QCDDs Explained: What the FCA’s New Crypto Disclosure Rules Require

The Financial Conduct Authority's (FCA) new cryptoasset regime will introduce a more comprehensive framework for the UK cryptoasset market. It covers areas including cryptoasset firms, admission to trading, disclosure, prudential resilience and market conduct.

The transition to the new regime is already underway. The FCA published its final rules on cryptoasset admissions, disclosures and market abuse on 30 June 2026. The application window for firms seeking authorisation under the new regime opens on 30 September 2026 and closes on 28 February 2027. The new regulation is scheduled to take effect on 25 October 2027. The requirements discussed in this article have therefore been finalised but are not yet in force as of publishing.

One important part of the new admissions regime is the Qualifying Cryptoasset Disclosure Document (QCDD), which introduces a formal disclosure mechanism for qualifying cryptoassets.

What is a QCDD?

A QCDD is a disclosure document that sets out the information material to a person considering buying or subscribing for a qualifying cryptoasset. The information must enable that person to make an informed assessment of the cryptoasset.

There are also some functional similarities between a QCDD and a crypto-asset white paper under the EU Markets in Crypto-Assets Regulation (MiCA). However, the two regimes differ materially in their structure and requirements. In particular, the UK framework gives retail UK qualifying cryptoasset trading platforms (QCATPs) a significant role in admission, disclosure and due diligence.

Where the relevant retail requirements apply, the platform does more than simply provide a venue for trading: it also has regulatory responsibilities connected with admitting cryptoassets to trading.

The UK cryptoasset regime, through this documentation,  aims to improve the quality and accessibility of information available when cryptoassets are admitted to trading, while strengthening consumer protection and making clear who is accountable for the disclosures.

The anatomy of a QCDD: core content requirements

The FCA has adopted an outcomes-based disclosure framework rather than prescribing a single rigid template for every qualifying cryptoasset.

This means that producing a QCDD is not simply an exercise in completing a fixed set of fields. The disclosure needs to reflect the particular cryptoasset and provide the material information needed by someone considering buying or subscribing for it.

Retail UK QCATPs therefore have an important role in determining what information is required for an admission. They may require additional information where this is appropriate given the characteristics and risks of a particular qualifying cryptoasset.

What information must a QCDD contain?

A QCDD must cover the following where they apply to the asset. The FCA’s guidance sets out what it expects to see under each.

• Features: the rights and obligations attached to the asset, its governance, how it is created, destroyed and distributed, and any underlying assets.
• Technology: the underlying technology, including protocols and consensus mechanism, its operational resilience, known vulnerabilities and any audits.
• Ownership and trading: ownership concentration, lock-ups for existing holders, trading performance and any major events that have affected the asset or its value.
• Risks and conflicts: the risks of holding the asset and any conflicts of interest, including any financial interest the platform has in it.
• People and control: matters about those who offered, created or control the asset that could affect its price or value.
• Identification: the Digital Token Identifier, or an alternative identifier only where none exists, and the name of the person requesting admission with their Legal Entity Identifier if they have one.

Where the platform could not obtain or verify information, the QCDD must say so clearly.

Each QCDD must also include a summary of no more than two A4 pages. It sets out the asset’s key features and risks, points to the detail in the full document and warns readers not to rely on the summary alone.

The summary is not intended simply to repeat technical specifications. Its purpose is to present key information about the qualifying cryptoasset in an accessible way. It gives readers an entry point into the fuller disclosure and helps prevent important information from being obscured by technical or legal detail.

QCATP due diligence and admission standards

A QCDD does not stand alone. It forms part of a wider admission process.

Before admitting a qualifying cryptoasset, a retail UK QCATP must carry out due diligence. It may only admit the asset if it is reasonably satisfied that admission is not likely to be detrimental to the interests of retail investors. The assessment must be risk-based and proportionate. It applies whether or not the asset is already traded on another platform.

To carry out that assessment, the platform must set admission criteria. The criteria must be risk-based and objective. They must take into account at least:

• the integrity and reputation of the people behind the asset and its admission, including its creator and the person requesting admission;
• the resilience, functionality and credibility of the asset’s governance and operational arrangements;
• any known risks in the underlying technology, such as the ledger infrastructure or smart contracts;
• whether those responsible for the QCDD could pay compensation if required to; and
• whether the information the platform obtains can be verified.

The platform’s governing body must approve the criteria, review them regularly and publish them on the platform’s website. The platform must apply them consistently.

Due diligence also reaches the QCDD itself. Before the platform publishes it, the platform must be reasonably satisfied that it contains the required information and is not untrue or misleading. The FCA expects checks such as confirming the identity of the people named, comparing claims about the asset’s features with its code and on-chain behaviour, and testing supply and lock-up information against on-chain data.

The rules also address conflicts of interest. Where a platform admits an asset of its own motion, or at the request of a group company, it must make sure its criteria are not applied less rigorously. It must keep the commercial decision separate from the assessment, and the people making the commercial decision must not carry out the assessment.

Admission to a retail UK QCATP is therefore a regulated assessment, not only a commercial decision.

Publication, filing and accessibility

Before admitting a qualifying cryptoasset, a retail UK QCATP must publish the QCDD on its website and upload it to the FCA-owned centralised repository for cryptoasset disclosures. The platform does this whether the QCDD was produced by the person requesting admission or by the platform itself. It must also keep a list on its website of the QCDDs and Supplementary Disclosure Documents for the assets it has admitted.

The FCA does not approve a QCDD before publication. Each QCDD and its summary must state clearly that the FCA has not approved it.

What happens if something changes before admission?

If new information, or a mistake or inaccuracy, comes to light after publication and before admission, and it may be material to someone considering buying or subscribing, the person who produced the QCDD must produce a Supplementary Disclosure Document (SDD). The platform cannot admit the asset until it has checked the SDD, published it on its website and uploaded it to the repository.

The QCDD itself is not amended. Any change or correction appears in the SDD.

Publishing an SDD can also give a buyer a right to withdraw. This applies to qualifying cryptoassets other than UK qualifying stablecoins, where:

• the buyer or subscriber agreed to buy after the QCDD was published;
• the SDD was published after that agreement; and
• the circumstances requiring the SDD arose or were noted before admission.

The buyer has two working days from publication of the SDD to withdraw, unless the person responsible for the offer, or the intermediary, allows longer.

After admission, the FCA does not require a QCDD to be updated. Continuing disclosure is principally dealt with through the Market Abuse Regime for Cryptoassets (MARC).

Legal accountability and liability

Who is responsible for a QCDD?

Responsibility for a QCDD attaches to the people involved in the admission rather than to an issuer as such. Three groups are responsible for a QCDD and any Supplementary Disclosure Document: the person who requested the admission, where the asset is admitted as a result of that request; the retail UK QCATP, where it admitted the asset of its own motion; and anyone who accepts responsibility and is stated in the document as doing so.

The rules do not depend on there being an identifiable issuer, so they apply where an asset has none. The responsible person may therefore be someone other than the person who created the asset. Giving advice about a QCDD’s contents in a professional capacity does not, on its own, make someone responsible for it.

What happens if the disclosure is defective?

A person responsible for a QCDD must pay compensation to anyone who bought or subscribed for the asset and suffered loss because the document contained an untrue or misleading statement or left out a matter the regulations require it to include. The same applies to loss caused by a failure to publish a Supplementary Disclosure Document that the rules require.

Liability is not automatic. The buyer must have bought in reliance on the document. A claim based on the summary succeeds only where the summary, read with the rest of the document, is misleading, inaccurate or inconsistent, or lacks the key information the rules require. A responsible person is also not liable if they satisfy a court that they reasonably believed, after reasonable enquiries, that the statement was true and not misleading, subject to further conditions. The regulations contain other exemptions as well.

A more formal framework for cryptoasset admissions

Taken together, the rules give admission to a retail UK QCATP a clear sequence. The platform assesses the asset against criteria it has published and satisfies itself that admission is unlikely to harm retail investors. A QCDD, produced by the person requesting admission or by the platform itself, sets out what a buyer needs to make an informed assessment. The platform checks that document, publishes it and uploads it to the FCA repository. If material information changes before admission, a Supplementary Disclosure Document corrects the record, and buyers who agreed earlier may be able to withdraw. Throughout, named people stand behind what the document says, and they can be liable to pay compensation if it is wrong.

The practical effect is that the quality of disclosure at admission now has an owner. Platforms must treat admission as a regulated assessment, not only a commercial decision. Those requesting admission must prepare a document they may have to answer for. Buyers receive a defined set of information and a route to recover loss where it falls short.

None of this removes the risks of cryptoassets. A QCDD tells buyers what they are buying and who answers for the description. It does not tell them whether the asset will hold its value.

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