MiCA Crypto Alliance and UK CBT Submit Joint Response to FCA Consultation CP25/25

The MiCA Crypto Alliance, together with the UK Centre for Blockchain Technologies (UK CBT), has submitted a joint response to the Financial Conduct Authority’s Consultation Paper CP25/25 on the application of the FCA Handbook to regulated crypto-asset activities. The response was endorsed, with further contributions from Alliance members the Cardano Foundation and Cointegrity. 

The consultation marks an important step in shaping the UK’s evolving regulatory framework for crypto-assets. Our response draws on practical experience from EU MiCA implementation, academic research, and engagement with firms preparing for authorisation.

Our contribution

Our response focuses on three areas highlighted by the FCA:

• Governance and conduct: We support the FCA’s proposal to align governance and conduct standards for crypto-asset firms with those for other FSMA-authorised entities. Our response highlights the need for independent oversight mechanisms and clear guidance for firms using automated or algorithmic strategies, including alignment with MiFID II RTS 6. We also emphasise adapted communication standards for decentralised environments and the importance of addressing conflicts of interest in vertically integrated business models.
• Operational resilience: We welcome the application of SYSC 15A but note that quantum transition risk remains insufficiently addressed. Our response recommends the inclusion of cryptographic-agility assessments, consideration of quantum disruption scenarios, and better guidance on managing dependencies on permissionless networks. We also encourage greater alignment between SYSC 15A and the EU Digital Operational Resilience Act (DORA).
• ESG Sourcebook application: We support applying the ESG Sourcebook to crypto-asset firms on a proportionate basis and without introducing additional crypto-specific indicators. Consistent requirements across FSMA-authorised sectors promote fairness and reduce unnecessary burdens. Our response also notes that sustainability data and methodologies developed under MiCA already provide transparent and reliable disclosures, and that voluntary use of these approaches can support best practice and improve alignment across regulatory frameworks.

Why it matters

As the FCA advances its regulatory regime for crypto-asset activities, clear and consistent expectations will be essential for crypto-asset firms preparing for FSMA authorisation. Academic and research institutions also have an important role in supporting supervisory capacity, whether through testing disclosure templates, validating sustainability metrics, or analysing operational resilience scenarios.

The MiCA Crypto Alliance and UK CBT remain committed to constructive engagement with regulators and to contributing practical, evidence-based insight to support effective implementation.

Download the full response here: https://www.micacryptoalliance.com/reports/response-to-fca-consultation-cp25-25