UK FCA Annual Work Programme 2025/26 – what this means for digital assets and blockchain

Following the publication of the FCA’s Strategy Paper last month (see our article on this here), and in line with the key regulator pledges announced by the UK government (see our previous article here), the FCA has set out its Annual Work Programme for 2025/26.

From a digital assets and blockchain perspective, the following items are of particular note:

• Becoming a more efficient and effective regulator: The FCA will aim to digitise and simplify the authorisation process to be able to make fast decisions regarding firm applications. It also notes that it will continue to reform its supervision model, to take a more flexible approach “with less intensive supervision for those demonstrably seeking to do the right thing”, and to be transparent about the risks and opportunities the FCA sees within the market “so that external stakeholders find our actions easier to understand and predict”. While these actions are not specific to cryptoasset firms or to any other type of firm, such reforms (to the extent they might cover cryptoasset businesses) will be helpful to those in the cryptoasset industry who are seeking authorisation and/or are navigating UK rules in order to remain compliant (including the financial promotions regime). 
• Digital Securities Sandbox: To further support growth and innovation, the FCA will continue to progress the digital securities sandbox, which provides a regulated environment for firms to test the issuance, trading and settlement of securities in the UK—including the pilot issuance of a Digital Gilt by the UK government (see also our previous article here). 
• Innovation in asset management: The FCA will seek to develop a roadmap for digital assets, starting with the asset management industry. Additionally, it aims to streamline regulatory requirements under the retail fund regime, to enable “better use of technology, including tokenisation of funds”. 
• New cryptoasset regime and FCA budget: The FCA will continue its work on developing a UK cryptoasset regulatory regime, with the aim to consult on rules over the course of 2025, finalising policy statements in 2026, and then opening the gateway of authorisation (see our previous article on the FCA’s timeline here). Importantly, the FCA states that it will invest £7.8m in developing and implementing a proportionate and safe regulatory regime for activities relating to cryptoassets (including stablecoins) in the UK. Separately, the FCA will return fees of £1m for in relation to cryptoasset financial promotions work which was not used.

While digital assets represent only one element of the FCA’s plans, the above commitments are positive signals for the cryptoasset industry. As noted in our UK policy update and what this means for digital assets and blockchain, the recent announcements by the UK government and shifts in regulatory focus on encouraging growth presents an interesting opportunity for digital asset firms to potentially help shape the direction of UK policy. 

Next steps

As part of our Regulating for Change programme, we are bringing together our sectoral, subject matter and public law and policy expertise, to help clients advocate powerfully in Whitehall, Westminster and across the regulatory community, for credible, specific regulatory and legislative changes. Do reach out to the Digital Assets and Blockchain Team if you’d like to discuss any of this further. 

For more resources, visit our Hogan Lovells Digital Assets and Blockchain Hub. 

Authored by John Salmon, Lavan Thasarathakumar, and Christina Wu.