The UK’s FCA has published GC26/2: Application of the Consumer Duty to cryptoasset firms, providing detailed guidance on how the Consumer Duty should be applied to firms offering cryptoasset products to retail customers. This consultation is part of the FCA’s broader efforts to ensure that the emerging crypto sector operates with customer protection at its core.
Introduced in 2022, the Consumer Duty requires firms to act in good faith, avoid foreseeable harm and support customers in pursuing their financial objectives. While these principles already apply across financial services, GC26/2 provides important clarification on how they should be interpreted in the context of cryptoassets, recognising the sector’s distinct risks, complexity and market structure.
Who this guidance applies to:
The guidance is relevant to a broad range of firms, including those seeking Part 4A authorisation to carry out regulated cryptoasset activities for retail clients and authorised firms already subject to the Duty planning to expand into crypto.
The FCA makes clear that the guidance applies to all retail-facing activity, including financial promotions likely to be received by UK consumers. It acknowledges that cryptoassets often involve high volatility, innovative features and complex distribution chains, all of which increase the importance of careful product design, clear communications and strong governance.
Applying the Consumer Duty in a Crypto Context
GC26/2 reinforces the three cross-cutting rules that underpin the Consumer Duty:
- Firms must act in good faith, dealing honestly and fairly with customers and aligning with their reasonable expectations.
- Firms must avoid causing foreseeable harm, identifying and mitigating risks where possible without implying protection from inherent investment losses.
- Firms must enable and support customers’ financial objectives, ensuring customers are equipped to make informed decisions.
In a crypto context, this translates into clear expectations around product and service design, fair value assessments, and effective consumer support. Firms are expected to consider whether products are appropriate for their target market, whether charges reflect the benefits provided, and whether disclosures and communications genuinely support customer understanding.
The FCA recognises that cryptoassets can be high-risk and confirms that the Consumer Duty does not prevent firms from offering such products. However, firms must be able to demonstrate a reasonable basis for believing that customers understand the risks involved and are able to make informed choices.
Good and poor practice
To illustrate expectations, the FCA includes practical examples throughout the guidance. Good practice includes embedding customer-focused governance arrangements, documenting decision-making, providing clear and prominent risk warnings, and offering accessible consumer support across the customer journey.
By contrast, poor practice may include selling high-risk cryptoassets without adequate consideration of the target market, failing to explain key risks in a clear and balanced way, or distributing products through channels that increase the likelihood of consumer harm.
Next Steps, Implications and Conclusion
The consultation closes on 12 March 2026, with the FCA encouraging firms and stakeholders to engage and provide feedback. GC26/2 sits alongside CP26/4, which sets out proposed rules for regulated cryptoasset activities, and both consultations form part of the FCA’s preparations for the cryptoasset authorisation gateway, expected to open in September 2026.
Firms intending to operate in the UK crypto market should use this period to review their Consumer Duty frameworks through a crypto-specific lens, assess product governance and disclosure arrangements, and ensure pricing, communications and customer support meet FCA expectations. Early engagement with the guidance will help firms prepare for authorisation and reduce regulatory and conduct risk.
Overall, GC26/2 signals the FCA’s clear expectation that cryptoasset firms must meet the same high standards of consumer protection as the wider financial services sector, while allowing room for innovation where risks are properly managed and communicated.
How Complyport Can Help?
At Complyport, we help firms manage evolving regulatory reporting requirements by:
- Operational Planning and Compliance Strategy: Our team helps firms assess the operational impact of applying the Consumer Duty to cryptoassets, including changes to product design, disclosures, pricing structures and customer support models. We support the development of proportionate strategies that align systems, processes and controls with FCA expectations, enabling effective implementation with minimal disruption.
- Governance and Documentation: We assist firms in updating governance frameworks, policies and procedures to reflect the FCA’s expectations for cryptoasset firms under the Consumer Duty. This includes clarifying accountabilities, strengthening oversight arrangements and ensuring decision-making is appropriately documented to evidence compliance and customer-focused outcomes.
- Training and Ongoing Support: Applying the Consumer Duty effectively requires engagement across the business. Complyport delivers tailored training for Compliance, Product, Operations and Senior Management, ensuring all stakeholders understand their responsibilities in a crypto context. We also provide ongoing advisory support to help firms remain aligned with evolving FCA guidance and supervisory expectations.
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