GBBC Response to FCA CP25/25 – Discussion Chapters: Consumer Duty, Conduct of Business, Product Governance, and Access to Redress
Published
GBBC has submitted its response to the Financial Conduct Authority’s (FCA) Consultation Paper CP25/25, covering the Discussion Chapters (6 and 7).
This section of the consultation sets out how existing FCA Handbook frameworks — including the Consumer Duty, Conduct of Business (COBS), and Product Governance (PROD) — could apply to newly regulated cryptoasset activities.
Our response recognizes the FCA’s efforts to integrate cryptoassets into the mainstream regulatory perimeter in a way that ensures consistent consumer protection while maintaining proportionality for innovative firms.
Read the full response here.
Key themes in our response include:
Support for applying the Consumer Duty in full, with proportionate sector-specific guidance.
Agreement that PROD should not apply directly to cryptoassets given the absence of traditional issuer–distributor structures.
Endorsement of the FCA’s proposal to disapply Distance Marketing (COBS 5) and rely on Consumer Duty outcomes instead.
Recognition that financial promotions for UK-authorized stablecoins should be de-frictioned, while ensuring transparent risk warnings for non-UK-issued coins.
Support for converting the 12 appropriateness-test matters from guidance to rule, with calls for clarity on practical implementation and proportionality.
Emphasis on ensuring FOS readiness and definitional consistency across FCA, HM Treasury, and Law Commission frameworks to avoid regulatory friction.
GBBC welcomes the FCA’s principles-based approach and its commitment to proportionate, outcomes-focused regulation. We stand ready to assist the FCA in refining guidance for implementation.