The guidance is non-binding, illustrative and non-exhaustive, and it does not prescribe a single methodology, so firms will choose their own approach. The materials do not explain how the FCA will decide when to require additional own funds or liquid assets, or what thresholds would trigger that. The publication date of FG26/9 is not stated, while FG26/10 is dated 30 September 2026. Firms that are also MIFIDPRU investment firms are excluded from this assessment and remain under MIFIDPRU 7.
The guidance sits under the prudential regime in PS26/12, published on 30 June 2026 as part of a five-document policy package. The regime rests on the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, passed on 4 February 2026. The FCA opened authorisation applications on 30 September 2026, and the regime applies to newly authorised firms from 25 October 2027. Firms seeking authorisation should build the overall risk assessment into their preparation now, since it will shape both the authorisation case and ongoing prudential arrangements. The assessment traces back to CP25/42, which modelled it on the ICARA process used for MIFIDPRU investment firms, so firms familiar with ICARA will find much of the structure recognisable.