On 14 October 2025, the UK's Financial Services Authority ("FCA") published Consultation Paper 25/28 on “Progressing Fund Tokenisation” (the "CP"), which it claims will be a key component of future financial services. The CP is addressed to authorised funds, where the FCA regulates both the fund and manager, but elements will be of interest to non-authorised funds where only the manager is FCA-regulated.
The FCA’s proposals include:
- Guidance on operating tokenised fund registers under current FCA rules through the UK Blueprint model (the aim of which is the operation of the UK funds industry using distributed ledger technology through the full investment value chain).
- A streamlined, alternative dealing model for fund managers to process buying and selling of units in authorised funds, whether traditional or tokenised.
- A roadmap to advance fund tokenisation and address key barriers like using public blockchains and settling transactions entirely on the blockchain.
- A discussion on how tokenisation models could evolve and how regulation may need to change.
The FCA will review the feedback and develop final regulatory requirements for publication in a Policy Statement, expected in the first half of 2026.
This consultation follows hot on the heels of another published on 17 September 2025, in the which FCA seeks feedback on its proposals on the minimum standards that crypto asset firms will be required to comply with. Unsurprisingly these minimum standards mirror many requirements for traditional financial firms, including those relating to operational resilience and systems and controls to prevent financial crime. The FCA is also seeking feedback on the extent to which consumer protections applying to securities should apply to crypto, in particular those under the Consumer Duty the ability to seek redress from the Financial Ombudsman Service. For our note on this consultation see here.
The FCA is expected to publish rules on both counts during 2026.
