GDF Response to FCA Consultation Paper CP25/28 – Progressing Fund Tokenisation (Part 2: Chapter 5 Supporting Future Tokenisation Models)
GDF convened its UK Policy and Regulatory Working Group to analyse the FCA’s
Consultation Paper CP25/28 (October 2025) on Progressing Fund Tokenisation – Chapter 5
Supporting Future Tokenisation Models.
Our members strongly support the FCA’s phased approach and agree that the direction of travel
outlined in Chapter 5 aligns with the operational realities and infrastructure investments
currently underway across the industry.
Our analysis also highlights that many of the envisaged consumer and efficiency benefits, real-time data, lower friction, greater accessibility, fractionalised exposures, are already being demonstrated through tokenised money-market funds, tokenised Treasuries and programmable fund-processing pilots. These practical examples provide helpful reference points for regulatory calibration and illustrate how tokenisation can operate fully within the existing authorised-funds framework. While these models represent a future-state rather than a redesign of the existing authorised-funds regime, early clarity on how they would interact with current COLL expectations, oversight structures and settlement rules will support orderly and scalable development.
Overall we remain supportive of the consultation.
Submitted: 12/12/25
Download