GDF Response to the Bank of England and FCA Approach to Joint Regulation of Systemic Stablecoin Issuers | September 2026

Global Digital Finance (GDF) has submitted a response to the Bank of England and Financial Conduct Authority (FCA) joint paper on the approach to regulating systemic stablecoin issuers, which sets out how issuers will transition from FCA-only regulation into joint FCA and Bank supervision, and how firms considered systemic at launch will be onboarded. The response draws on GDF’s Global Stablecoin Regulatory Playbook, member evidence and discussion at GDF’s Bank of England roundtables on 10 September 2026.

GDF supports a managed route into joint supervision, but stresses that systemic recognition should not create a regulatory cliff edge. The response recommends a single FCA and Bank transition roadmap agreed before recognition, setting out day-one requirements, temporary modifications, milestones and evidence requirements, with dependency-led sequencing so that firms are not treated as non-compliant because of delays in settlement-account approval or payment-system access outside their control. GDF supports the proposed 12-to-36-month planning range, with firm-specific timetables reflecting each issuer’s starting position.

Key themes include clarifying how the T+0 issuer-redemption standard will be assessed in practice, including out-of-hours requests and delays in independent payment infrastructure; assessing capital, reserves, backing-asset, localisation and operating requirements as a cumulative package through published worked scenarios; allowing equivalent overseas safeguarding and custody arrangements to continue during transition; and ensuring mobilisation and scaling restrictions are proportionate, time-limited and removed promptly once objective criteria are met. GDF also calls for a distinct use-case-based pathway for wholesale settlement, recognising that delivery-versus-payment models differ materially from retail payment use.

On the international dimension, GDF recommends a transparent, outcomes-based deference process for non-sterling overseas issuers, with published evidence requirements, pre-systemic engagement and robust home-host cooperation, and cautions against defaulting to separate local issuance structures that could fragment liquidity. The response concludes that the UK can build a framework accommodating regulated stablecoins alongside central bank money and tokenised deposits within an interoperable multi-money system, provided rules are clear, calibrated to actual risks and compatible with comparable regimes in other major financial centres.

Date:
September 2026

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