Publicado originalmente por Taylor Wessing em 2026-01-12
Por dentro da Trilogia de Consultas sobre Cripto da FCA: Um Guia Prático
Três documentos de consulta publicados pela FCA no fim de 2025 definem as regras detalhadas para empresas de cripto do Reino Unido — de plataformas de trading ao abuso de mercado. Analisamos as principais propostas e os prazos mais importantes.
If the UK government's December 2025 announcement was the headline, the three consultation papers published by the Financial Conduct Authority are the fine print. Together, CP25/40, CP25/41 and CP25/42 form the most detailed regulatory blueprint for cryptoassets ever produced by a major financial regulator — and firms operating in the UK market need to understand what they contain.
CP25/40: The Activities Framework
The first paper tackles the broadest question: which crypto activities will require FCA authorization? The answer is, essentially, all of them. Trading platforms, intermediaries, lending and borrowing services, staking providers and even certain decentralized finance activities fall within scope. Larger platforms — those with average annual revenue above £10 million — face additional obligations, including non-discriminatory access rules and enhanced transparency requirements.
For retail lending specifically, the FCA proposes mandatory over-collateralization requirements. This is a direct response to the wave of crypto lending platform collapses in 2022-2023, and it signals that the regulator has studied the sector's failure modes closely.
CP25/41: Disclosure and Market Abuse
The second paper introduces requirements that will feel familiar to anyone who has worked in traditional securities markets. Issuers seeking admission to UK trading platforms must produce qualified cryptoasset disclosure documents — essentially prospectuses — including a two-page summary highlighting the key risks. The market abuse regime prohibits insider dealing and market manipulation, requiring major platforms to monitor on-chain activity for suspicious patterns.
This is where the regulation becomes genuinely groundbreaking. Monitoring on-chain activity for market abuse poses a technical challenge with no direct precedent in traditional finance. In practice, the FCA is requiring platforms to develop blockchain analytics capabilities that go well beyond current industry standards.
CP25/42: Prudential Requirements
The third paper sets out the financial reserves crypto firms must hold. Own funds requirements range from £75,000 to £750,000 depending on the activities carried out, with additional capital adequacy standards and disclosure obligations p
Source: Taylor Wessing