As the new year begins and the financial services regulatory landscape across the UK and European Union continues to evolve, Travers Smith is pleased to present our 2026 Regulatory Roadmap. 

This briefing summarises key regulatory developments for asset managers, financial market infrastructures and fintech firms in the coming year to help senior managers and in-house legal and compliance advisers to stay on top of forthcoming changes.

2026 is set to be a pivotal year for payments and fintech regulation across the UK and the EU, as the regulatory focus shifts to the implementation of major regulatory reforms. This Update distils the key developments shaping the payments and digital assets ecosystem — spanning safeguarding, payments infrastructure reform, and evolving cryptoasset regulation — alongside other incoming initiatives that firms should be building into their strategic roadmaps.

On 15 December 2025, HM Treasury published the final draft of the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 (the Cryptoasset Regulations), which will establish a comprehensive UK regulatory framework for cryptoassets under the UK’s existing Financial Services and Markets Act 2000 (FSMA) framework. In addition, on 16 December 2025, the UK Financial Conduct Authority (FCA) published three consultation papers setting out proposed rules and guidance on (a) certain regulated cryptoasset activities, (b) the admissions, disclosures, and market abuse regime, and (c) the prudential framework, for authorised cryptoasset firms.

This piece is the third in a mini-series looking at a set of key HMT and FCA publications, delivered the week before the festive break began for many. Following on from our briefings Instrumental Health: Final Cryptoasset Legislation and UK cryptoassets prudential proposals: unexpected gift or the nightmare before Christmas?, this article brings the series to a seasonal close by looking at the FCA's proposals in CP25/40 and CP25/41. It is convenient to look at those together as there are aspects that overlap and interrelate.

The firms most interested in these proposals will be those wishing to operate a cryptoasset trading platform (CATP), participate in one or more CATPs, use CATPs to make offers of cryptoassets to the public, or otherwise act as a cryptoasset intermediary (both CPs are very relevant to those cohorts). CP 25/40 is also of specific relevance to firms carrying on the "cryptoasset-specific" activities of staking, and lending/borrowing of cryptoassets.    

Various conduct rules for that set of activities are covered in CP25/40 (uninformatively-titled "Regulating Cryptoasset Activities"). CP25/41 cover the proposals for Admissions & Disclosures (A&D) and the Market Abuse Regime for Cryptoassets (MARC). 

On 16 December 2025, the UK Financial Conduct Authority (FCA) published its proposals relating to the prudential framework that will apply to firms authorised to carry on cryptoasset-related regulated activities under the new UK cryptoassets regulatory framework. We previously published our briefing summarising the final cryptoassets legislation published by the UK Treasury, which is available here.

The proposed prudential rules build on the FCA's earlier proposals in CP25/15 and will determine the financial resources and risk management systems that authorised cryptoasset firms will need to maintain as a condition of their continued authorisation.

In this briefing, Travers Smith's Fintech, Market Infrastructure and Payments team give their view on the latest proposals and summarise the key elements of the FCA's proposed prudential new regime.

His Majesty's Treasury (HMT), published the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 (the Regulations) on 15 December 2025. While they may well ultimately be dated 2026 (Parliament rises for Christmas on 18 December and the Regulations must be approved by both chambers), this marks a key milestone in the UK's journey on digital assets, which will sit squarely within the regulatory perimeter of the Financial Conduct Authority (FCA). The Regulations will come fully into force on 25 October 2027, meaning that (if one were minded to be critical) it will have taken the best part of seven years for the UK to establish a regulatory framework for cryptoassets, dating back to the consultation and call for evidence of January 2021.      

Observers of, and aspiring participants in, the UK stablecoin market have needed deep wells of patience. In case this has slipped readers' minds, His Majesty's Treasury (HMT) has not actually yet laid the secondary legislation bringing cryptoassets, including stablecoins, into FCA regulation. We analysed the draft for consultation over six months ago, and expect the finalised version to be laid very soon.

In many ways that six month wait has been nothing compared to the extremely gentle pace (if that is the correct word) at which the Bank of England is designing its regime to regulate payment systems using systemic stablecoins. The original discussion paper was published a full two years and four days before last week's eagerly-awaited consultation paper, and a further set of publications are trailed for 2026. Senior officials from the Bank, up to and including Governor Andrew Bailey, have drip-fed aspects of the Bank's thinking over the spring and summer. This article outlines the proposals that are open for feedback until 10 February 2026. Critically, aspiring issuers will need to plan with both FCA and Bank regimes in mind – and it is imperative that they operate together coherently, and not in siloes.

Rory Tanner, UK Head of Government Affairs. Revolut

Rory is the Head of UK Government Affairs and Public Policy at Revolut. He leads Revolut's engagement with Government, Parliament, regulators and industry to secure positive business outcomes. Additionally, he leads policy development to identify and shape future opportunities and threats. Key topics are Open Banking, fraud, crypto and CBDCs, global expansion and the UK's international competitiveness in FS. Previously he has worked in the House of Commons and at public affairs consultancy Political Intelligence.

Revolut is an app for all things money. Founded in 2015 in the UK, it offers over 50 separate financial services products through a single app to 10 million users in the UK and over 45 million users globally. Revolut has launched into 41 countries, providing services such as payments, savings, credit, digital assets, stocks and vaults. They are valued at $45 billion, making them the UK's largest fintech and Europe’s most valuable private technology company.