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The UK spent this fortnight laying the rails for tokenised markets in public. On 18 May the FCA and the Bank of England issued a joint Call for Input setting out a shared long-term vision for tokenisation in wholesale markets, alongside Bank work toward near 24/7 settlement and PRA Dear CEO letters on the prudential treatment of tokenised assets and stablecoins. Coming weeks after the FCA finalised fund tokenisation in PS26/7, this is the regulators moving the whole market, from funds to settlement to bank capital, onto a common digital-assets roadmap, and inviting firms to help design it before the rules harden. Feedback closes on 3 July.
The standards agenda ran in parallel. The FCA told section 21 financial promotion approvers to raise their game after a review found unsubstantiated claims and retail investors seeing professional-only promotions, warned that firms must do more to prevent sanctions breaches as £37 billion of assets sit frozen in the UK, and signed a new intelligence-sharing arrangement with the trade sanctions office. It responded to the Treasury’s Consumer Credit Act reform by promising to consult on a more rules-based regime under the Consumer Duty, and opened its Scale-up Unit to solo-regulated firms. The PRA published its Pillar 2A and CRR restatement policy statements, and Hamilton Lane and a Capital Group-KKR venture brought tokenised and hybrid private-credit products to market. The direction is unmistakable: build the digital plumbing, and tighten the controls that run through it.
FCA and Bank of England Set a Shared Vision for Tokenised Wholesale Marketsdummyanimatedrotating
On 18 May 2026 the FCA and the Bank of England published a joint Call for Input setting out a shared vision and a set of principles for the safe adoption of tokenisation in UK wholesale markets. Having heard from industry that firms need more certainty on regulation and infrastructure, the two regulators set out their approach in the areas firms most want clarity on, prudential treatment, tokenised collateral and settlement instruments, and opened a discussion on the principles that should govern a future digital wholesale market.
- From pilots to production: Sarah Breeden, the Bank’s deputy governor for financial stability, framed the task as moving from pilots to production. The Bank and FCA continue to work with 16 firms on live issuance and settlement of tokenised assets through the Digital Securities Sandbox, and the Bank is committing to launch a live synchronisation service targeted for 2028.
- The settlement rails: Alongside the vision, the Bank published a consultation on extending RTGS and CHAPS settlement hours toward near 24/7 operation, and is enabling tokenised equivalents of eligible assets to be used as collateral, work that also supports HM Treasury’s pilot issuance of a digital gilt, DIGIT.
- The prudential layer: The PRA issued Dear CEO letters to all banks and designated investment firms on the prudential treatment of tokenised assets, stablecoins and other cryptoasset exposures, and on innovations in deposits, e-money and stablecoins, reaffirming risk-management expectations as the market develops.
- The funds connection: Simon Walls, the FCA’s executive director of markets, said the partnership will ensure a common approach across all parts of wholesale markets. The FCA also committed to consider how its client asset (CASS) rules may evolve, building directly on the fund tokenisation policy statement, PS26/7, published weeks earlier.
This is the moment tokenisation stops being a funds story and becomes a market-structure story. The FCA handled the product layer with PS26/7. Now the regulators are addressing the harder questions underneath it: how tokenised assets settle, how they count as collateral, how banks must capitalise them, and how money moves around the clock to support them. Feedback on the Call for Input closes on 3 July 2026, with a feedback statement due in the summer.
The phrase that should focus minds is from pilots to production. A sandbox tolerates operational rough edges; a production wholesale market does not. Firms that have run tokenisation experiments should now ask whether their settlement, collateral and reconciliation controls would survive being load-bearing. The CASS review the FCA has flagged is the tell: client-asset protection is where tokenisation will be tested hardest, and the Sapia case three weeks ago showed exactly how unforgiving the regulator is on client-money controls.
Engagement is the strategic move. The regulators are explicitly asking where existing rules and infrastructure support or constrain safe adoption. The firms that respond to the Call for Input with concrete operational evidence, on settlement finality, collateral eligibility and prudential treatment, will help shape a framework they then have to live under. Treating this as a consultation for someone else to answer cedes the design of the next decade of market plumbing to competitors.
Regulatory Updates
FCA Tells Financial Promotion Approvers to Raise Standardsdummyanimatedrotating
On 27 May 2026 the FCA published a review of section 21 financial promotion approvers, the FCA-authorised firms permitted to approve promotions for businesses that are not themselves authorised. Assessing ten such firms, the review found the strongest applied the Consumer Duty from the start of their approval process, but others fell well short.
- The failures: Some firms approved adverts with unsubstantiated claims, allowed retail investors to see promotions intended for professional clients, and relied on third-party templates instead of doing proper checks themselves. The review sampled promotions approved since each firm was authorised, across Buy Now Pay Later, crowdfunding and corporate finance.
- The consequences: Lucy Castledine, director of consumer investments, said that when approvers fail, people can be misled into harmful financial decisions. As a result of the work, one firm has already conducted a remediation exercise and some websites have been blocked to retail customers. The section 21 approver rules came into force on 7 February 2024.
The approver gateway is where the financial promotions regime is enforced in practice, and the FCA has just shown it will test the substantiation behind individual sign-offs, not just the firm’s policy. Any firm holding section 21 permission should pull a sample of its recent approvals and check two things: whether the audience targeting actually held, and whether the evidence for every claim exists on file. Outsourcing the check to a third-party template is precisely the failure the FCA named.
FCA Warns Firms to Do More to Prevent Sanctions Breachesdummyanimatedrotating
On 28 May 2026 the FCA reported that financial firms have improved their sanctions systems and controls but must do more, noting that £37 billion of assets were frozen in the UK as of last year. Since February 2022 the FCA has proactively assessed the sanctions controls of more than 150 firms across the sector.
- The weak points: The most common root causes of reported breaches were weaknesses in due diligence, alert management, transaction and name screening, and the management of frozen assets and licences. Firms found trade sanctions, covering bans on exports and imports of goods, technologies and services, harder to detect and prevent than financial sanctions.
- The threat picture: Reports still relate primarily to the Russian regime, but the FCA is increasingly seeing reports linked to Libya, Iran and North Korea. On the same day it signed a Memorandum of Understanding with the Office of Trade Sanctions Implementation, adding to its existing arrangement with the Office of Financial Sanctions Implementation.
The signal in the trade-sanctions gap is the one to act on. Most firms have built their screening around financial sanctions and named persons; trade sanctions, which turn on goods, technologies and end-use, sit awkwardly in those controls. Firms with any exposure to trade finance, supply-chain lending or dual-use sectors should test whether their screening can actually catch a trade-sanctions breach, because the FCA has now told the market that is where it expects to find gaps.
FCA Responds to Treasury’s Consumer Credit Act Reformdummyanimatedrotating
On 18 May 2026 the FCA responded to the Treasury’s policy statement on reform of the Consumer Credit Act 1974, welcoming a framework that shifts emphasis from prescriptive legislation toward FCA rules and guidance. The regulator said it intends to consult on the key elements of the consumer credit framework previously set in legislation, where it has the powers to do so, across the whole consumer credit process.
- The anchor: The FCA’s approach will be underpinned by the Consumer Duty. It will consider existing consumer rights and protections, including cancellation, withdrawal and termination of agreements such as early settlement, with any proposals supported by evidence and a cost benefit analysis.
Moving consumer credit from statute into the FCA rulebook is a transfer of design responsibility on a large scale. For lenders, the practical implication is that the certainty of black-letter legislation will be replaced by the judgement-based expectations of the Consumer Duty. Firms that have treated the Consumer Credit Act as a compliance checklist will need to develop the outcomes-based muscle the Duty demands, because that, not the statute, is where the rules are heading.
FCA Opens the Scale-up Unit to Solo-Regulated Firmsdummyanimatedrotating
On 20 May 2026 the FCA opened its Scale-up Unit to applications from solo-regulated firms, extending a service that had been piloted with six dual-regulated firms alongside the PRA. The unit gives fast-growing firms a dedicated point of contact and practical help navigating regulatory processes, developing products and understanding policy changes.
- How to engage: Jessica Rusu, the FCA’s chief data, information and intelligence officer, said the initiative will help firms grow with confidence and make the UK the best place to start and scale a financial services business. Applications for solo-regulated firms are open from 20 May to 22 June 2026, and the unit sits alongside Innovation Pathways, the Pre-Application Support Service and the Early and High Growth Oversight function.
The Scale-up Unit is part of the same growth machinery as the tokenisation work: the FCA positioning itself as an enabler, not just a supervisor. Smaller managers and fintechs with genuine growth plans should treat the application window as a low-cost way to get regulatory questions answered early. The firms that build a relationship with the unit now will navigate the coming tokenisation and crypto regimes with a direct line the rest will not have.
The UK is building the rails for tokenised markets in public, and inviting firms to help lay the track.Asad Bukhory
PRA Developments
PRA Finalises Pillar 2A Reform and Restates CRR Definitionsdummyanimatedrotating
The PRA closed May with two banking policy statements consolidated in its May Regulatory Digest, published on 1 June. PS15/26, published on 28 May, finalises the first phase of the Pillar 2A review, giving feedback to CP12/25 and updating the methodologies and guidance the PRA uses to set Pillar 2A capital, the requirement that addresses risks not adequately captured by Pillar 1.
- What Pillar 2A Phase 1 changes: The policy statement reworks the credit-risk methodologies, including removing the benchmarking approach and setting systematic methodologies for exposures to central and regional governments and for retail lending, as the first stage of a two-phase review.
- CRR restatement: PS14/26, published on 27 May, finalises the restatement of Capital Requirements Regulation definitions into the PRA Rulebook, giving feedback to CP19/25 from July 2025, part of the wider transfer of retained EU law into the PRA’s own rules.
Insurance note: PS13/26, published on 21 May, finalises the PRA’s policy on insurance third-country branches, responding to CP20/25 and completing another tranche of the Solvency UK reform programme.
PRA Issues Dear CEO Letters on Tokenised Assets and Stablecoinsdummyanimatedrotating
On 18 May 2026, alongside the joint tokenisation Call for Input, the PRA published two Dear CEO letters from David Bailey, Charlotte Gerken and Rebecca Jackson to the chief executives of all banks and designated investment firms. The first sets out updated guidance on the prudential treatment of tokenised assets, stablecoins and other cryptoasset exposures; the second clarifies the PRA’s expectations on innovations in the use of deposits, e-money and stablecoins.
- The message: Both letters reflect recent market developments and reaffirm the PRA’s expectations on risk management and compliance. They are the prudential complement to the FCA’s conduct-side tokenisation work, ensuring that as banks engage with tokenised assets and stablecoin-linked products, capital and risk treatment keep pace.
For dual-regulated firms: tokenisation now carries expectations from both regulators at once, conduct and market structure from the FCA, prudential and risk management from the PRA. Engaging with one without the other leaves a gap.
Fund Launches
Hamilton Lane Launches Tokenised Share Class for Its Global Private Assets Funddummyanimatedrotating
Hamilton Lane launched a tokenised share class providing access to its Global Private Assets evergreen fund, built with Allfunds Blockchain and Apex Group, with BBVA Asset Management named as the first distributor. The move, reported on 26 May 2026, lands squarely in the fortnight the FCA and Bank of England set out their tokenisation vision.
- Why it matters: A major private-markets manager bringing a tokenised wrapper to an evergreen private-assets fund is precisely the production-grade adoption the regulators say they want to see. It pairs tokenisation infrastructure providers with an established manager and a bank distributor, a template others are likely to follow.
- The governance corollary: Tokenised access to illiquid private assets compounds two challenges the regulators are watching: the operational integrity of the token layer and the valuation and liquidity governance of the underlying evergreen fund. Both must hold for the structure to deliver what it promises retail and wealth investors.
Capital Group and KKR Bring a Public-Private Credit Fund to Europedummyanimatedrotating
Capital Group and KKR launched what was reported on 27 May 2026 as their first public-private credit fund in Europe, extending a partnership that began in the United States. The hybrid structure blends public bonds with private debt and is designed for broader, wealth-channel access rather than purely institutional investors.
- The structure: According to reporting, the fund holds around 60% in public bonds and 40% in private debt, and offers monthly redemption windows capped at around 3% of assets, the semi-liquid design now standard for retail-accessible private credit.
- The watch item: Capped monthly redemptions are the pressure point. The blended-liquidity model works until redemption demand exceeds the cap, at which point the gate becomes the story, exactly the liquidity-redemption alignment the FCA and PRA have named as a supervisory priority for private markets.
Enforcement
High Court Approves Distribution of Money Recovered from Argento Wealthdummyanimatedrotating
In a judgment dated 19 May 2026 and announced by the FCA on 29 May, the High Court approved the pro rata distribution to eligible investors of money the FCA recovered from Argento Wealth Limited. The recovery flows from the FCA’s action against an unauthorised business, and the distribution covers investors in the AWL Loan Scheme and in the EMB Scheme where the investment was arranged by Argento Wealth or its sub-distributors.
- The deadline: Eligible investors must provide their bank details to the FCA by 1 August 2026 to receive a payment. The FCA is writing to investors it can identify, and is asking others who believe they are eligible to come forward before the deadline, after which no further distribution can be made to them.
Recovery and distribution is the quiet, unglamorous end of enforcement, and it carries a lesson for distributors. The scheme reached investors whose money was arranged through sub-distributors, a reminder that the chain of responsibility for unauthorised investment schemes runs through everyone who introduced or arranged them. Firms that act as introducers should know exactly which schemes they have ever channelled clients into, because the FCA traces those chains when it recovers money.
Two More Authorised Firms Enter Administrationdummyanimatedrotating
The period closed with two further FCA-authorised firms failing. Halo Financial Limited entered special administration on 29 May 2026, with joint special administrators from BTG Begbies Traynor appointed, while Sukate & Bezeboh Ltd, trading as SB Remit, entered administration on 22 May 2026. In both cases the FCA confirmed the appointments and the routes for affected customers to obtain information.
A steady drumbeat of authorised-firm failures is the backdrop against which all the growth and tokenisation rhetoric should be read. The same regulator opening a Scale-up Unit is processing a continuous flow of administrations. For firms, the lesson is in the contrast: regulatory support for growth does not soften the consequences of running out of capital or controls. Resilience planning is not the opposite of a growth strategy; it is its precondition.
Market Developments
Bank of England Moves Toward Near 24/7 Settlementdummyanimatedrotating
Alongside the tokenisation vision, the Bank of England published a consultation on 18 May 2026 on extending the operating hours of its RTGS and CHAPS systems, setting out a staged path toward near 24/7 settlement. The proposed approach includes weekend and extended daily operating hours, subject to consultation and industry readiness.
- Why it matters: Round-the-clock settlement is the infrastructure that tokenised, programmable assets need to deliver their promised efficiency. It also supports faster cross-border payments and new settlement models. The Bank is separately working to enable tokenised equivalents of eligible assets to serve as collateral, and is targeting a live synchronisation service for 2028.
Extending settlement hours sounds operational, but it reshapes liquidity and risk management. A market that can settle at any hour removes the overnight window firms have long used to net, fund and reconcile. Treasury and operations teams should start mapping what near 24/7 settlement does to intraday liquidity, staffing and control coverage, because the move from a banking-hours market to an always-on one changes where operational risk concentrates.
FCA Warns Young Drivers Over Social-Media Ghost Brokingdummyanimatedrotating
On 20 May 2026 the FCA warned drivers aged 17 to 25 about ghost broking scams, in which criminals sell bogus motor insurance policies through social media and messaging platforms. Victims are left unknowingly uninsured and exposed to prosecution as well as financial loss.
Ghost broking is a small story with a large signal: financial crime has moved decisively onto social platforms, and the victims are young and digitally native. For firms, the read-across connects to the financial promotions review in the same fortnight. The same channels carrying illegal insurance promotions carry unapproved investment promotions, and the FCA is policing both. Distribution and marketing teams should assume social-media financial promotion is now a supervised, high-scrutiny channel.
FCA to Hold Its Annual Public Meeting in Edinburghdummyanimatedrotating
On 26 May 2026 the FCA confirmed that its Annual Public Meeting will be held in Edinburgh for the first time, on 6 October 2026. The choice underlines the regulator’s stated ambition to be visible across the whole of the UK, not only in London, and follows its broader push to build presence in Scotland and beyond.
The venue is symbolic, but symbols matter in regulation. Holding the Annual Public Meeting outside London signals a regulator conscious of its national remit and its relationships with the major asset-management and banking centres beyond the City. Firms in Scotland and the regions should read it as an invitation to engage more directly, and take it.
Calendar
June 2026
- 20 May to 22 Jun FCA Scale-up Unit application window for solo-regulated firms.
- 28 Jun Applications close for the FCA Smaller Business Practitioner Panel.
July to August 2026
- 3 Jul FCA and Bank of England wholesale tokenisation Call for Input closes.
- Summer FCA crypto regime policy statements expected, plus the wholesale tokenisation feedback statement.
- 1 Aug Deadline for eligible Argento Wealth investors to provide bank details for distribution.
Autumn 2026
- 30 Sep FCA cryptoasset authorisations gateway opens.
- 6 Oct FCA Annual Public Meeting, held in Edinburgh for the first time.
- Autumn FCA final policy statement on the cryptoasset perimeter guidance.
Key Dates Later in 2026 and Beyond
- 1 Jan 2027 Basel 3.1 final rules and the SDDT simplified capital regime take full effect.
- Mar 2027 Standardised operational incident and third-party reporting regime comes into force.
- Oct 2027 UK cryptoasset regime takes full effect.
- 2028 Bank of England targets launch of its live synchronisation service for tokenised settlement.
The FCA found that some financial promotion approvers were signing off adverts on the strength of a third party’s template rather than their own checks. So ask it of your own firm: if you hold a section 21 permission, could you show the FCA the evidence behind every claim in the last ten promotions you approved, and prove the audience targeting actually held? If not, you are the firm the review was written about.
We’d welcome your perspective. The best responses may feature in a future edition.
Much of the industry discussion around tokenisation continues to focus on technology: distributed ledgers, digital assets, smart contracts and settlement efficiencies. The regulators are increasingly focused elsewhere. Their attention is shifting towards the governance, control and risk frameworks that sit underneath these technologies.
That distinction matters.
The regulatory challenge is no longer whether tokenisation can work. Pilot programmes, digital securities sandboxes and tokenised fund structures have already demonstrated technical feasibility. The question regulators are now asking is whether firms can operate these models safely at scale.
The Bank of England’s move towards near 24/7 settlement is a useful illustration. While often presented as an infrastructure enhancement, continuous settlement fundamentally changes the operational risk profile of financial institutions. Reconciliations, liquidity management, collateral processes, sanctions screening and incident response frameworks were largely designed around traditional market operating hours. An always-on market reduces the natural control windows firms have historically relied upon.
The same principle applies to tokenised funds and assets.
A tokenised wrapper does not eliminate existing regulatory obligations. Client assets still require protection. Financial promotions still require approval and substantiation. Sanctions controls still need to operate effectively. Prudential requirements still apply. If anything, increased automation raises the importance of control effectiveness because failures can occur faster and scale more rapidly.
This helps explain why the FCA’s review of financial promotion approvers and its sanctions messaging sit comfortably alongside its support for tokenisation. They are not separate initiatives. They are components of the same supervisory philosophy.
The regulatory message is straightforward. Innovation will be supported. Weak controls will not.
For boards and senior management teams, the strategic risk is assuming that digital transformation and regulatory compliance are distinct workstreams. Increasingly, they are becoming inseparable.
The firms most likely to benefit from the next phase of market digitisation will not necessarily be those with the most advanced technology. They will be the firms that can demonstrate robust governance over that technology.
That raises three questions boards should be considering now:
- Can our existing control framework operate effectively in a near real-time environment?
- Are our governance arrangements keeping pace with the speed of technological change?
- If a regulator reviewed our tokenisation strategy today, would they see a technology programme or a risk-managed business transformation programme?
The distinction is critical. Historically, regulatory change has often followed innovation. In tokenisation, regulators are attempting to shape the market structure before mass adoption occurs. The firms engaging with consultations, testing operational models and evidencing governance outcomes today will help define the future framework.
Those that wait until the rules are finalised may discover that the market architecture has already been designed around assumptions they had no role in shaping.
The strategic opportunity therefore extends beyond technology adoption. It is participation in the design of the next generation of financial market infrastructure.
That is ultimately what the FCA and Bank of England’s Call for Input represents. Not merely a consultation on tokenisation, but an invitation to influence how trust, control and accountability will operate in increasingly digital financial markets.
Asad Bukhory | Founder, Artizan Governance
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