GBBC Submits Response to UK FCA CP25/15 – Prudential Regime for Cryptoasset Firms

GBBC has submitted its response to the FCA’s CP25/15 Consultation Paper, which sets out the proposed prudential requirements for cryptoasset custodians and stablecoin issuers authorised under FSMA.

We support the FCA’s objective of ensuring a robust, credible prudential framework for the UK cryptoasset sector. However, we raise concerns about the cumulative complexity of the proposed regime and its potential impact on proportionality, competitiveness, and legal certainty.

Key points in our submission:

🔹Recommend simplifying the interaction of PMR, FOR, K-factors, BLAR, and ILAR 🔹Urge FCA to clarify the scope of capital application to avoid capturing group-wide operations 🔹Oppose the statutory trust requirement in favour of outcome-based safeguarding standards 🔹Raise legal uncertainty around trust formation and recognition in non-UK jurisdictions 🔹Call for proportional adjustments for smaller and decentralised firms 🔹Suggest alignment with CASS 6/CASS 7, EMRs, and international standards

Our response is intended to support the development of a workable and internationally competitive framework by highlighting areas where greater clarity, proportionality, or flexibility could enhance the effectiveness of the regime.

We thank the FCA for its industry consultation and its continued willingness to work with the business and innovation community to shape a proportionate and forward-looking regime.

View the full submission here.

GBBC continues to support safe, well-regulated growth of the UK’s cryptoasset ecosystem.