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5 May 2026

FCA Policy Statement On Fund Tokenisation: What You Need To Know

KM
Katten Muchin Rosenman LLP

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On 30 April 2026, the Financial Conduct Authority (“FCA”) published a policy statement (“PS26/7”), setting out rules and guidance to support the adoption of fund tokenisation in the UK.
United Kingdom Finance and Banking
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On 30 April 2026, the Financial Conduct Authority (“FCA”) published a policy statement (“PS26/7”), setting out rules and guidance to support the adoption of fund tokenisation in the UK. The policy statement follows an earlier FCA consultation paper published in October 2025 (“CP25/28”). 

PS26/7 applies directly to UCITS management companies, UK Alternative Investment Fund Managers managing authorised funds, and depositaries of authorised funds. The rules and guidance set out in PS26/7 came into force with immediate effect on 30 April.

Key Changes from the Consultation

The FCA received 64 responses to CP25/28, with apparent near-universal support for its ambition to accelerate fund tokenisation. The final guidance has been introduced largely as proposed, but the FCA has made several noteworthy changes in response to industry feedback:

  • On-chain records as primary books and records. Firms need not maintain a full “mirror” off-chain record of unit deal transactions, provided appropriate resiliency plans are in place.

  • Multi-chain flexibility. Units within a class may be issued on multiple blockchains, so long as the underlying rights of holders and the nature of charges taken from scheme property remain the same.

  • Client money account proposal dropped. The FCA will not proceed with requiring unattributable payments to be placed into a client money account, opting instead for enhanced reconciliation requirements.

  • Principal dealing under D2F permitted. Fund managers will not be prohibited from dealing as principal in units of a fund using the “Direct to Fund” (or “D2F”) model, reversing the original consultation proposal.

  • Anti-money laundering. The FCA will not proceed with including some of the anti-money laundering guidance, given it would otherwise repeat firms’ existing obligations.

Looking further ahead, the FCA has set out a roadmap for the development of “composable finance” (i.e., modular, distributed ledger technology-based investment processes) and encourages firms exploring tokenised portfolio management to engage with the FCA and take advantage of its open-door policy.

PS26/7 can be found here. Further information on CP25/26 can be found here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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