The Duke Crypto regulation desk
FCA expectations are moving quickly. The Duke Crypto turns authorisation deadlines, stablecoin rules and crypto financial promotions into clear actions for UK firms, advisers and investors.
Read the rule that affects your next decision.
Key date: 1 January 2026
Preparation time is running down.
The clock shows the period until the framework date. Check official FCA notices before acting.
01 / Authorisation pathway
FCA registration is only one part of the operating plan. Your business model, custody flow and financial promotion route decide which permissions need attention first.
Start early. A weak file creates delay.
Separate exchange execution, custody, brokerage, payment services and promotion activity. Each route can bring a different regulatory obligation.
Record customer flows, assets held, outsourcing partners, governance owners and the evidence supporting your financial crime controls.
Show who makes decisions, how risks are tested and how customers receive accurate information. Policies must match the way the business actually operates.
Prepare ownership records, compliance monitoring, safeguarding controls, complaints handling, incident plans and management information.
Track the applicable consultation, final rules and transition window. Keep HMRC registration and tax records aligned with your compliance file.
02 / Communications control
A polished advert can still breach the UK regime. Clear risk language and an authorised approval route come first.
| Scenario | Compliant approach | Red flag |
|---|---|---|
| Risk statement | Green flag Place a prominent warning beside the main claim and keep its wording legible on mobile. |
Red flag Hide the warning behind a secondary link or small-print footer. |
| Performance claim | Green flag Use balanced evidence, explain the period measured and state that past performance is not a guide. |
Red flag Suggest certainty, guaranteed returns or urgency based on a price move. |
| Approval route | Green flag Record the approving firm, version, audience, channel and review date before publication. |
Red flag Assume an influencer, affiliate or overseas platform sits outside UK rules. |
Advertising standards
ASA decisions can expose weak substantiation after publication. Read each campaign as a regulator would, then retain the evidence behind every line.
See advertising standards analysis →03 / Payments and reserves
Fiat-backed tokens need more than a reserve account. Issuers must explain redemption, governance, operational resilience and how customer money is protected through stress.
The reserve story must be testable.
Issuance, promotion and customer-facing activity may create separate responsibilities. Map the full chain.
Tokens used at scale in UK payments may raise wider financial stability and settlement questions.
Payment institutions and e-money firms need a careful boundary review before launching token services.
04 / Market infrastructure
Exchange operators need a joined-up control set. AML registration alone does not answer custody, market abuse, complaints or safeguarding questions.
Customer due diligence, transaction monitoring and suspicious activity escalation need named owners and tested thresholds.
Show how keys are controlled, how withdrawals are approved and what happens during a security incident.
Fees, execution limits, conflicts and asset risks should be understandable before the customer commits funds.
Set response times, preserve records and test continuity when a provider, wallet or banking rail fails.
Recent enforcement lessons
Weak governance appears early. Fix ownership and evidence before a control failure becomes a public action.
Senior managers must know the risks attached to the product they approve.
High-reach campaigns need the same care as a direct customer communication.
Controls need evidence, testing and a clear response when they fail.
05 / Customer outcomes
Bank access, dispute routes and compensation limits shape real customer risk. They deserve the same attention as licensing.
Keep evidence for source-of-funds checks, transaction purpose and the controls behind your banking relationship.
Read banking analysis →Check the Financial Ombudsman Service position before presenting a complaint route as a customer guarantee.
Review dispute risks →Cryptoassets are not automatically covered. Explain what protection may apply to a linked regulated service.
See protection coverage →A clear explanation of custody, loss, volatility and complaint options prevents avoidable misunderstandings.
Read investor guidance →06 / Working resources
Use these resources to organise the next review. They are built for practical decisions, not legal theatre.
Check risk wording, approval records, evidence and channel controls before a campaign goes live.
Access resource →Set out customer risk, monitoring ownership, escalation points and management reporting.
Access resource →Compare activities, evidence requirements and transition questions before speaking with advisers.
Access resource →Plain-English definitions for registration, authorisation, safeguarding, promotions and custody.
View glossary →The Duke Crypto sends concise updates on consultations, policy statements, enforcement and dates that affect UK crypto businesses.
Make the next decision carefully
Read the latest UK crypto regulation analysis or send The Duke Crypto a specific question about FCA rules, licensing, stablecoins or financial promotions.
Bring the facts. We will start there.