Trilógia konzultácií FCA o kryptomenách: praktický sprievodca

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 framework for cryptoassets ever produced by a major financial regulator — and firms operating in the UK market need to understand exactly 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, in essence, all of them. The scope covers trading platforms, intermediaries, lending and borrowing services, staking providers and even certain decentralized finance activities. Larger platforms — those with average annual revenue exceeding GBP 10 million — face additional obligations, including non-discriminatory access rules and stricter transparency requirements.

For retail lending specifically, the FCA proposes mandatory overcollateralization requirements. This is a direct response to the wave of crypto lending platform collapses in 2022–2023, and signals that the regulator has studied the sector's failure modes in detail.

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 qualifying cryptoasset disclosure documents — essentially prospectuses — including a two-page summary highlighting the key risks. The market abuse regime prohibits insider dealing and market manipulation, with large platforms required to monitor on-chain activity to detect suspicious patterns.

This is where the regulation becomes genuinely groundbreaking. Monitoring on-chain activity for market abuse presents a technical challenge with no direct precedent in traditional finance. In effect, the FCA is requiring platforms to develop blockchain analysis capabilities that