Einblick in die Krypto-Konsultationstrilogie der FCA: Ein praxisnaher Leitfaden

If the UK government's December 2025 announcement was the headline, then 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 addresses the most fundamental question: which crypto activities require FCA authorization? The answer, in essence, is 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 an average annual revenue above £10 million — face additional obligations, including rules on non-discriminatory access 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 signals that the regulator has carefully examined the industry's failure patterns.

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

This is where the regulation becomes truly novel. Monitoring on-chain activity