK (see our article here about the territorial scope of the UK regime for CATPs). There will also be a separate regime for UK-issued stablecoins, which we discuss later in this article. In relation to the A&D regime, while the FCA is continuing with most of its proposals from the Discussion Paper, there are a few refinements, clarifications, and modifications, which we have set out below.

Eligibility and Admission to Trading

Following feedback from the Discussion Paper, the FCA has now proposed that, rather than prescriptive rules, CATPs must instead establish risk based and objective admission criteria for assessing whether a proposed admission to trading for qualifying cryptoassets (other than UK-issued qualifying stablecoins) is likely to be detrimental to the interests of retail investors. The criteria must be approved by the CATP’s governing body, published on the CATP’s website, and periodically reviewed and updated. The proposal requires rejection where admission is likely to be detrimental to retail investors, although the FCA clarifies that there is no requirement to publish individual rejection decisions. CATPs should start to consider the scope of criteria that they should be using and how the governance in relation to this will work in practice. 

Due Diligence Requirements

The FCA is proceeding with its proposals to set rules requiring CATPs to conduct due diligence before admitting or offering a qualifying cryptoasset to trading. Specifically, CATPs should conduct their due diligence and include the factors listed in the CATP’s own admission criteria. The Consultation Paper includes non exhaustive examples of checks CATPs can perform for due diligence purposes, such as:

• Identity of the key persons associated with the offer and admission;
• Purpose and functionality of the qualifying cryptoasset;
• Tokenomics, supply structure and lockup arrangements;
• Project roadmap and development status; and
• Risk disclosures.

Qualifying Cryptoasset Disclosure Documents, Supplementary Disclosure Documents, and Key Information Documents

The FCA has confirmed that CATPs may only admit or offer a qualifying cryptoasset on a UK authorised CATP where a Qualifying Cryptoasset Disclosure Documents (“QCDD”) has been produced. While the legislation sets out what is needed in a QCDD, the FCA has also supplemented this by setting out requirements and guidance on what must be included in a QCDD from their perspective. The FCA states that a QCDD should include, in summary, information on the governance mechanisms and characteristics of the qualifying cryptoasset, its operational and cyber resilience, its underlying technology and protocols, its ownership and its trading performance and history. However, a QCDD is not required where the relevant qualifying cryptoasset is (i) a UK-issued qualifying stablecoin, (ii) fungible with qualifying cryptoassets already admitted to trading on the particular CATP, or (iii) only available to qualified investors.

The FCA has further proposed that CATPs must require a Supplementary Disclosure Document (“SDD”) if a significant new factor, material mistake, or material inaccuracy arises post QCDD publication that could be material to a person considering a purchase or subscription of a cryptoasset. This is consistent with the treatment of prospectuses under the Public Offers and Admissions to Trading Regulations 2024 (“POATR”) regime.

In addition, the FCA is proposing a two page ‘summary of key information’ to be included in each QCDD. The FCA will not publish a template but expects the content, format, and presentation of the summary of key information to be industry led, unlike in traditional markets where the FCA produces templates. Summary documents are common in the traditional financial services markets and are a helpful tool for investors, albeit a new requirement for existing CATPs.

Filing and Publication

The FCA continues to propose that CATPs must file approved QCDDs and SDDs with an FCA owned centralised repository (e.g. the UK's National Storage Mechanism (“NSM”) which is the official repository for regulated financial information) before trading. In addition, CATPs must also publish QCDDs and SDDs on their own websites. The FCA is no longer mandating a specific machine readable format for these documents. The FCA also no longer requires CATPs to check the NSM before accepting a new QCDD, instead, the FCA believes that an industry led standardisation effort offers a more proportionate way to promote alignment and ensure comparability of disclosures across platforms.

Responsibility and Liability

In line with the FCA’s approach in the Discussion Paper, the person seeking admission of the qualifying cryptoasset and preparing their own QCDD or SDD will be responsible and liable for its content, along with those accepting responsibility in these documents. Where a QCDD or SDD prepared by a third party is used, the person seeking admission is still liable. For intermediaries offering qualifying cryptoassets and preparing a QCDD, responsibility for its content remains unless it is prepared by another party. If there’s no identifiable issuer (for example, Bitcoin), the liability for disclosure attaches to the party that is responsible for the QCDD/SDD, which could for example be the CATP admitting the cryptoasset to trading on its own behalf. Firms should take due consideration in relation to liability and ensure they act appropriately.

Consumer Duty and Protected Forward Looking Statements

The FCA has decided that the Consumer Duty will not apply to activities relating to public offers and admissions to trading of qualifying cryptoassets. In relation to protected forward looking statements (“PFLS”), these will now be voluntary for QCDDs and SDDs,  as opposed to mandatory, which is a welcomed development. PFLS’ carry a modified liability regime to encourage meaningful forward looking disclosure. The modified liability standard is based on recklessness/dishonesty and provides a conditional exemption from the usual compensation liability where the PFLS conditions are met. The FCA proposed rules for PFLS’ will broadly follow the approach under the POATRs regime, for existing investments, adapted for the cryptoasset context.

Transitional Arrangements

The FCA has clarified that it is considering transitional arrangements as part of the wider cryptoasset regime, in relation to these enhanced disclosures, and will provide clarity in a future consultation.

Disclosures for UK-Issued Qualifying Stablecoins

The disclosure regime for UK-issued qualifying stablecoins will be different than those for other types of cryptoassets.

The FCA proposes that UK-issued qualifying stablecoin issuers must provide the following two forms of disclosures:

• Disclosures in the form of information on the issuer’s website, available to holders, prospective holders and the general public; and
• A UK-issued qualifying stablecoin QCDD, available on the issuer’s website and on an FCA-owned centralised repository, such as the NSM.

However, there will be differences regarding the content requirements of the QCDD (e.g., no summary will be required) and the PFLS provisions will not apply. The FCA does not propose to apply rules around issuing voluntary PFLS to issuers of UK qualifying stablecoins or requiring a QCDD summary, as the above disclosures should be sufficient.

The FCA also proposes that CATPs can admit a UK-issued stablecoin using the issuer’s permalink (i.e bespoke URL) QCDD without amendments. While CATPs may seek additional information, they cannot charge further due diligence fees to issuers or third parties requesting admission of UK-issued qualifying stablecoins. CATPs will have the right to reject admission, detailing their reasons to the issuer and the FCA; however, they cannot reject based on the QCDD’s accuracy or quality. Where third parties are seeking the admission of a UK-issued qualifying stablecoin to a CATP, issuers remain responsible and liable for the content of documents, as they are best placed to keep the information up to date.

Issuers of UK-issued qualifying stablecoins will be able to make representations to CATPs if they wish to oppose the admission of their stablecoin to trading (for example, where a third party has made a request to a CATP to admit the relevant UK-issued qualifying stablecoins).

The FCA is not proposing to apply the exclusions to the Consumer Duty for the A&D regime to UK-issued stablecoin QCDDs and therefore the consumer duty may apply - the FCA will consult on the position regarding the Consumer Duty in January 2026.

Concluding Remarks

The FCA’s Consultation Paper marks a significant step towards finalising the regulatory framework for cryptoassets in the UK ahead of the regime coming into force in October 2027. The proposals set out detailed rules for the A&D regime, focusing on protecting retail investors while providing flexibility for CATPs through risk based admission criteria, due diligence obligations, and structured disclosure documents.

The Consultation Paper also clarifies responsibilities and liabilities for parties involved in admissions, distinguishes rules for UK-issued qualifying stablecoins, and introduces proportionate mechanisms for filing, publication, and ongoing disclosure updates.

Overall, the FCA’s proposals aim to balance investor protection with industry led standardisation, ensuring transparency, accountability, and market integrity in the rapidly evolving cryptoasset sector. Stakeholder feedback by 12 February 2026 will be crucial in shaping the final rules and transitional arrangements for the new regime.

Co-authored by William Gower, Trainee Solicitor