FinTech Global FS Regulatory Round-up - w/e 12 December 2025

In this edition we round up FinTech-related financial services regulatory developments for the week ending 12 December 2025.

This is the last edition of the round-up for 2025; the next edition will be published on 14 January 2026 covering all developments up to the week ending 9 January 2026.

ICYMI

• Major changes to UK Cyber Legislation: Cyber Security and Resilience Bill published in UK Parliament
• Navigating legal privilege issues when using AI
• Still in motion – Revisiting our Global FSR Outlook 2025

Global

BIS Innovation Hub: Project Leap Phase 2 – quantum-proofing payment systems

The Bank for international Settlements (BIS) Innovation Hub has published a report on the findings of Project Leap Phase 2, which tested post-quantum cryptography in an operational payment system. The project confirmed that post-quantum cryptography can be successfully implemented in payment systems.

The experiment replaced traditional digital signatures with post-quantum cryptography in an existing payment system, while sending liquidity transfers. It involved modifying numerous system components to ensure compatibility with updated cryptographic libraries. [11 Dec 2025] #Quantum #Crypto #Payments

GFIN report: Global regulatory perspectives on tokenisation

The Global Financial Innovation Network (GFIN) has published a report detailing the findings of its Tokenisation Project, which was co-led by the Jersey Financial Services Commission (JFSC) and the Central Bank of Bahrain (CBB). Throughout 2025, GFIN surveyed regulators worldwide, convened discussions at its annual general meeting, and hosted deep-dive roundtables and case studies with national authorities.

The findings reveal that that:

• no single model for tokenisation exists;
• design choices vary by jurisdiction, asset type and market infrastructure;
• regulators prefer evolution over revolution, adapting existing rules rather than creating new asset classes; and
• consumer protection and financial crime controls remain non-negotiable, even as innovation accelerates.

The report includes case studies, shared approaches and lessons learned. It does not set regulatory guidance or policy positions. Instead, it offers a global snapshot of how regulators are responding to tokenisation, and what this means for financial innovation. [11 Dec 2025] #Tokenisation #DigitalAsset

UK

FCA consults on new crypto regime

As part of its preparations for introducing a new UK crypto regime, the FCA has published three consultation papers (CPs).

• CP25/40: Regulating cryptoasset activities presents proposed rules and guidance for firms conducting regulated cryptoasset activities such as trading platforms, intermediaries (including cryptoasset lending and borrowing), staking and decentralised finance.
• CP25/41: Regulating cryptoassets – Admissions and disclosures and market abuse regime for cryptoassets covers: offerings to the public of qualifying cryptoassets that are or will be admitted to trading on a cryptoasset trading platform (CATP); the admission of qualifying cryptoassets to trading on CATPs; disclosure obligations relating to admissions to trading and the issuance of UK issued qualifying stablecoins; and requirements to prevent, detect and disrupt market abuse in cryptoasset markets.
• CP25/42: A prudential regime for cryptoasset firms sets out the FCA's proposed prudential regime for cryptoasset firms. The FCA is proposing to set out the regime in two new sourcebooks: COREPRU and CRYPTOPRU.

Responses for all three CPs are requested by 12 February 2026.

Alongside the consultations, the FCA has also published a note reporting findings of research into consumer behaviours and attitudes. Among other matters, the research suggests that consumer awareness of cryptoassets 'remains very high', that the use of credit to purchase cryptoassets has decreased since 2024, and that 25% of cryptoasset users would be more likely to invest if cryptoassets were more regulated in the UK.

A second note presents findings from an online experiment on regulating cryptoassets, which looked at how different levels of information about the regulatory status of cryptoassets and the protections that regulation may provide affected consumers' decisions and beliefs. Among the findings were: that informing consumers that cryptoassets are regulated increased demand; participants had a poor understanding of the potential protections of cryptoasset regulation; additional infomration helped, but had limited impact; and without providing additional information about the coverage of protections, regulation made participants less trusting of the FCA. [16 Dec 2025] #Crypto #DigitalAsset #Stablecoin

Draft SI: The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025

The draft Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 have been published. This proposed statutory instrument (SI) will create a regulatory framework for certain cryptoasset activities pursuant to powers conferred by the Financial Services and Markets Act 2000 (FSMA 2000).

The draft SI includes:

• the introduction of two designated activity regimes in relation to: public offers of qualifying cryptoassets and admissions to trading on qualifying cryptoasset trading platforms, and market abuse;
• amendments to the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 to specify certain activities relating to cryptoassets as regulated activities for the purposes of FSMA 2000; and
• amendments to the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 to specify certain activities relating to cryptoassets as controlled activities, and update to the definition of 'qualifying cryptoassets' for the purposes of section 21 of FSMA 2000.

The draft SI is accompanied by an explanatory memorandum. [16 Dec 2025] #Crypto #DigitalAsset

FSCP responds to FCA consultation on progressing fund tokenisation

The Financial Services Consumer Panel (FSCP) has published its response to the FCA consultation paper on progressing fund tokenisation (CP25/28). The FSCP reiterates that rules must evolve in line with emerging technologies, and that regulatory developments should prioritise consumer interests, particularly with regard to conflicts of interest, product suitability and the effectiveness of disclosures.

The FSCP supports the general direction of the proposals and broadly agrees with the proposed three phases of tokenisation. However, it emphasises the need for tailored, enforceable rules that reflect the unique risks and characteristics of tokenised funds.

The FSCP urges the FCA to 'remain open yet cautious, allowing innovation and experimentation while critically continuing to monitor risks, including systemic risks'. [12 Dec 2025] #Tokenisation #DigitalAsset

Regulatory Initiatives Grid – December 2025

The Financial Services Regulatory Initiatives Forum has published the 9th edition of the Regulatory Initiatives Grid which sets out the regulatory pipeline for financial services for the next two years. The edition includes 124 live initiatives. Of these, 45 are joint initiatives, where there is strong collaboration across regulators and government departments.

The grid also highlights work to support the Government's Financial Services Growth and Competitiveness Strategy. Key initiatives include supporting the creation of a UK issued stablecoin regime and the National Payments Vision. [11 Dec 2025] #Stablecoin #DigitalAsset #Payments

FCA: CP on digital pension planning tools

The FCA has published Consultation Paper 25/39 Adapting our requirements for a changing pensions market. The consultation includes proposals to provide support for consumers using digital pension planning tools and those making non-advised decisions to transfer Defined Contribution (DC) pensions. The FCA is proposing:

• a new regime for interactive digital pension planning tools for in-force pensions; and
• a new process to support non-advised consumers to make informed decisions about whether and where to transfer or consolidate DC pensions.

Responses are requested by 12 February 2026. [11 Dec 2025] #DigitalPension

MaPS: Latest report on pensions dashboards

The Money and Pensions Service (MaPS) has produced its latest progress update report on pensions dashboards. The report includes findings from the mid-point of Phase 1 consumer testing of the MoneyHelper Pensions Dashboard. The first phase of testing, involving low volumes, has seen good feedback on the dashboard's design and satisfaction with meeting user expectation. MaPS has also outlined how areas for refining the dashboard have been uncovered, and how it intends to continue testing going forwards. Three-quarters of pension records are now connected to the dashboards ecosystem. This is in addition to millions of State Pension records. [11 Dec 2025] #PensionsDashboards

FCA updates Prime Minister, Chancellor and Secretary of State on work to support economic growth

The FCA has published its letter to the Prime Minister, Chancellor and Secretary of State to provide updates on its approach to growth. In its letter, the FCA listed the reforms it had delivered this year and set out its plans for next year, which include accelerating digital innovation to enhance productivity. The FCA will oversee the launch of variable recurring payments, finalise digital assets rules, and set out plans for delivery of open finance. Stablecoin payments will be a priority in 2026. [10 Dec 2025] #Stablecoin #DigitalAsset #Payments #OpenFinance

Europe

EBA: Q&A on setting limits for execution of payment transaction – PSD2

The EBA has published a question and answer (Q&A) on whether a payment service provider (PSP) in one Member State is permitted to set a general limit (daily and/or per transaction) for the execution of payment transactions to a payee with a PSP in another Member State for the purpose of mitigating the risk of fraud.

The answer confirms that a PSP can implement spending limits for payment transactions initiated via specific payment instruments, provided such limits are agreed with the payment service user (PSU) in the framework contract. [12 Dec 2025] #Payments

Australia

ASIC finalises new exemptions to support digital asset innovation

ASIC has announced new measures to foster digital asset and payment sector growth and innovation. These changes followed five submissions providing feedback on the proposed class relief in response to CS 32. The amendments are set out in full in ASIC Amendment Instrument 2025/871 (Explanatory Statement) and ASIC (Stablecoin and Wrapped Token Relief) Instrument 2025/867 (Explanatory Statement) and achieve the following:

• Exempting intermediaries from the requirement to hold the following licenses when providing services relating to eligible stablecoins or wrapped tokens:
  • Australian Financial Services (AFS) License;
  • Australian Market License; and
  • Australian Clearing and Settlement Facility License.
• Allowing providers to hold digital assets which are financial products in omnibus accounts (subject to certain record-keeping and reconciliation requirements). [9 Dec 2025] #DigitalAsset #Payments

Hong Kong

FSTB and IRD launch consultation on implementation of CARF and amendments to CRS to incorporate crypto-assets and digital financial products into framework for enhancing tax transparency and combatting cross-border tax evasion

The Financial Services and the Treasury Bureau (FSTB) and the Inland Revenue Department (IRD) have jointly published a consultation paper on proposals to implement the Crypto-Asset Reporting Framework (CARF) and amendments in relation to the Common Reporting Standard (CRS) promulgated by the Organisation for Economic Co-operation and Development (OECD) in Hong Kong. Comments on the proposal are required to be submitted by 6 February 2026.

• CARF: This is a new tax transparency framework which provides for the automatic exchange of tax information on transactions in crypto-assets in a standardised manner with the jurisdictions of residence of taxpayers. Hong Kong was identified by the OECD as 'immediately relevant' to CARF given its growing crypto-asset sector, and was invited to implement CARF by 2028 at the latest. As announced in the 2025 Policy Address, the Government will introduce legislative proposals into the Legislative Council (LegCo) in 2026, such that the reporting crypto-asset service providers can collect the information required under CARF starting from 2027 for the IRD's exchange with partner jurisdictions from 2028.
• Amendments to CRS: This covers digital financial products and provide for enhanced CRS reporting and due diligence requirements. All jurisdictions implementing the CRS are required by OECD to adopt the amended CRS by 2030 at the latest. The Government plans to implement the amended CRS from 2029.

The FSTB and the IRD will take into account the comments received in the consultation and are aiming to introduce legislative amendments into the LegCo in the first half of 2026. [9 Dec 2025] #Crypto #DigitalAsset

US

CFTC withdraws outdated guidance on digital assets

Acting CFTC Chair Caroline D. Pham has announced the withdrawal of guidance related to actual delivery of "virtual currencies." The withdrawal of the guidance is intended to facilitate the CFTC's ongoing work to implement the recommendations in the President's Working Group on Digital Asset Markets report. [11 Dec 2025] #Crypto #DigitalAsset

FINRA releases 2026 edition of its oversight report

FINRA has published the 2026 FINRA Regulatory Oversight Report. The report presents insights gleaned from FINRA's regulatory operations programs that member firms can use to help enhance their resiliency and strengthen their compliance programs.

Matters covered in the report include: GenAI, cybersecurity and cyber-enabled fraud; manipulative trading in small-cap, exchange-listed equities; and the third-party risk landscape. For each, the report: identifies the relevant rule(s); summarizes noteworthy findings from recent oversight activities involving firms; outlines firms' effective practices that FINRA observed through its oversight activities; and provides additional resources that may be helpful to firms in reviewing their supervisory procedures and controls and fulfilling their compliance obligations. [9 Dec 2025] #GenAI #Cybersecurity

CFTC launches digital assets pilot program for tokenized collateral in derivatives markets

CFTC Acting Chair Caroline D. Pham has announced:

• the launch of a digital assets pilot program for certain digital assets to be used as collateral in derivatives markets;
• guidance on tokenized collateral; and
• withdrawal of some requirements in light of the enactment of the GENIUS Act.

The new guidance on the use of tokenized assets as collateral in the trading of futures and swaps issued by three CFTC Divisions explains that CFTC regulations are technology-neutral, and encourages the assessment of tokenized assets on an individual basis in light of the CFTC's regulatory framework and firms' policies and procedures. The guidance applies to tokenized real world assets. It covers: eligible tokenized assets; legal enforceability; segregation, custody and control arrangements; haircuts and valuation; and operational risks.

Additionally, the CFTC's Market Participants Division has issued a no-action position with respect to certain requirements applicable to Futures Commission Merchants (FCMs) that accept non-securities digital assets, including payment stablecoins, as customer margin collateral or hold certain proprietary payment stablecoins in segregated customer accounts. It establishes a pilot program to support responsible financial innovation while allowing CFTC staff to closely monitor developments.

The Market Participants Division also withdrew CFTC Staff Advisory No. 20-34, Accepting Virtual Currencies from Customers into Segregation. [8 Dec 2025] #DigitalAsset #Tokenisation #GENIUS

OCC issues Interpretive Letter confirming bank authority to engage in riskless principal crypto transactions

The OCC has published Interpretive Letter 1188 which confirms that a national bank may engage in riskless principal crypto-asset transactions as part of the business of banking. These transactions involve a bank acting as principal in a crypto-asset transaction with one customer while simultaneously entering into an offsetting transaction with another customer.

The OCC notes that, as with any activity, a national bank must conduct these activities in a safe and sound manner and in compliance with applicable law. [8 Dec 2025] #Crypto #DigitalAsset

SEC Chair addresses Investor Advisory Committee

The SEC has published the opening remarks delivered by Chair Paul S. Atkins at the meeting of the Investor Advisory Committee. Chair Atkins noted that DLT and tokenization are changing issuer-investor interaction, and set out how the SEC should respond in a way which facilitates innovation. [4 Dec 2025] #DLT #Tokenisation

Fed announces pricing for payment services which will be effective January 1, 2026

The Federal Reserve (Fed) has announced the pricing for payment services provided to banks and credit unions (such as the clearing of checks, automated clearing house (ACH) transactions, instant payments, and wholesale payment and settlement services) which will be effective on January 1, 2026. [4 Dec 2025] #Payments

FINRA Foundation reports research findings – retail investors

The FINRA Investor Education Foundation (FINRA Foundation) has released new research, Investors in the United States: Results from the FINRA Foundation's National Financial Capability Study. The report sets out insights drawn from the investor survey component of the FINRA Foundation's latest National Financial Capability Study (NFCS) into the attitudes, behaviors, knowledge and experiences of retail investors in the U.S.

Among the findings are:

• some 29% of investors report relying on social media for information; and
• a quarter of investors used recommendations from finfluencers to inform investment decision making;
• 13% said they had bought meme stocks or other viral investments;
• the percentage investing in crypto remained steady from 2021 to 2024 at 27%, but fewer investors were considering crypto investments in 2024 (26%) than in 2021 (33%); and
• word of mouth from friends, family and colleagues was among the more common sources of investment information with 65% using this source (other common sources include brokerage firms' research and tools (75%); recommendations from financial professionals (69%); and business and finance articles (67%)). [4 Dec 2025] #SocialMedia #Finfluencers #Crypto #DigitalAsset