# FCA opens consultations on DeFi obligations and crypto permission boundaries

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Published: 2026-10-22T00:37:41.007Z
Publisher: Yield Dispatch

Responses are due November 18 on existing-requirement guidance and proposed interpretations of cryptoasset exclusions, including technical access to DeFi.

The UK's Financial Conduct Authority opened two consultations on October 21 examining how regulated firms use decentralised finance and how cryptoasset activities fall inside or outside its remit. Both accept responses until November 18.

[GC26/7](https://www.fca.org.uk/publications/guidance-consultations/gc26-7-decentralised-finance-guidance) proposes guidance on applying existing operational-resilience and financial-crime requirements to firms using DeFi. It addresses regulated firms interacting with protocols, facilitating access or providing financial services through them, where the relevant requirements apply. The document does not propose a new set of policy requirements.

Its examples illustrate measures firms might consider when meeting those existing obligations. They are not evidence that a particular protocol has received regulatory approval, or that every illustrated measure is a mandatory new control.

The separate [CP26/36 consultation](https://www.fca.org.uk/publications/consultation-papers/cp26-36-cryptoasset-perimeter-guidance) proposes changes to the FCA's guidance on which cryptoasset activities require permission. Its decentralisation analysis looks at the substance of arrangements and each participant's activities, rather than relying on a DeFi label, software or smart contracts alone. The business and UK territorial tests remain relevant.

One proposed clarification concerns technical services that merely provide access to a third party's services or a decentralised protocol. The exclusion concerns arranging deals and has conditions. It does not automatically remove every software-based business from regulation or extend to other activities such as dealing.

For firms using DeFi, the consultations separate two questions: whether their activities require permission, and how existing obligations apply to the services they provide. The FCA says the expanded cryptoasset regime begins on October 25, 2027. November 18 is the feedback deadline for these proposed interpretations, rather than the start of that regime. Publication of the consultations does not itself finalise the guidance.

## Sources

- [GC26/7: Decentralised finance guidance (DeFi)](https://www.fca.org.uk/publications/guidance-consultations/gc26-7-decentralised-finance-guidance) — Financial Conduct Authority
- [CP26/36: Cryptoasset Perimeter Guidance](https://www.fca.org.uk/publication/consultation/cp26-36.pdf) — Financial Conduct Authority
- [GC26/7: Decentralised Finance (DeFi)](https://www.fca.org.uk/publication/guidance-consultation/gc26-7.pdf) — Financial Conduct Authority
- [CP26/36: Cryptoasset perimeter guidance](https://www.fca.org.uk/publications/consultation-papers/cp26-36-cryptoasset-perimeter-guidance) — Financial Conduct Authority
- [UK financial watchdog opens consultations for DeFi guidance, crypto laws](https://cointelegraph.com/news/uk-fca-consultations-defi-crypto-laws) — Cointelegraph

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