GBBC Response to FCA CP25/40 – Regulating Cryptoasset Activities

GBBC has submitted its response to the Financial Conduct Authority’s CP25/40. We welcome the FCA’s continued engagement and broadly support the direction of travel towards a workable UK regime that protects consumers and supports fair, orderly markets.

Our response recommends targeted calibration so the framework does not unintentionally worsen outcomes for UK users by restricting access to global liquidity and weakening price discovery. We therefore recommend: auditable, outcomes-based criteria for “sufficient UK presence”; a workable best execution approach where UK-authorised venues or price sources do not exist at scale (including the use of reliable non-UK benchmarks under clear criteria); a clear menu of recognised conflict mitigants; and transparency and recordkeeping anchored to consistent data standards, including a recognised asset identifier.

We also encourage a clear line between custodial and non-custodial models for lending/borrowing and staking, and early coordination with HMRC on potential CARF interactions to avoid duplicative reporting outcomes.

Read the full response.