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FCA Finalises Overall Risk Assessment Guidance (FG26/9, FG26/10) for UK Cryptoasset Firms

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Why it matters

The FCA has finalised two non-Handbook guidance documents on the overall risk assessment under its new prudential regime for cryptoasset firms: FG26/9, on COREPRU 7, and FG26/10, on CRYPTOPRU 7. The FCA published them alongside feedback statements responding to consultations GC26/4 and GC26/5. The guidance explains how firms should run the assessment, which the FCA treats as the main tool for setting the own funds and liquid assets needed to meet the overall financial adequacy rule. Firms should identify risks, run stress tests, plan recovery actions and prepare for wind-down. FG26/9 presents risk appetite, early warning indicators and triggers as best practice. The assessment must be reviewed at least every 12 months and after any material change, and firms must keep records for at least three years. After supervisory review, the FCA may require additional own funds or liquid assets. Both documents take effect on 25 October 2027.

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.

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