Mengupas Trilogi Konsultasi Kripto FCA: Panduan Praktis

If the UK government's December 2025 announcement was the headline, the three consultation papers published by the Financial Conduct Authority are the fine print. Together, CP25/40, CP25/41, and CP25/42 form the most detailed regulatory blueprint for crypto assets ever produced by a major financial regulator — and firms operating in the UK market need to understand what's in them.

CP25/40: The Activities Framework

The first paper tackles the broadest question: which crypto activities will require FCA authorisation? The answer is essentially all of them. Trading platforms, intermediaries, lending and borrowing services, staking providers, and even certain decentralised finance activities fall within scope. Larger platforms — those exceeding £10 million in average annual revenue — face additional obligations, including non-discriminatory access rules and enhanced transparency requirements.

For retail lending specifically, the FCA proposes mandatory over-collateralisation requirements. This is a direct response to the wave of crypto lending platform collapses in 2022-2023, signalling that the regulator has studied the industry's failure patterns closely.

CP25/41: Disclosure and Market Abuse

The second paper introduces requirements that will feel familiar to anyone who has worked in traditional securities markets. Issuers seeking admission to a UK trading platform must produce a qualifying crypto asset disclosure document — essentially a prospectus — including a two-page summary highlighting the key risks. The market abuse regime prohibits insider dealing and market manipulation, with large platforms required to monitor on-chain activity to identify suspicious patterns.

This is where the regulation becomes genuinely new. Monitoring on-chain activity to detect market abuse is a technical challenge with no direct precedent in traditional finance. The FCA is effectively requiring platforms to develop blockchain analytics capabilities that j