The FCA has introduced a regulatory framework for firms facilitating the buying, trading and holding of cryptoassets in the UK. Aimed at establishing the UK as a stable, competitive global hub, the regime balances strict regulatory certainty with space for corporate innovation. 

Under these rules, firms must meet rigorous financial resilience standards, including capital mandates and stress testing, alongside new market integrity protections targeting insider trading and market manipulation.

Alongside this, after a consultation period, the Bank of England simplified capital requirements for stablecoin firms and tailored trading rules to better align with practical crypto market operations. The regime holds firms to standards similar to traditional financial providers without removing inherent investment risks.

Following the passing of legislation in February 2026, the rules will officially take effect on 25 October 2027. Mandatory FCA authorisation is required for trading platforms, intermediaries, custodians, stablecoin issuers and staking firms. The application window for these stakeholders runs from 30 September 2026 to 28 February 2027.

ICAEW has welcomed the FCA’s strategy, emphasising that long-term trust in tokenised markets relies heavily on establishing clear compliance frameworks for financial reporting, taxation and independent assurance alongside base regulation.

What this means for accountants and auditors

The FCA’s final cryptoasset regime brings many crypto firms into full FCA authorisation from 25 October 2027, replacing the current anti-money laundering registration regime.

While the rules are primarily aimed at crypto firms, they are expected to increase demand for accounting and assurance services across governance, safeguarding of client cryptoassets, prudential requirements, regulatory reporting and internal controls.

Accountants and auditors will also play an increasingly important role in assessing the existence, ownership and valuation of cryptoassets, the effectiveness of private key and custody controls, and the integrity of transaction records.

As crypto firms become subject to a regulatory framework more closely aligned with traditional financial services, demand for specialist expertise in cryptoasset accounting, assurance and regulatory compliance is likely to grow.

Setting out the future of tokenisation

Alongside the announcement, the FCA and BoE issued a call for input regarding safeguarding requirements for Specified Investment Cryptoassets (SICs).

ICAEW urges the FCA to let custody characteristics drive regulations rather than superficial token labels. ICAEW proposes a ‘tokenisation model applicability matrix’ to categorise holdings across three distinct architectures, especially for CASS accountants and auditors. This would include categorising tokenised assets into non-digitally native ‘digital twins’ to represent off-chain assets requiring verification; digitally native assets issued directly on ledger and secured via depositaries or private keys; and tokenised records representing entitlements or bilateral collateral arrangements.

Polly Tsang, Senior Financial Services Regulatory Manager, ICAEW, says, “Tokenisation has the potential to transform wholesale financial markets, but innovation must be underpinned by trust.”

“As tokenised assets move into the regulatory perimeter, it’s vital that we embed the hard-won lessons of the 2008 financial crisis by ensuring robust safeguarding and custody arrangements that deliver equivalent protections for market participants,” Tsang explains.

To upgrade CASS 6 effectively, ICAEW suggests these four recommendations:

• Books and records: firms must implement internal sub-ledgers synchronised with distributed ledgers to track client entitlements at the wallet or address level.
• Reconciliations: incorporate CASS 17's ‘resource and requirement method’ for on-chain verification when firms self-custody. Firms should clearly define ‘settlement finality’ given that distributed ledger transfers are not instantaneous.
• Means of access: integrate strict lifecycle protections for cryptographic private keys and shards, accounting for multi-party computation.
• Insolvency recovery: expand CASS Resolution Packs (CASS 10) so insolvency practitioners can immediately identify if an asset is tokenised or traditional, ensuring efficient distribution.

Chris Woolard, the government’s Wholesale Digital Markets Champion, has also issued his first report on the digitalisation of UK markets, outlining the sector’s progress so far, and exploring the regulatory, tax and legal treatment of tokenised assets. ICAEW contributed to the report, advising on the importance of tax and accounting and leading to the set-up of a future working group covering the same topics.