CP25/15: A regime for cryptoasset firms: current developments

Prudential Services is now part of the Financial Resilience sector at Cosegic.

The Financial Conduct Authority's (FCA's) release of the new draft rules is relevant to firms and consumers that either plan to or already use/operate with stablecoins and cryptoassets in the UK. Previously, the regulatory scope for firms operating in the cryptoasset sphere was limited to the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017), the financial promotions regime, and consumer protection legislation. With the introduction of the new regime, firms operating in the sector will be subject to more stringent regulations, akin to those governing the traditional finance sector. This shift should result in a safe, competitive, and transparent crypto sector, ensuring firms, for instance those issuing fiat-based stablecoins and/or safeguarding stablecoins and cryptoassets, have the financial resilience to weather market downturns in a highly volatile cryptocurrency market.  

In the wider context, the FCA proposes creating a single prudential sourcebook COREPRU which will contain the core prudential provisions for all regulated firms. Firms operating in the crypto sector will be subject to the CRYPTOPRU sourcebook, which will draw on COREPRU and introduce specific prudential requirements proportionate with the activity of firms in the crypto space. Further, in the event that a firm operates both in the crypto and traditional finance sector, the firm will be subject to both CRYPTOPRU and the existing MIFIDPRU sourcebook. 

Introduction 

On May 28, 2025, the FCA published CP25/15 (A prudential regime for cryptoasset firms) and CP25/14 (Stablecoin issuance and cryptoasset custody) laying out proposed regulations and guidance for companies wishing to undertake regulated activities such as issuing stablecoins and safeguarding cryptoassets. These CPs follow a discussion paper released in May on how the FCA plans to regulate crypto activities (DP25/1) and demonstrate the FCA’s commitment to lay out the regulatory landscape for firms wishing to undertake crypto activities. To ensure that the rules are practical and align with market realities, the FCA has invited members of the public to provide feedback on the CP25/15 until July 31, 2025.  

To ensure financial resilience, the FCA will expect firms subject to this regime to hold sufficient capital, both in quality and quantity, to meet its capital requirements. The FCA’s proposal is for capital to comprise of the following three tiers (similar to MIFIDPRU firms): 

To ensure that capital remains loss absorbing, the FCA proposes that certain deductions will apply (similar to MIFIDPRU firms): 

As in MIFIDPRU,  firms will also be required to hold the following minimum proportions of each capital tier: 

Similar to MIFIDPRU firms, firms under this regime can include interim profits as CET1 only if these have been verified by independent auditors and a notification has been submitted to the FCA.  

The FCA proposes to adopt the three-pillar approach from MIFIDPRU so that the OFR for crypto firms is the higher of the PMR, FOR, and K-Factors: 

For firms subject to both the prudential regime for crypto asset firms, for instance where a company safeguarding cryptoassets may also be conducting investment activities as a MIFIDPRU investment firm, the following will apply:  

The FCA proposes the following liquidity requirements for firms in the crypto sector:  

The BLAR can be met with the following: 

GBP-denominated cash at bank / cash equivalents  

Non-GBP denominated cash at bank / cash equivalents where a firm incurs its expenditure in currencies other than pound sterling (proportionate to expenditure incurred in that currency) 

The FCA is stressing the importance of mitigating concentration risk within the cryptoasset sector. This aims to minimise the risk of overexposure to a single counterparty leading to substantial losses in light of recent events such as the collapse of Silicon Valley Bank. 

To safeguard against such risks, the FCA mandates that all cryptoasset firms implement robust administrative and accounting procedures, and ensure sound internal controls. 

Firms will be expected to: 

Firms seeking authorisation will need to provide evidence of these arrangements as part of their application for. 

Conclusion 

The developments in regulating firms wishing to conduct crypto activities in the UK demonstrate the regulator’s goals to support growth and offer protection to UK consumers, as outlined in the letter addressed to UK Prime Minister Keir Starmer earlier this year. By, establishing a robust and clear regulatory framework for cryptoassets in the UK, the FCA aims to offer an attractive market for crypto firms while ensuring financial resilience and market integrity. To ensure the new regime is practical, effective and proportionate, the regulator encourages firms operating or intending to operate in the UK crypto sector to provide their feedback by July 31, 2025.  

What next? 

How can Cosegic step in and support you?  

If you think your firm will be in scope of the new regime, we can assist you with variety of services including, but not limited to: