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FCA and the Bank of England set out approach to joint regulation of systemic stablecoin issuers

AI Analysis

Executive Summary

The FCA and Bank of England have set out a joint supervisory model for **systemic stablecoin issuers**, clarifying how firms will move from FCA-only oversight to joint regulation once HM Treasury designates them as systemic. This matters because UK‑based and non‑UK stablecoin issuers used for payments will face distinct prudential, conduct and structural requirements depending on whether they are non‑systemic (FCA only) or systemic (Bank of England plus FCA), with a managed transition between regimes.

What Changed

  • - UK stablecoin issuance will be subject to a dual regulatory regime: non‑systemic stablecoins will be supervised solely by the FCA, while systemic stablecoins used for payments will be jointly regulated by the Bank of England and FCA once recognised
  • Issuing a qualifying sterling‑denominated stablecoin in the UK will become a regulated activity, requiring FCA authorisation for non‑bank issuers and bringing them within the FCA’s prudential, conduct and safeguarding rules until any systemic designa
  • HM Treasury will apply statutory systemic tests under the Banking Act (e.g. scale, interconnectedness, substitutability, impact on confidence in sterling) to decide whether a stablecoin payment system or service provider is systemic, informed by advi
  • Once recognised as systemic, stablecoin issuers and systemic payment system providers will fall under the Bank of England’s remit under the Banking Act 2009, including powers to obtain information, issue principles and codes of practice, require rule
  • Systemic sterling‑denominated stablecoin issuers will be required to maintain backing reserves equal to all outstanding coins, with backing assets held on statutory trust in the UK and ring‑fenced from the issuer’s general estate to protect coinholde
  • The Bank of England’s policy statement and draft Code of Practice propose that backing assets be held as interest‑bearing short‑term UK government debt (up to 70%) plus central bank deposits (at least 30%), with the composition calibrated to support

Suggested Considerations

  • Map all existing and planned sterling‑denominated stablecoin products against the UK’s systemic and non‑systemic regimes and assess whether their intended use in UK payments could trigger HM Treasury systemic recognition.
  • Initiate or update FCA authorisation applications for stablecoin issuance and cryptoasset custody activities, ensuring business models, governance and safeguarding arrangements align with CP25/14 and the forthcoming stablecoin regime.
  • Design and implement reserve‑management frameworks capable of maintaining backing assets equal to outstanding coins, in the proposed 70/30 mix between short‑term UK government debt and Bank of England deposits, with appropriate stress testing and liquidity risk oversight.
  • Establish statutory trust and segregation structures for backing assets and liquid‑asset reserves, including appointing UK‑authorised third‑party custodians and aligning documentation with FCA client‑asset‑style protections and coinholder proprietary claims.
  • Develop capital planning processes and ICAAP‑style assessments to meet the Bank of England’s requirements for capital against general business risk and dedicated reserves for financial risk and wind‑down costs.
  • For non‑UK issuers with UK‑facing sterling stablecoins, plan and implement the establishment of a licensed UK subsidiary, including governance, risk management, booking models and onshoring of backing assets to meet UK systemic regime expectations.

Key Dates

10 November 2025
- Bank of England consultation paper issued on the proposed regulatory framework for sterling‑denominated systemic stablecoins and systemic payment system operators
Late 2026
- Bank of England intends to finalise the Code of Practice and supporting materials by the end of 2026, confirming the prudential and structural regime for systemic stablecoins
From 2026
- UK introduces new regulatory authorisation requirements for stablecoin issuers, including FCA authorisation for qualifying issuance and custody activities
10 February 2026
- Consultation period closes for the Bank of England’s systemic stablecoin regime proposals
June 2026
- Bank of England publishes its policy statement and draft Code of Practice for systemic stablecoin issuers, setting out detailed prudential and backing‑asset rules and confirming joint work with the FCA on an end‑to‑end regime
22 September 2026 DEADLINE
- Deadline for stakeholder feedback on the Bank of England’s draft Code of Practice and supporting materials for systemic stablecoin issuers

Compliance Impact

Non‑compliance with the emerging stablecoin regime may result in refusal of authorisation, enforcement directions, restrictions on issuance volumes, and potential wind‑down of stablecoin products, with significant balance‑sheet, reputational and operational consequences. Systemic issuers face heightened supervisory scrutiny and Banking Act enforcement powers, making early alignment with prudential

Who is Affected

UK‑authorised non‑bank firms that issue sterling‑denominated stablecoins used for everyday retail and corporate payments.Non‑UK stablecoin issuers whose sterling‑denominated coins are or may become widely used in UK payments and could be designated as systemic by HM Treasury.UK payment system operators and other service providers in the stablecoin supply chain that may be recognised as systemic due to their role in systemic stablecoin payment systems.UK banks and wholesale market participants using stablecoins as settlement assets in core wholesale financial markets, particularly where those stablecoins may be recommended for systemic recognition through the Digital Securities Sandbox.UK‑authorised custodians and other infrastructure providers involved in safeguarding backing assets and reserves for systemic stablecoin issuers.FCA‑authorised firms engaged in stablecoin issuance or cryptoasset custody under the FCA’s non‑systemic regime (including payment providers and crypto exchanges offering UK‑facing stablecoin products).

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Summary

The Bank of England and the FCA have published a joint approach setting out how they and where relevant other authorities will work together to regulate systemic stablecoin issuers in the UK.It explains how responsibilities will be split between the authorities, and how UK stablecoin issuers may move from FCA supervision to joint regulation once recognised as systemic by HM Treasury.The approach aims to provide clarity and predictability for firms as the market develops.Read the paper

Relevant Firm Types

FintechCrypto ExchangeBankPayment Provider
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