GDF & CCI Response to FCA CP25/42: A prudential regime for cryptoasset firms
GDF and CCI are the two leading global members’ associations representing firms delivering crypto and digital assets solutions. Our members span the digital asset ecosystem and include the leading global crypto exchanges, stablecoin issuers, digital asset Financial Market Infrastructure providers, innovators, and investors operating in the global financial services sector.
Together, our members share the goal of encouraging the responsible global regulation of crypto and digital assets to unlock economic potential, improve lives, foster financial inclusion, protect security, and disrupt illicit activity.
CP25/42 sets out a comprehensive prudential framework for cryptoasset firms, including minimum capital requirements, a range of activity-based K-factors, and additional requirements relating to trading activity, counterparty exposure, concentration risk, governance, and disclosure. GDF and CCI support the FCA’s objective of ensuring that cryptoasset firms operating in the UK are subject to robust, risk-sensitive prudential standards, and we welcome the continued engagement with industry on the design of the regime.
Throughout our response, GDF and CCI we focus on targeted refinements to calibration, operability, and proportionality, aimed at ensuring that the prudential regime supports financial resilience and orderly wind-down, without unnecessarily constraining authorised business models or incentivising activity to move outside the UK regulatory perimeter. We would welcome continued engagement with the FCA to test calibration, explore transitional or smoothing mechanisms where appropriate, and ensure that the final framework delivers on both prudential and competitiveness objectives.
Submitted: 12/02/26