GBBC Response to FCA CP25/41 – Admissions & Disclosures and Market Abuse Regime for Cryptoassets

GBBC has submitted its response to the FCA’s CP25/41. We welcome the FCA’s work to develop a more consistent admissions, disclosure and market abuse framework for cryptoassets, and we broadly support the direction of travel.

Our response sets out targeted recommendations, including: a standardized presentation structure and CRYPTO 3.2 checklist for admission criteria; due diligence expectations anchored to existing obligations and clearer triggers for renewed diligence; a QCDD/SDD model supported by a minimum core dataset and update design that prevents “disclosure sprawl”; and an FCA-owned disclosure repository built as API-enabled, version-controlled operational infrastructure.

On market integrity, we support “touchpoint-based” on-chain monitoring calibrated to risks that directly connect to a platform, and recommend against using a revenue threshold as the gating condition for applying on-chain monitoring requirements. We also support cross-platform information sharing to detect market abuse migrating across venues, and recommend industry-led interoperable mechanisms for secure, consistent sharing.

Read the full response here.