Bank of England and Financial Conduct Authority’s approach to joint regulation of systemic stablecoin issuers

1: Introduction

Through a co-ordinated approach and regulatory framework, we aim to provide regulatory clarity and certainty to firms issuing stablecoins in the UK whatever the size, aspirations or business model.

Within the United Kingdom’s (UK) stablecoin regime, the Financial Conduct Authority (FCA) will regulate all UK‑issued qualifying stablecoins and, in due course, their use in retail payments. Where stablecoins are widely used in payments and may pose risks to UK financial stability, their issuance will be subject to joint regulation by the Bank of England (the Bank) and the FCA, once recognised as systemic by HM Treasury (HMT).

This document sets out how the Bank and the FCA will apply the UK’s stablecoin regime jointly to systemic stablecoin issuers. The Bank’s proposed rules can be found in its sterling-denominated systemic stablecoin Policy Statement and consultation on draft Code of Practice published in June 2026 (Bank’s June 2026 publication), while the FCA’s are available in its Stablecoin Issuance Policy Statement (PS26/10).

As set out in the Banking Act 2009, HMT may determine a payment system or service provider as systemic. In doing so, HMT must consult relevant regulators as part of the recognition process.

Section 2.3.1 of the Bank’s proposed regulatory regime for sterling-denominated stablecoins published in November 2025 (CP25), explains that the Bank’s approach to providing HMT information as part of its recognition process to assess whether a payment system or service provider may be systemic is grounded in the recognition criteria and is undertaken on a holistic, case-by-case basis. In making a recommendation to HMT, the Bank would consider a range of indicators, including the scale, nature of use, substitutability, interconnectedness, as well as use by the Bank in the course of its role as a monetary authority. The assessment of whether a payment system or service provider is systemic requires the exercise of judgement, reflecting the forward-looking nature of the framework.

This approach is designed to accommodate new and evolving use cases. As set out in CP25, the same level of activity may have materially different implications for financial stability depending on how a stablecoin is used (for example, for crypto-asset trading versus everyday payments). A case-by-case assessment supports a proportionate and risk-based approach as the market develops.

At the same time, we recognise the importance of clarity and predictability for firms. The Bank has provided guidance on the factors and indicators and will continue to engage with industry and HMT as the regime is implemented.

As set out in the Banking Act 2009, a stablecoin issuer could be recognised as systemic by HMT as an operator of a systemic payment system using a digital settlement asset (DSA),^{footnote [1]} a systemic DSA service provider, or a firm who provides essential services to a systemic payment system or to a systemic DSA service provider. In this document, a stablecoin issuer should be considered as referring to any of these business models.

An issuer could be recognised as ‘systemic at launch’ (SaL) from the outset of its operations, where, although it is not currently operating at systemic scale, it is likely to do so (Section 3 and 4.3). All UK-based qualifying stablecoin issuers that are non-systemic will be captured under the FCA’s regime.

The Bank and the FCA have worked closely together to design an integrated two-part regime for issuers of stablecoins in the UK, with proportionate requirements for both non-systemic and systemic stablecoin issuers with a view to ensuring clarity, consistency and a smooth transition between the two sets of rules.

In the Bank’s June 2026 Publication, the Bank reiterated that the authorities were developing a stablecoin regime that is underpinned by a shared commitment to support innovation and growth, ensure strong consumer protection and maintain market integrity.

However, the two authorities act pursuant to distinct statutory objectives. The Bank’s rules are designed to advance its financial stability objective, reflecting the greater risks to financial stability that can arise where a stablecoin is widely used as money at scale in everyday retail and corporate payments. The FCA’s rules are designed to advance its consumer protection, market integrity, competition and secondary international competitiveness and growth objectives, and apply more broadly to stablecoin issuance and related cryptoasset activities.

The Bank and FCA have been working closely and considered where regulatory requirements can align across both sets of rules; particularly to support clarity for issuers that may transition from being non-systemic and solely regulated under the FCA to joint regulation once recognised as systemic. Full alignment, however, is neither necessary nor always appropriate. Targeted differences are maintained where this best reflects the authorities’ distinct statutory objectives and differing risks addressed by each set of rules. Systemic stablecoin issuers warrant more stringent requirements than those applying to non-systemic issuers regulated solely by the FCA.

This document sets out:

• how supervisory responsibilities will be allocated where issuers fall within the remit of multiple authorities;
• which issuers will be subject to Bank requirements;
• how Bank requirements interact with FCA rules;
• how FCA rules apply or will be disapplied when a firm becomes jointly regulated;
• how transition arrangements will operate where an FCA-authorised stablecoin issuer is recognised by HMT as systemic and brought into the joint regulatory framework;
• how the Bank intends to apply its rules during the transition period for firms moving to joint regulation; and
• the application of the UK’s stablecoin regime to systemic stablecoin issuers that are recognised as SaL.

The authorities recognise that some stablecoin issuers may be part of a group that is subject to the Prudential Regulation Authority (PRA) rules.^{footnote [2]} In these cases, the relevant authorities will co-ordinate and engage with firms on a case-by-case basis, to determine how relevant regulatory and transition requirements apply where the different sets of rules interact or overlap (eg group prudential requirements).

In addition, the Payment System Regulator (PSR) has regulatory powers over participants in systemic and non-systemic payment systems.^{footnote [3]} The PSR is responsible for promoting competition, innovation and end user interests for any payment system which is designated by HMT. The FCA will take on these responsibilities once the PSR consolidation has occurred.^{footnote [4]} Where a stablecoin falls within the remit of the PSR following prior designation by HMT, the authorities will address the joint application of rules on a case-by-case basis.

2: Application of authorities’ remits to regulating systemic stablecoin issuers

2.1: Cross-authority remits

The Financial Services and Markets Act 2023 (FSMA 2023) introduced changes to the Banking Act 2009 which extended the regulatory remit of the Bank to cover payment systems transferring DSAs, including systemic stablecoins, and issuers of systemic stablecoins. FSMA 2023 also introduced changes to the Financial Services (Banking Reform) Act 2013 (FSBRA) which extended the regulatory remit of the PSR to cover payment systems transferring DSAs, including stablecoins, and participants in such systems. The Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (as amended) (RAO) will expand the FCA’s regulatory remit to cover qualifying stablecoins,^{footnote [5]} through amendments made by the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (Cryptoasset Regulations).

The FCA will regulate all qualifying stablecoin issuers who are issuing stablecoins from an establishment in the UK, to protect consumers, promote effective competition, and protect and enhance the integrity of the UK markets. This may be alongside other authorities if the stablecoin issuer is recognised as systemic. In such cases, the Bank will assume responsibility for prudential regulation and other key elements of the regime, as set out in the Bank’s June 2026 publication.

The PSR’s remit applies to participants in payment systems designated by HMT under FSBRA. It may regulate the designated systems and their participants in relation to competition, access and their effective operation of the system, including through the exercise of its statutory powers. Where a designated payment system includes the transfer of stablecoins, either wholly or partly, those activities will fall within the PSR’s remit to the extent provided for in the designation order. The PSR also has concurrent powers with the Competition and Markets Authority over participants in any system (not just designated ones) including powers to enforce the prohibition against anti-competitive agreements. Upon consolidation of the PSR into the FCA, these functions will transfer to and be exercised by the FCA.

The designation by HMT under FSBRA is a separate process to HMT’s recognition process of a systemic stablecoin issuer. We recognise that it is possible for firms to become both recognised and designated, and for this to happen concurrently. Stablecoin issuers will remain regulated by the FCA irrespective of recognition or designation.

Where an issuer is regulated by multiple authorities, those authorities will engage with the firm and each other on a case-by-case basis as part of ongoing supervision and enforcement and will consider the application of relevant regulatory and transition requirements where these interact or overlap.

As set out in the Memorandum of Understanding (Payments MoU) (Annex), authorities may share confidential information through statutory gateways when necessary, proportionate and for regulatory purposes. Any information shared between authorities remains subject to applicable confidentiality obligations and may only be used for lawful purposes consistent with the basis on which it was disclosed.

2.2: FCA and Bank regulatory remits and rules for systemic stablecoin issuers

The table below summarises the Bank and the FCA’s regulatory remits as they apply to stablecoin issuers. It sets out the Bank’s remit over stablecoin issuers that HMT has recognised as systemic, and the FCA’s remit over UK stablecoin issuance and cryptoasset activities more broadly. The summary clarifies how the authorities’ responsibilities differ by geographical scope and activity, and how those responsibilities may interact for systemic stablecoin issuers.

The FCA has published its final rules for the regulation of cryptoassets including qualifying stablecoins – these include rules applicable to UK stablecoin issuers.

The Bank has published its draft rules set out in the draft code of practice (Code of Practice, CoP, consulted on in the Bank’s June 2026 Publication) for systemic sterling-denominated stablecoin issuers.

Table 3 provides an overview of the policy areas covered by both the FCA’s final rules applicable to stablecoin issuers and the Bank’s rules included in its draft CoP. It also indicates how supervisory responsibility for those areas would be allocated in the supervision of jointly regulated systemic stablecoin issuers. It is intended as an overview only. The table is non-exhaustive and firms should refer to the FCA’s policy statement and the Bank’s draft CoP for the full detail of the relevant requirements. The Bank intends to finalise its CoP by the end of the year.

The authorities’ experience demonstrates that overlapping supervisory responsibilities can be managed effectively through clear allocation of objectives, co-ordinated supervisory activity, and established coordination and escalation mechanisms. Where responsibilities overlap, each authority will act in accordance with its statutory objectives, with coordination underpinned by the Payments MoU, policy alignment and supervisory engagement.

Where differences arise, these are resolved through escalation between authorities, with each retaining its own decision‑making powers.

The FCA will determine which of its rules are to be disapplied to avoid conflicts with the Bank’s requirements. It will consult on how the allocation of rules and responsibilities set out in Table 3 above will be operationalised once the Bank’s CoP for systemic issuers has been finalised. This consultation cannot take place until both the FCA and the Bank requirements are settled.

In finalising the requirements and joint regulatory approach for systemic stablecoin issuers, the authorities will continue to co-ordinate closely and monitor the potential impact on issuers, including during the transition to joint regulation. Should it be needed, the authorities will issue a further joint publication, including additional detail on areas of overlap between the FCA and the Bank, the application of the Bank’s CoPs to systemic stablecoin issuers, and the supervisory approach to supporting issuers through transition.

3: Authorities’ engagement during the recognition process of systemic stablecoin issuers

3.1: Recognition of a systemic stablecoin issuer

As set out in Table 2 above, HMT may bring a stablecoin issuer within the Bank’s remit where the issuer is an operator of a systemic payment system using DSAs, is a systemic DSA service provider, or provides essential services to a systemic payment system or to a systemic DSA service provider.^{footnote [6]} In order to recognise a payment system or service provider as systemic, HMT must be satisfied that any deficiencies in the design or disruption to the operation of the payment system, or any deficiencies in, or disruption to, the services provided would be likely to:

• threaten the stability of, or confidence in, the UK financial system; or
• have serious consequences for business or other interests throughout the UK.

HMT must consult relevant authorities (such as the Bank, FCA and PSR) before making a recognition order or specifying a service provider. In addition, HMT must notify the issuer and consider any representations made.^{footnote [7]}

The Recognition Criteria the Bank will consider when making a recognition recommendation to HMT include transaction volumes and values, the nature of transactions, substitutability, interconnectedness and its use by the Bank in the course of its role as a monetary authority. In considering whether to recognise a payment system or DSA service provider, HMT must have regard to a similar list of factors set out in the Banking Act 2009.

As described earlier, some issuers may be recognised as SaL. This means an issuer is determined by HMT as likely to be systemically important in the UK, following consultation with the relevant authorities (as set out above) and consideration of the Recognition Criteria.

3.2: Authorities and firms’ engagement prior to recognition

In line with the Payments MoU, the Bank and the FCA will routinely engage and exchange information on issuers. This is intended to support early visibility of potential financial stability risks, without prejudging any subsequent assessment by the Bank or decision by HMT.

Where an issuer’s scale or growth may indicate a trajectory towards systemic importance and is solo regulated by the FCA, the FCA may share relevant authorisation and supervisory information with the Bank. Such information may include information about the issuer’s application for a Part 4A permission or, if authorised, information collected by the FCA in its supervision of the issuer. Where information is shared between authorities, it remains subject to confidentiality obligations and may only be used for lawful purposes consistent with the original basis for disclosure.

Throughout the recognition process of an issuer that has already been authorised by the FCA for the activity of stablecoin issuance and is already operating in the UK, the Bank will engage with the issuer to understand its business model, risk profile and the potential implications of its activities for financial stability. Where appropriate, the Bank will also engage with the issuer to support early preparation for an issuer’s transition into meeting the Bank’s CoP, should the firm be recognised as systemic.

Once a recognition order has been made, the issuer will be subject to the Bank’s rules and will be jointly regulated by the FCA and the Bank. The Bank recognises that, in some cases, an issuer may require a transition period following recognition for it to be able to meet the requirements applicable to systemic stablecoin issuers in full. The Bank will use its power of direction (PoD) in section 191 of the Banking Act 2009 to waive or modify the requirements of the Bank’s CoP during such a transitional period. ^{footnote [8]}

Where HMT is considering recognising an issuer as SaL before the issuer has existing operations, authorities will follow the same principles stated in the Payments MoU to share relevant information. The Bank and FCA will engage with the issuer to assess and understand its business model, risk profile, and in the case of the Bank, potential risk to financial stability.

In such cases, during the recognition process the issuer should either be seeking to be authorised, or be already authorised by the FCA to issue a UK-qualifying stablecoin. Without FCA authorisation the firm would not be permitted to issue stablecoins in the UK.^{footnote [9]} HMT’s recognition of the firm as a systemic stablecoin issuer does not fetter the FCA’s statutory obligation to consider the application for Part 4A permissions, including rejecting the application.

To provide more clarity on the application of rules from each authority and the transition path that issuers will need to follow if they are recognised as systemic by HMT, we are building on the illustrative examples provided in CP25 to illustrate two scenarios: i) an issuer transitioning from being solo regulated by the FCA to being jointly regulated by the Bank and FCA and ii) a new issuer that is considered ‘systemic at launch’.

4: Application of rules for issuers being recognised as systemic

4.1 Approach to onboarding new Financial Market Infrastructures (FMIs)

For issuers that move from being solo regulated by the FCA to joint regulation once recognised as systemic by HMT, as well as for new sterling-denominated stablecoin issuers that are recognised as SaL, the Bank would expect to apply the principles and approach set out in the Bank of England’s supervisory approach to onboarding new FMIs (Approach Document) which complements the Bank’s overall approach to supervising FMIs. In using the Approach Document, the Bank recognises that innovation is happening in the FMI landscape and seeks to support market entry of new and innovative FMIs as well as development of existing businesses, further supporting UK growth. The document outlines different paths issuers might take when recognised as a systemic.

This supervisory approach seeks to ensure that issuers are supported as they transition into being a regulated FMI and can grow their business safely, while managing risks to financial stability as they become more established.

In particular, the Approach Document explains two discretionary stages available which could support new issuers as they enter the Bank’s remit (Figure 2). During stage 3 (mobilisation) firms are allowed to operate under de minimis limits and conduct activities for live testing purposes only, rather than for economic value. Regulatory oversight would be proportionate to the risks posed by the firm in this stage. During stage 4 (scaling) firms are able to conduct business for economic value, but subject to certain business restrictions or conditions which may be necessary to limit risks to the Bank’s objectives.

Where appropriate, an issuer may enter one or both of the discretionary stages, or it may be more suitable for the issuer to move straight to baseline supervision. The discretionary stages could support new issuers to complete aspects of their operational set-up (such as those which depend on securing further investment) which may have otherwise been difficult to achieve before authorisation or recognition. For example, entering the mobilisation stage may be particularly suitable for a new systemic stablecoin issuer that is not yet operating in the UK and has been recognised as SaL. On the other hand, for some issuers that are transitioning from FCA solo regulation to joint regulation with the Bank, the scaling stage could support the issuer in fully meeting the rules for a systemic stablecoin issuer. The way in which different issuers can make use of these stages may depend on different factors such as the entity type, the maturity of the firm and/or its business model.

The Bank will apply supervisory resources in a way that is proportionate and commensurate with the issuer’s potential impact on financial stability. The Bank will set out its supervisory expectations for issuers in transition and may on a case-by-case basis use a PoD to temporarily disapply specific rules and set minimum requirements. In doing so, the Bank would support an issuer’s smooth transition to meeting the Bank’s rules. The Bank may use its PoD in a similar way for issuers that are recognised as SaL and apply the step-up approach^{footnote [10]} while they reach full operational capacity. The Bank might impose business restrictions during the scaling stage, depending on the Bank’s risk assessment and the issuer’s progress in meeting the Bank requirements.

The following sections will cover the application of the Approach Document to stablecoin issuers that are recognised as systemic. This is explained in Section 4.2 through the hypothetical scenario of a systemic stablecoin issuer ‘Coin GBP’. Section 4.3 covers the application of the Bank’s rules under the proposed ‘step-up approach’ for SaL issuers. This is explained through the hypothetical scenario of a SaL stablecoin issuer, ‘Coin UK’.

4.2: Transition from solo FCA regulation to joint regulation

We recognise that an issuer transitioning from being solo regulated by the FCA to being jointly regulated by the Bank and the FCA, may need time to meet all relevant Bank requirements, while continuing to meet the relevant FCA requirements. Without transitional arrangements implemented by the Bank issuing a PoD, the issuer would become subject to the Bank’s rules for systemic stablecoin issuers from the day of recognition in full.

While the Bank would expect issuers to meet its applicable requirements as promptly as possible, the Bank will set a specific timeframe for each issuer upon its recognition, having taken into account a number of factors, including the issuer’s rate of growth, the potential implications of disruption for UK financial stability, and the extent to which additional time may be needed to meet particular requirements. The Bank may also specify the order in which requirements need to be met. This will be informed by the risk assessment made by the Bank through the recognition process and communicated to the firm. The Bank expects a typical transition period to be in the range of 12 to 36 months. This expectation would allow an issuer up to 12 months to apply for access to a settlement account at the Bank and complete the backing assets transition, including applicable safeguarding arrangements. The Bank would also expect the issuer to apply for direct access to a payments system during this first part of the transition. A further period of up to 24 months may be required for the issuer to meet the capital and reserve requirements, including the safeguarding arrangements.

Table 4 below summarises the Bank’s and FCA’s requirements as set out in the Bank’s June 2026 draft CoP and FCA’s PS26/10. It identifies the key areas where the Bank rules will apply to systemic stablecoin issuers, and where the Bank might exercise its PoD to temporarily waive or adjust requirements to ensure a smooth transition. Without the Bank issuing a PoD, a stablecoin issuer that becomes jointly regulated would be expected to meet all rules included in the Bank draft CoP from the point it is recognised as systemic.

The FCA will continue to supervise stablecoin issuers once recognised by HMT as systemic, including during any transition period set by the Bank.

The FCA may engage with the issuer regularly during any transition to ensure there are no material impacts with its compliance with FCA rules. The Bank and the FCA will also seek to ensure that any direction issued by the Bank does not impact on an issuer’s ability to comply with FCA rules applicable under the joint regime.

From the day an issuer is recognised as systemic by HMT, the issuer will be jointly regulated by both the FCA and the Bank, and each authority will be responsible for supervising against their rules.

The table below summarises the key areas where there is a difference in the requirements for an issuer that is recognised as systemic, namely payment system direct access, redemption, backing assets, capital and reserve requirements, safeguarding and temporary issuance guardrails.

The below illustrates an example of a hypothetical stablecoin issuer (Coin GBP) that transitions to joint regulation. Dates and timelines would depend upon the facts of each individual issuer and arrangement.^{footnote [11]} The example assumes that both the Bank and the FCA regimes are live.

Questions:

1. Do you consider the onboarding approach set out in Section 4 to be appropriate for a stablecoin issuer transitioning to joint regulation? Please explain your reasoning, including any benefits and challenges.

2. How long do you envisage it could take a firm to transition from being solo regulated by the FCA to fully meeting the requirements for a systemic stablecoin issuer?

3. How much longer could it take an issuer transitioning to joint regulation to meet the capital and reserve requirements once the backing asset composition requirement has been met?

4. Have you identified any challenges for an issuer in transition to joint regulation to meet the redemption requirements on T+0 from the point at which a firm is recognised? If so, please elaborate on them.

5. Are there any areas not covered above that present significant challenges for a firm transitioning into joint regulation? Please list the identified challenges.

6. Are there other areas that might require an issuer entering the mobilisation or scaling stage for firms transitioning into joint regulation? Please explain.

4.3: Step-up approach for firms recognised as Systemic at launch (SaL)

The Bank’s approach for stablecoin issuers that are recognised as SaL by HMT will be proportionate and follow an incremental pathway that allows the business model to grow safely while limiting risks to the Bank’s objectives. As part of this approach, the Bank has proposed a step-up approach for new stablecoin issuers who are recognised as SaL which will allow them to hold up to 95% of their backing assets in short-term sterling-denominated UK government debt securities, with the remaining 5% held in unremunerated central bank deposits. This would be accompanied by proportionate capital and reserve requirements. The FCA will supervise issuers proportionately as they scale, applying an integrated and co-ordinated approach that shares information, aligns oversight with other authorities and supports effective management of risks while enabling innovation and sustainable growth.

The Bank would expect a SaL issuer to enter the mobilisation stage when it becomes recognised by HMT and authorised by the FCA. During this period, the Bank may use its PoD to set de minimis operational limits and specify the supervisory requirements for progression into the next stage. These requirements will be applied on a proportionate basis, reflecting the issuer’s risk profile rather than the standards applicable to a higher impact issuer. This approach is intended to support market entry and innovation while maintaining appropriate risks controls. Once the Bank is satisfied that the issuer has met the requirements to exit the mobilisation stage, the issuer will proceed either to a scaling stage, in which it might undertake limited activity for economic value, or directly to baseline supervision, depending on its circumstances.

Before the issuer starts to carry out any regulated activities, the issuer would need to obtain FCA authorisation under Part 4A FSMA. To obtain authorisation, an issuer must demonstrate that it meets, and will continue to meet, the FCA’s threshold conditions, including those relating to effective supervision, appropriate resources, suitability and a viable business model. Firms should expect a statutory determination period of up to 6 months for complete applications and up to 12 months where the application is incomplete.

Issuers recognised as SaL^{footnote [14]} would typically be expected to have applied for FCA authorisation at, or shortly after, the point of recognition.

For stablecoin issuers, applications to be authorised by the FCA will be assessed against the threshold condition from the point of authorisation and on an ongoing basis. As the gateway opens, issuers should plan for sufficient lead time to prepare a complete application and ensure their business model, governance and operational arrangements are fully developed at the point of submission. An issuer that is recognised as systemic before 25 October 2027 would need to be registered with the FCA for Money Laundry Regulation (MLR) purposes.

Questions:

7. Do you consider the onboarding approach set out in Section 4 to be appropriate for a new stablecoin firm entering the market? What are the benefits and / or challenges?

8. Are there any further challenges for a firm recognised as SaL where more guidance could help business looking to enter the UK market?

9. Does simplifying the capital rules to meet the step-up approach better allows an issuer recognised as SaL to scale is business? Are there aspects of the capital and reserves requirements that need to be further reconsidered for firms recognised as SaL?

10. Are there other areas that might require an issuer entering the mobilisation or scaling stage for firms recognised as systemic at launch? Please explain.

5: Next steps

In light of responses to this consultation, the Bank will publish a summary of responses and consider whether updates are required to existing documents, including the Approach to FMI Supervision, the Approach to onboarding new FMIs, and the Payments MoU. The Bank will also consider whether additional guidance is needed for issuers transitioning into joint regulation or recognised as SaL. The FCA may respond where relevant to its remit.

The Bank and the FCA may follow up with a final joint publication including further detail on how the Bank CoP and FCA PS26/10 will apply in areas where rules overlap. Once the Bank rules are finalised, the FCA will consult on which rules it will disapply when a firm is recognised as a systemic stablecoin issuer.

As announced today in the DSS Dashboard update the Bank and FCA will permit the use of certain stablecoins for securities settlement in the Digital Securities Sandbox (DSS). By observing this use case in a controlled live environment with a view to identifying how future regulation would need to be amended, authorities are supporting innovation in wholesale financial markets. Authorities will provide further communication and subject to amending the Central Securities Depository Regulations (CSDR), stablecoins could be used as a settlement asset by FMIs.

6: Responding to this consultation

This consultation paper seeks to gather feedback on the Bank’s proposed application of rules for systemic stablecoin issuers during transition when recognised as systemic by HMT. This builds on the rules the Bank is consulting on in the Bank’s June 2026 Publication and the final rules published by the FCA on its PS26/10.

This consultation closes on 30 September 2026. The Bank welcomes responses to any questions but does not expect respondents to provide an answer to every question. We are keen to hear from a wide range of stakeholders, which includes community or charitable-focused organisations, the payments industry, businesses, and the general public. When providing your response, please tell us whether or not you consent to the Bank publishing your name, and/or the name of your organisation, as a respondent to this consultation paper.

Please indicate in your response if you believe any of the proposals in this paper are likely to impact persons who share protected characteristics under the Equality Act 2010 and, if so, please explain which groups and what the impact on such groups might be.

You can respond to this questionnaire through the web form.

You can also respond by email: CP-systemicstablecoin@bankofengland.co.uk.

By post:

FMID Payments Policy Team
Bank of England
20 Moorgate
London
EC2R 6DA

By telephone: 020 3461 4878.

Should you have any additional requirements, please contact us through one of the above channels and we can provide this in accessible formats.

By responding to this consultation, you provide personal data to the Bank. This may include your name, contact details (including, if provided, details of the organisation you work for), and opinions or details offered in the response itself. We may use your details to contact you to clarify any aspects of your response. Responses may also be shared with the FCA, PSR, PRA, and HMT, considering the relevance of the consultation proposals to those organisations.

Please refer to the Bank’s privacy notice which sets out how we handle personal data in the performance of our functions.

7: Public Sector Equality Duty

In developing the proposed framework for backing assets in a systemic stablecoin regime, the Bank has had due regard to its obligations under section 149 of the Equality Act 2010 (the Public Sector Equality Duty), including the need to consider impacts on persons who share relevant protected characteristics.

The Bank has considered these issues as part of its policy development and, in line with the PSED, invited views in the 2025 consultation from stakeholders on whether the proposals may give rise to differential impacts on persons sharing protected characteristics, including religion or belief, and how any such impacts might be mitigated.

Please refer to the Bank's June 2026 Publication for a summary of the Bank's assessment of the PSED considerations.

8: List of questions included in this consultation

Q1: Do you consider the onboarding approach set out in Section 4 to be appropriate for a stablecoin issuer transitioning to joint regulation? What are the benefits and / or challenges?

Q2: How long do you envisage it could take a firm to transition from being solo regulated by the FCA to fully meeting the requirements for a systemic stablecoin issuer?

Q3: How much longer could it take an issuer transitioning to joint regulation to meet the capital and reserve requirements once the backing assets composition requirement has been met?

Q4: Have you identified any challenges for an issuer in transition to joint regulation to meet the redemption requirements on T+0 from the point at which a firm is recognised? If so, please elaborate on them.

Q5: Are there any areas not covered above that present significant challenges for a firm transitioning into joint regulation? Please list the identified challenges.

Q6: Are there other areas that might require an issuer entering the mobilisation or scaling stage for firms transitioning into joint regulation? Please explain.

Q7: Do you consider the onboarding approach set out in Section 4 to be appropriate for a new stablecoin issuer entering the market? What are the benefits and / or challenges?

Q8: Are there any further challenges for a firm recognised as SaL where more guidance could help business looking to enter the UK market?

Q9: Does simplifying the capital rules to meet the step-up approach better allows an issuer recognised as SaL to scale its business? Are there aspects of the capital and reserves requirements that need to be further reconsidered for firms recognised as SaL?

Q10: Are there other areas that might require an issuer entering the mobilisation or scaling stage for firms recognised as systemic at launch? Please explain.

9: Annex: Regulatory cooperation

The Bank and the FCA will co-ordinate and cooperate in relation to matters of common regulatory interest, such as the joint regulation of systemic stablecoin issuers, with the aim to support the efficient and effective exercise of their respective objectives.

In doing so the Bank and the FCA will have regard to the principles set out in the Payments MOU^{footnote [15]} and engage with firms to inform the review of the Payment MoU in ensuring the effectiveness and efficiency of authorities’ coordination and cooperation.

In particular the Bank and the FCA will:

1. Provide clarity of roles and responsibilities.
2. Take a holistic approach: where the Bank and FCA identify matters of common regulatory interest and consider that a decision may have a material impact on the advancement of the other authority’s objectives or regulatory functions, they will consult with the other authority.
3. Co-ordinate and cooperate in the exercise of relevant functions: the Bank and FCA will seek to ensure effective coordination and cooperation when exercising relevant functions in relation to matters of common regulatory interest
4. Exchange information: the Bank and FCA will share relevant information and advice between them, to support coordination and cooperation when exercising their functions, unless legally constrained from doing so.

In giving effect to the principles set out above, the Bank and the FCA will seek to provide clarity and predictability to firms by ensuring that the allocation of responsibilities between them is transparent and understood, including, where appropriate, identifying a lead authority for particular activities or decisions.

The Bank and the FCA will seek to ensure that their engagement with firms is co-ordinated and proportionate, including, where appropriate, aligning supervisory interactions, minimising duplication in information requests, and providing, as far as practicable, consistent communications on regulatory expectations.

The Bank and the FCA will have regard to the end-to-end regulatory lifecycle of firms, including authorisation, supervision, and any transition to joint regulation, and will seek to ensure that such transitions are managed in a transparent and orderly manner.

The Bank and the FCA will seek to identify, at an early stage, matters of potential policy divergence or material cross-authority impact, and will engage with each other to, avoid, as far as possible, the imposition of conflicting or duplicative requirements on firms.

The Bank and the FCA recognise the importance of effective coordination in stressed or time-sensitive situations and will seek to ensure, where appropriate, that there is clarity as to roles and responsibilities and that communications with firms and the market are appropriately co-ordinated.

Where entities or activities fall within, or may fall within, the remit of the Payment Systems Regulator (PSR) and the Prudential Regulation Authority (PRA), authorities engage as appropriate.

Where firms are subject to joint regulation, authorities will seek to ensure that engagement with is co-ordinated, proportionate, and reflects the allocation of regulatory responsibilities between authorities.

The Bank and the FCA acknowledge that the PRA and PSR (and in future the FCA discharging its payment systems function) may, in due course, establish rules or expectations relevant to firms in their remit utilising stablecoins.

If a firm that is regulated by the PRA, or that is part of a PRA-regulated group is recognised as a systemic stablecoin issuer, the same principles stated above will apply.

Authorities will take a holistic approach in matters of common interest such as capital, liquidity and resolution, avoiding duplication of requirements.