News

FCA DeFi Consultation: Draft Guidance, Existing Responsibilities

October 28, 2026
5 min read

FCA's GC26/7 consults on DeFi guidance, with responses due November 18. The draft does not suspend existing obligations or approve an individual service.

The UK's Financial Conduct Authority opened GC26/7 on October 21, 2026, consulting on proposed DeFi guidance about operational resilience and financial crime. Comments are due November 18. This is draft guidance about compliance; it does not mean existing obligations are suspended or that the FCA has approved an individual protocol or exchange.

Identify what kind of document you are reading

The consultation calls the proposed material non-Handbook guidance. Its stated audience includes FCA-regulated firms using DeFi that are within the relevant operational-resilience and financial-crime requirements and the Money Laundering Regulations. The page also lists other interested readers. Being interested in a consultation and being subject to a particular requirement are not the same classification.

Item in the discussionQuestion it answersWhat still needs separate evidence
GC26/7 consultationWhat guidance is being proposed and discussed?The final text and any subsequent changes
Existing applicable requirementsWhich obligations already govern a firm?The particular firm's activities and legal scope
Perimeter guidanceHow activities are classified for regulationWhether the actual business meets the relevant conditions
A firm's permission recordWhat that firm is permitted to provideThe identity and service involved in your transaction
A consumer protection questionWhat protection may cover this situation?The applicable product and scheme conditions

Use this as a reading map, not a legal decision about a business. A page marked consultation can coexist with binding requirements that already apply elsewhere. Conversely, the existence of an established regulatory framework does not turn every example in a draft into a final instruction. Record the document title and stage alongside any claim made about it.

The related perimeter consultation asks a different question

The FCA directs readers to CP26/36 on the cryptoasset perimeter. That consultation concerns guidance on exclusions and whether particular activities need permission. GC26/7's risk-management discussion should not be used by itself to declare that every DeFi activity is authorised, exempt or outside regulation.

For example, a service describing itself as technical infrastructure has supplied a description, not a regulatory determination. Ask what activity it performs, which entity performs it and what official basis supports any claimed status. This review does not classify an individual service, interpret an exclusion for a business or offer a route around applicable requirements.

Keep the consultation deadline separate from a customer deadline

GC26/7's November 18 date is the deadline for consultation comments. It is not a deadline for holders to move coins, pay an account-verification charge or register a wallet through a link. The FCA says it plans final guidance for January 2027; a plan to publish is not evidence that the final text already exists.

What a user can check before relying on a regulatory claim

  1. Open the regulator's publication independently and identify whether it is a consultation, final guidance or another document.
  2. Record the named entity and the precise service claiming a regulatory status.
  3. Check the applicable permission information through official FCA resources rather than a logo in a message.
  4. Keep questions about compensation or complaint protection separate from the firm's permission status.
  5. For an existing transfer, retain its transaction and account records; a consultation announcement does not determine that payment's result.

The FCA Firm Checker is intended to help consumers check a firm's authorisation and relevant permissions. Its page also says the tool cannot confirm that FSCS or Financial Ombudsman protection will definitely apply. A successful firm check should therefore not be expanded into a promise that any crypto loss will be compensated.

The same page directs readers to the Financial Services Register for information not covered by the checker, including published crypto restrictions. Keep the identity and contact details consistent across the official record and the service you are dealing with. This article has not checked or certified a particular firm's entry, and a consultation reference is not a substitute for doing so.

Operational resilience is useful to ask about without inventing a rule

A practical service question might be: ‘Which part of my transfer is waiting, and how will I receive an update if your interface is unavailable?’ That is an editorial example of a useful support question. It is not presented as wording required by GC26/7 or proof that a firm has implemented any specific control from the proposed guidance.

Keep the next exchange under its actual conditions

For a later no-account swap, read the exchange process and AML policy. The FCA consultation does not approve KOT.CASH or determine its status. No-account access also does not itself establish that compliance checks are absent. The actual service terms and applicable requirements remain relevant to the chosen operation.

Check the current consultation stage and timetable before relying on a dated summary. Describe the UK development as a UK development; a Russian-language account does not convert it into another country's rules. The useful distinction is proposed guidance, applicable obligations and a specific permission record, each supported by the document that actually addresses it.

FAQ

Does an FCA consultation mean its proposed DeFi guidance is already final?

No: GC26/7 is a guidance consultation with a stated comment period. Its draft status also does not suspend obligations that already apply through other requirements.

Does FCA crypto regulation make every DeFi service authorised?

No general conclusion about an individual service follows from this consultation. Identify the entity, activity and applicable permission information separately.

Does the FCA crypto roadmap guarantee protection for my transaction?

A publication timetable is not a determination of consumer protection. The Firm Checker itself says it cannot confirm that FSCS or Ombudsman protection definitely applies.

no-account swapexchange processAML policy

Sources

Ready to exchange crypto?

Fast, transparent swaps — no registration required.

Start Exchange Now
FCA DeFi Consultation: Draft Guidance, Existing Responsibilities | KOT.CASH