The FCA has published its Feedback Statement on tokenisation in UK wholesale financial markets, following the joint FCA and Bank of England Call for Input published in May. The feedback will inform a forthcoming Tokenisation Roadmap for the digitalisation of wholesale markets, which the FCA expects to publish later this year.
Alongside this, the FCA has opened a separate Call for Input on tokenised gold, seeking evidence on the opportunities, risks and possible regulatory issues arising from tokenisation of gold in UK markets. For firms involved in wholesale markets, custody, settlement, collateral, tokenised securities or digital asset infrastructure, the publications give a useful indication of the FCA's likely near-term priorities.
The key feedback points were:
- The market is asking for pace and certainty. Firms called for faster progress and clearer timelines, including on the prudential treatment of tokenised assets, CASS, synchronisation and tokenised deposits.
- There is pressure to move beyond pilots. Respondents supported a shift from sandboxes and proofs of concept towards production, scale and permanence, including a long-term model for settling digital securities after the Digital Securities Sandbox and further Digital Gilt Instrument issuances.
- Collateral is the priority use case. Tokenised collateral was the most frequently raised issue. Respondents sought clarity on eligibility and collateral mobility, while tokenised money market funds were also highlighted, particularly by buy-side firms.
- Settlement finality is central. Firms want assurance that blockchain-settled transactions can benefit from insolvency protections under the UK settlement finality regime. Some respondents also asked for stablecoins to be permitted as settlement assets.
- Equivalent treatment needs more detail. Respondents sought further clarity on the FCA's position that tokenised and non-tokenised assets should be treated the same where legal rights are identical and underlying risks are comparable. They also asked for more detail on the application of the Bank of England's Dear CEO letter.
- Custody is likely to remain a key workstream. Most respondents favoured applying CASS 6 to the safeguarding of relevant specified investment cryptoassets, with targeted overlays for blockchain-specific risks such as private key management.
- Interoperability is not just a technology issue. Respondents pointed to the need for legal, regulatory and cross-jurisdictional interoperability, including alignment with non-UK regulators on settlement and collateral, alongside industry standards and technical interoperability.
- Accountability may affect decentralised models. Respondents broadly supported the FCA's suggestion that there should be an accountable person for all regulated activities, although some noted that this could create practical challenges for firms using decentralised finance technology.
Tokenised gold: what is the FCA looking at?
The FCA's Call for Input on tokenised gold follows industry feedback identifying gold as a potential tokenisation use case. The FCA is seeking evidence on whether tokenisation could improve the way gold is traded, transferred, pledged and held in UK markets while maintaining market integrity and appropriate protections.
Potential benefits include more efficient transferability, improved use of gold as wholesale collateral and support for new investment products. The FCA is also considering how tokenised gold could interact with existing market infrastructure and whether industry-led standards could support interoperability.
The FCA notes that tokenised gold may interact with different regulatory regimes depending on the structure, use case and participants involved. In particular, it is considering whether uncertainty around the collective investment scheme and alternative investment fund perimeters may affect the development of some models.
Depending on the evidence received, the FCA may consider a range of responses, including further regulatory clarity, guidance, a bespoke regime or other action. The deadline for responses is 23 October 2026.
Next steps
The FCA also plans to consult on the custody of relevant specified investment cryptoassets in the first half of 2027. The Roadmap is expected to explain how the FCA's work will interact with tokenisation initiatives led by HM Treasury and the Wholesale Digital Markets Champion, including work on interoperability, repo and collateral.
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