UK FCA draft guidance puts DeFi interface operators on notice as crypto applications open

  • FCA draft guidance examines when operators of UK-facing DeFi interfaces may need authorization.
  • Operators should assess interface control, facilitated activities and links to UK users.
  • GC26/7 and CP26/36 consultations close Nov. 18, 2026, with final guidance expected in January 2027.

The UK Financial Conduct Authority (FCA) has issued draft guidance on when operators of user-facing decentralized finance (DeFi) interfaces serving UK customers may need authorization. The guidance focuses on the people or entities that control access to protocols, not on imposing a blanket authorization requirement on DeFi activity or autonomous code. Operators are urged to assess their activities, operational control and UK customer links; the draft is not final and remains open to industry feedback. The guidance adds to the FCA’s broader effort to clarify how existing obligations and legislative exclusions apply to crypto businesses. On Oct. 21, 2026, it published Guidance Consultation GC26/7 and opened consultation CP26/36. GC26/7 covers operational resilience under SYSC 15A, compliance functions under SYSC 6 and requirements under the Money Laundering Regulations. CP26/36 examines exclusions for temporary settlement arrangements, qualifying stablecoin holding in payment processing, some proprietary trading and technical services that provide access to another provider or a decentralized protocol. The FCA says authorization depends on the functions performed and the specific arrangements involved; automation, smart contracts and distributed ledgers do not by themselves remove that requirement. Both consultations close on Nov. 18, 2026, with final guidance expected in January 2027. The FCA’s crypto authorization gateway opened on Sept. 30, 2026, and will accept applications until Feb. 28, 2027. The wider cryptoasset regime is scheduled to take effect on Oct. 25, 2027.

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