The UK Financial Conduct Authority (FCA) has opened two consultations aimed at clarifying how DeFi and crypto activities will be treated under the forthcoming regulatory regime. Guidance Consultation GC26/7 asks for input on how firms that use or provide access to decentralised finance protocols should meet existing obligations, focusing on operational resilience (SYSC 15A), compliance functions (SYSC 6) and the Money Laundering Regulations (MLRs). A parallel paper, CP26/36, addresses exclusions from the regulated perimeter.
Published on October 21, 2026, the consultations close on November 18, 2026, with final guidance expected in January 2027. The FCA opened its authorization gateway on September 30, 2026; applications are accepted until February 28, 2027, and the full regime is scheduled to take effect on October 25, 2027. The regulator stresses that use of automation, smart contracts or distributed ledgers does not automatically exempt activity from authorization — obligations will depend on the functions performed and specific arrangements. The FCA intends a case-by-case approach: where there is an identifiable controlling entity the rules can apply, whereas genuinely decentralised activity may fall outside its remit. The consultations target intermediaries — firms between users and protocols — and industry responses will help determine where the line is drawn.