From blueprint to production: The FCA finalises its fund tokenisation framework

On 30 April 2026, the FCA published PS26/7 (the Policy Statement). The Policy Statement finalises the framework the FCA consulted on in CP25/28 (the Consultation Paper), which concerns the use of distributed ledger technology (DLT) in authorised funds. We discussed the Consultation Paper in our previous briefing and blog post. The Policy Statement also introduces an optional Direct to Fund (D2F) dealing model that can be used by both conventional and tokenised funds. The new rules and guidance came into force on the day they were published (i.e. 30 April 2026).

The FCA’s final position broadly builds on its earlier Consultation Paper, but there are several material refinements in the Policy Statement which reflect industry feedback:

1. For tokenised funds, the FCA: (i) clarifies its expectations around control of the unitholder register, smart contracts and whitelisting in the context of DLT registers; and (ii) confirms that units of the same class may be issued across multiple blockchains.
2. For D2F, the FCA has dropped the proposed prohibition on Authorised Fund Managers (AFMs) dealing as principal and has replaced the standby AFM client money account proposal for unattributable cash with more practical enhanced reconciliation and return requirements.
3. To help firms comply with existing regulatory requirements when using DLT, the FCA now expressly accepts that on-chain records of unit transactions may be considered as the primary books and records of transactions. Specifically, they confirm that no full off-chain mirror is required where appropriate operational resilience and backup plans are in place.

Our client briefing explains in more detail the key changes the FCA has implemented in response to industry feedback.