The UK’s Financial Conduct Authority (FCA) has published guidance consultation GC26/7, which sets out proposed non-Handbook guidance for firms providing financial services using decentralised finance (DeFi). The draft guidance is intended to help these firms comply with FCA rules on operational resilience and financial crime, as well as with the Money Laundering Regulations (MLRs). The consultation closes on 18 November 2026, and the regulator plans to publish final guidance in January 2027.
Scope of the proposed guidance
The consultation sets out the FCA’s observations on the current risk landscape relevant to DeFi, with a focus on operational resilience and financial crime. It also includes illustrative examples of measures that firms may wish to consider when managing these risks. As non-Handbook guidance, the document is designed to support firms in meeting existing obligations rather than to create new rules.
According to the regulator, the aim is to help firms manage these risks more effectively, which in turn is intended to protect consumers, uphold market integrity, and promote effective competition.
The FCA describes DeFi as a general term for financial services facilitated by distributed ledger technology, characterised by high levels of automation, open and interoperable technology, and, in some cases, the absence of a traditional intermediary. The regulator notes that these features can expose firms and their clients to increased operational resilience and financial crime risks. As with other technologies, firms using DeFi are expected to do so safely and responsibly.
Who the consultation applies to
The guidance is directed at FCA-regulated firms providing financial services using DeFi that fall within the scope of SYSC 15A on operational resilience, SYSC 6 on compliance, internal audit, and financial crime, or that are subject to the MLRs. The FCA has also indicated that the consultation may be relevant to a wider audience, including other regulated firms, entities not authorised by the FCA that interact with DeFi, industry groups and trade bodies, professional advisers, consumer representatives, policymakers, and other regulators, as well as academics and industry commentators.
Firms are asked to read GC26/7 alongside CP26/36, the FCA’s consultation paper on cryptoasset perimeter guidance. The regulator also points to its wider publications on the cryptoasset regime, including policy statements, and to its existing materials on operational resilience and its Financial Crime Guide.
Timeline and regulatory context
The consultation sits within a broader expansion of the UK’s cryptoasset framework. From 25 October 2027, the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 will bring new cryptoasset activities into the FCA’s regulatory perimeter. With final DeFi guidance scheduled for January 2027, the guidance is due to be in place roughly nine months before the new regime takes effect.
Responses can be submitted through the FCA’s online response form or by email. Respondents submitting by email are asked to indicate whether they want their response treated as confidential and whether they are content to be named. The FCA has stated that it will consider the feedback received and update the proposed guidance as appropriate.
For firms operating in or alongside DeFi, the consultation indicates how the FCA expects existing operational resilience, financial crime, and AML obligations to apply where services rely on automated, interoperable protocols, including arrangements without a traditional intermediary. Read together with the perimeter guidance in CP26/36, GC26/7 forms part of the material firms are expected to consider ahead of the 2027 regime.
