The U.S.-based advocacy group argues that non-custodial developers should not face intermediary-style obligations, warning that broad rules are structurally incompatible with decentralized protocols.
The DeFi Education Fund (DEF) has formally requested the U.K. Financial Conduct Authority (FCA) to apply regulatory obligations only to entities possessing "unilateral control" over user assets or transactions. Responding to an FCA consultation, the U.S.-based advocacy group argued that software developers without operational powers—such as the ability to block transactions or modify protocol parameters—should not be subject to centralized intermediary regulations. DEF warned that imposing standard money-laundering and prudential requirements on non-custodial, automated protocols would be structurally incompatible with the technology's nature.