Overview

• The consultation proposes a ‘same risk, same regulatory outcome’ approach, applying PRIN, SYSC, COND, GEN, SUP, COCON and FIT to cryptoasset activities with tailored adjustments.
• The Senior Managers & Certification Regime would extend to crypto firms with Core/Enhanced classifications, management responsibility maps for larger firms and certification of relevant staff including client‑facing roles.
• Operational resilience rules under SYSC 15A would cover all crypto firms, requiring impact tolerances, service mapping and scenario testing, with permissionless DLT not treated as outsourcing under SYSC 8.
• Crypto firms would be subject to the full financial crime framework for Part 4A FSMA firms, including AML systems and controls and a designated Money Laundering Reporting Officer.
• The FCA is consulting on applying COBS and PROD, exploring whether to apply the Consumer Duty or craft tailored protections, and seeking views on ESG rules without proposing crypto‑specific sustainability disclosures.