UK FCA issues DeFi and crypto perimeter consultation papers

The significance here is procedural rather than substantive: the FCA is drawing the boundary of its regime before the regime exists, and the DeFi paper explicitly clarifies existing obligations instead of creating new ones, which suggests continuity for firms already operating under AML and resilience rules. The crypto perimeter paper matters most for stablecoin payments and settlement arrangements, where exemptions determine who falls inside the regime and who does not. The long runway—consultations closing in November, final guidance in January 2027, regime effective October 2027—means the open question is whether firms treat this as a planning horizon or wait for final text.