On 22 September 2025, the UK and U.S. governments announced the creation of a Transatlantic Taskforce for the Markets of the Future, a strategic initiative aimed at deepening cooperation on capital markets and digital asset regulation. The agreement was reached during talks between UK Chancellor Rachel Reeves and U.S. Treasury Secretary Scott Bessent in Downing Street, coinciding with President Donald Trump’s state visit.

The task force will be jointly chaired by officials from HM Treasury and the U.S. Treasury, with participation from key regulators including the FCA and the SEC. It will report back within 180 days via the UK-U.S. Financial Regulatory Working Group, and will focus on:

• Short and medium-term collaboration on digital assets while legislation and regulatory regimes continue to evolve;
• Reducing cross-border capital-raising burdens for UK and U.S. firms; and
• Exploring long-term opportunities for innovation in wholesale digital markets.

The initiative forms part of a broader strategy to reinvigorate the UK’s financial services sector. HM Treasury has described the task force as a vehicle to “drive innovation and growth in global markets,” with a particular focus on shaping future regulatory frameworks for digital assets. At the same time, the move reflects the U.S.’s increasingly crypto-friendly posture under the Trump administration, which has introduced landmark stablecoin legislation and rolled back enforcement actions against major crypto firms.

On 14 October 2025, the FCA published a consultation paper setting out its plans to progress the tokenisation of funds – that is, the digital representation of interests in investment funds, using distributed ledger technology (DLT).

In outline, the main proposals in the consultation are:

• Guidance for operating a tokenised fund under the Blueprint model: The industry-led Technology Working Group (TWG) published a report in November 2023 setting out how firms can operate a tokenised unitholder register within existing legal and regulatory frameworks – known as the Blueprint model. The consultation contains additional guidance from the FCA to assist firms who wish to use the Blueprint model or more advanced models that are set out in the consultation.
• Rules and guidance for a “direct to fund” (D2F) model: The consultation sets out proposals for an alternative, streamlined dealing model for conventional and tokenised authorised funds, referred to as “direct to fund” (D2F).
• Roadmap for fund tokenisation and tokenised money market funds (TMMFs): The consultation includes details of how the FCA intends to support two use-cases that the TWG had previously identified as priority matters: (i) fully on-chain investment markets, with tokenised funds investing in tokenised securities such as fixed-income or other asset classes; and (ii) the use of TMMF units as eligible collateral in accordance with the rules for non-centrally cleared derivative contracts.
• Future tokenisation models: The consultation includes a discussion on future tokenisation models that use DLT to provide tokenised portfolio management for retail investing at scale and how regulation may need to change to be fit for the future.

The consultation closes on 21 November 2025 in respect of most of the proposals and on 12 December 2025 in respect of the future tokenisation models.

The FCA expects to publish a policy statement, which will contain final rules, in the first half of 2026.

For more on this development, take a look at this Our Thinking article.

On 1 October 2025, Bank of England Governor Andrew Bailey published an article in the Financial Times signalling a notable softening in the central bank’s stance on stablecoins. Bailey wrote that it would be “wrong to be against stablecoins as a matter of principle,” acknowledging their potential to drive innovation in domestic and cross-border payment systems.

This marks a departure from Bailey’s earlier position, including his July 2025 Mansion House speech, where he stated that stablecoins were not a substitute for commercial bank money. The Bank of England has faced criticism for its earlier proposal to cap stablecoin holdings at £10,000–£20,000 for individuals and £10 million for businesses, a move industry groups have called “unworkable” and damaging to UK competitiveness.

In his latest remarks, Bailey suggested that the financial system “does not have to be organised” around the current reliance on bank lending, and that stablecoins could coexist with banks, with non-bank entities playing a larger role in credit provision.

The article also addressed operational risks, including the need for insurance schemes and resolution frameworks to protect holders in the event of insolvency. Bailey emphasised that stablecoins must be backed by risk-free assets, and must be directly exchangeable into fiat currency.

Looking ahead, Bailey confirmed that the Bank will publish a consultation paper later this year outlining a regulatory regime for UK-issued stablecoins.

On 2 October 2025, it was reported that Thailand’s Securities and Exchange Commission (SEC) has confirmed plans to expand the scope of domestic cryptocurrency exchange-traded funds (ETFs) beyond Bitcoin. The move reflects rising demand for more diverse investment opportunities in the country’s fast-growing crypto market.

Under the new framework, local mutual funds and institutional investors will be permitted to offer ETFs that include a wider range of cryptocurrencies – such as Ethereum and Solana – rather than being restricted to single-asset products. This marks a strategic move aimed at attracting institutional investors and provide more options for Thai investors who wish to diversify their portfolios with digital assets. Thailand’s first Bitcoin ETF was approved earlier in 2024, but this new initiative will open the door to a broader selection of cryptocurrencies.

Currently, Thai investors can only access crypto ETFs via licensed asset managers investing in overseas products. The new initiative would enable domestic offerings, improving accessibility and market depth. It also comes amid a 7.6% decline in the Stock Exchange of Thailand this year, prompting regulators to modernise investment options.

On 24 September 2025, the Australian Government published the Treasury Laws Amendment (Regulating Digital Asset, and Tokenised Custody, Platforms) Bill 2025 for public consultation. The draft legislation proposes to bring digital asset platforms and tokenised custody platforms within the scope of the Corporations Act 2001, formally recognising them as financial products. The move delivers on a commitment made in the 2024–2025 Budget to modernise Australia’s digital asset regulatory framework.

The proposed regime aims to close existing regulatory gaps and provide legal clarity around digital assets and the infrastructure supporting them. It adopts a “same risk, same regulation” approach, aligning with international peers such as the EU and UK, while using Australia’s domestic concepts of “financial product” and “financial service.” Notably, the draft legislation avoids defining “digital assets” directly. Instead, it introduces references to “digital tokens” to ensure the law remains technology-neutral. Rights associated with digital tokens may be treated as financial products depending on the legal recognition of the holder’s position.

The legislation also introduces two new financial products – digital asset platforms and tokenised custody platforms – subject to existing licensing and consumer protection rules. Providers will be required to hold an Australian Financial Services Licence and comply with targeted obligations. Platforms handling less than A$5,000 per customer and processing under A$10 million annually will be exempt.

The consultation closed on 24 October 2025.

On 3 October 2025, it was reported that the National Bank of Kazakhstan had confirmed that its central bank digital currency (CBDC), the digital tenge, and the newly launched Evo stablecoin are not in competition but are designed to serve complementary roles within the country’s digital asset ecosystem.

The Evo stablecoin, developed in partnership with Solana and Mastercard, is part of Kazakhstan’s broader strategy to become a regional crypto hub. It is issued by Intebix exchange and Eurasian Bank under the central bank’s regulatory sandbox. Meanwhile, the digital tenge, launched in 2023, is being piloted as legal tender and is expected to play a key role in interbank settlements.

According to the press report, the National Bank’s Deputy Governor stated that stablecoins like Evo are intended for specific ecosystems and private-sector use cases, while the digital tenge will serve as a sovereign payment instrument and foundation for fintech innovation. The government is working to establish the digital tenge as legal tender, with plans for broader circulation once the regulatory framework is finalised.

On 27 September 2025, Poland’s lower house of parliament (the Sejm) passed the Crypto-Asset Market Act (Bill 1424), introducing a licensing regime for crypto-asset service providers (CASPs) and aligning national regulations with the EU’s Markets in Crypto-Assets (MiCA) framework.

The bill designates the Polish Financial Supervision Authority (KNF) as the primary regulator and requires all CASPs – including exchanges, issuers, and custodians, both domestic and foreign – to obtain a KNF licence. Applicants must submit detailed documentation covering corporate structure, capital adequacy, compliance systems, risk management, and AML procedures.

Violations of the new regime could result in fines of up to 10 million Polish zlotys (approx. $2.8 million) and prison terms of up to two years. If enacted, CASPs will have a six-month transitional period to comply.

The bill now moves to the Senate for further consideration.

The Digital Assets (Scotland) Bill was introduced in the Scottish Parliament on 30 September 2025 as a result of the Scottish Government's Programme for Government's commitment to ‘clarify the status of digital assets as property in Scots private law, to provide greater legal certainty for individuals and for businesses including those investing in digital assets, for technology and financial start-ups, as well as for the legal sector'.

The Bill confirms that certain kinds of digital asset (like cryptocurrency) can be objects of property in Scots private law, confirms how to acquire and own these digital assets, and ensures the general principles of Scots private law apply to these digital assets. 

On 25 September 2025, it was reported that the People’s Bank of China (PBOC) has officially launched a digital yuan operations centre in Shanghai, marking a strategic milestone in the country’s central bank digital currency (CBDC) rollout. The centre will oversee cross-border payment networks, blockchain services, and digital asset platforms, reinforcing the digital yuan’s role in international finance.

The initiative reflects Beijing’s broader ambition to internationalise the yuan and reduce reliance on the U.S. dollar in global trade. Three core platforms were unveiled at the launch:

• A cross-border payments system to facilitate faster, cheaper international transactions;
• A blockchain services platform, powered by the domestic Chang’an Chain, aimed at secure and scalable financial applications; and
• A digital asset platform integrated with the Shanghai Clearing House, enabling real-time settlement of tokenised assets.

On 30 September 2025, the New York State Department of Financial Services (NYDFS) issued guidance to update and replace the previous 23 January 2023 Guidance on Custodial Structures for Customer Protection in the Event of Insolvency. The updated guidance provides additional direction for virtual currency entities that act as custodians (VCE Custodians), particularly with regard to sub-custodians, while continuing to emphasize sound custody and disclosure practices to protect customers in the event of an insolvency or similar proceeding.

The U.S. Department of the Treasury issued an Advance Notice of Proposed Rulemaking on 18 September 2025 seeking public comment related to the Treasury's implementation of the GENIUS Act, since the statute tasks Treasury with issuing regulations that encourage innovation in payment stablecoins while also providing an appropriately tailored regime to protect consumers, mitigate potential illicit finance risks, and address financial stability risks. The Treasury invited the public to offer comments, including providing data and other information, that may be useful for Treasury to consider. Comments had to be received before 20 October 2025.

On 8 October 2025, it was reported that India’s Union Minister of Commerce and Industry had announced plans to introduce a digital currency backed by the Reserve Bank of India (RBI), as part of a broader effort to integrate blockchain technology into the country’s financial infrastructure.

The RBI-backed digital currency, designed to function similarly to traditional fiat, will be fully government-backed and aims to enhance transaction efficiency, security, and transparency. Each transaction will be verifiable, helping to curb illegal or untraceable transfers. The initiative draws parallels with regulated stablecoins in the U.S. under the GENIUS Act but remains sovereign in nature.

This move aligns with the RBI’s ongoing efforts to develop its central bank digital currency (CBDC), the Digital Rupee, which recently entered a retail sandbox phase. The sandbox is testing the currency’s performance in real-world retail scenarios, including merchant payments, wallet interoperability, and offline transactions. Select banks, fintechs, and merchants are participating in controlled environments across major cities.

On 15 October 2025, the Bank of England (BoE) published a document that sets out its approach to innovation in AI, distributed ledger technology (DLT) and quantum computing. It has focused on these three technologies as it has identified them as being those that currently have the greatest potential to shape the UK economy and financial services.

The document covers work that the BoE has done and planned future work. For example, the BoE refers to its recently launched DLT Innovation Challenge, which engages with the private sector to better understand the implications of incorporating DLT into wholesale central bank settlement. Through this initiative, the BoE will look to determine if wholesale central bank money can be securely transacted and settled on external, programmable ledgers not controlled by the central bank.

There is also reference to the BoE’s approach to innovation in money and payments, along with the National Payments Vision and the development of a new model to deliver the next generation of UK retail payments infrastructure.

On 16 October 2025, the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) published complementary reports setting out high-level recommendations for the regulation and oversight of cryptoassets and global stablecoins (GSCs). An overview of the scope and findings of their reports was also published in a joint information note.

The reports are based on thematic implementation reviews carried out by the FSB and IOSCO in 2025 in over 40 jurisdictions.

The FSB's peer review focuses on financial stability and assesses the implementation progress by FSB jurisdictions and some volunteering non-FSB jurisdictions in implementing its July 2023 global regulatory framework for cryptoasset activities. The FSB has also published an interactive map showing the implementation status of each participating jurisdiction for both cryptoassets and GSCs.

The review highlights the notable progress of jurisdictions in regulating cryptoasset activities but notes slower progress to develop GSC arrangements. Overall, significant gaps and inconsistencies remain. Eight recommendations are made to assist jurisdictions as they further develop their regulatory regimes.

IOSCO's thematic review report, conducted jointly by its Fintech Task Force and its Assessment Committee, assesses the implementation of a subset of ten recommendations from IOSCO's 18 policy recommendations for crypto and digital asset (CDA) markets (November 2023). The CDA recommendations assessed were those most directly relevant to IOSCO's market integrity and investor protection objectives. Among other things, the review found that jurisdictions had made progress in implementing the key elements of the assessed recommendations and in regulating cryptoasset markets. However, risks remain within the fast-evolving cryptoasset ecosystem.

The key areas identified for continued progress include promoting greater consistency in implementation, reducing risks of regulatory arbitrage and strengthening enforcement practices. Appendix 1 to the report contains a full list of the policy recommendations.

The report is an initial assessment conducted under IOSCO's cryptoasset implementation roadmap, and its findings will inform the development of an assessment methodology for future assessments.

On 8 October 2025, the Bank of England (BoE) published a speech by Sasha Mills, Executive Director, Financial Market Infrastructure (FMI), on how innovation is shaping the UK financial system and how the BoE's approach to regulation supports responsible innovation. Key points from the speech include:

• Stablecoins could change market structures by weakening the link between money and the creation of credit (the traditional stronghold of banks), with the introduction of more market-based finance. By imposing holding limits to stablecoins, the BoE will be able to learn more about the impact on the cost and availability of credit and to reduce the risk of a disorderly transition. A consultation on regulating systemic stablecoins is due to be published by the BoE later in 2025.
• New technologies are changing the way transactions are executed and how systems interact, introducing some challenges e.g. when applying decentralised, DLT-based transaction models. Market fragmentation is also a possibility with the introduction of new platforms and protocols. To avoid resultant inefficiencies, siloed liquidity and restricted interoperability, standards will need to be established.
• The BoE addresses emerging risks by concentrating on the activities themselves, rather than solely on who performs them. This may result in regulating less in aggregate, e.g. the BoE may do less in the early stages of novel businesses, but put greater emphasis on areas that matter most.
• The Payments Vision Delivery Committee (PVDC), of which the BoE is a member, will publish its strategy for retail payments later in 2025.

Latest publications relating to the Regulation on markets in cryptoassets ((EU) 2023/1114) (MiCA) include the following:

• On 3 October 2025, Commission Delegated Regulation (EU) 2025/1264, which supplements MiCA with regard to regulatory technical standards (RTS) on the minimum contents of the liquidity management policy and procedures for certain issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs), was published in the Official Journal of the European Union. It entered into force on 23 October 2025.
• On 10 October 2024, the European Banking Authority (EBA) published the following two opinions responding to the amendments proposed by the European Commission to its draft RTS on specifying the highly liquid financial instruments (HLFI) with minimal market, credit and concentration risk, and on the liquidity requirements of the reserve of assets under MiCA:
  • Opinion on the Commission's amendments relating to the final draft RTS to further specify the liquidity requirements of the reserve of assets under Article 36(4) of MiCA (dated 9 October 2025); and
  • Opinion on the Commission's amendments relating to the final draft RTS to specify the HLFI with minimal market risk, credit risk and concentration risk under Article 38(5) of MiCA (dated 9 October 2025).

The EBA sets out amended draft RTS in an Annex to each of the opinions and has submitted these to the Commission for endorsement, after which the final draft RTS will be subject to scrutiny by the European Parliament and the Council of the EU before being published in the Official Journal of the European Union.

In a recent interview with the FT, Verena Ross, chair of the European Securities and Markets Authority (ESMA), confirmed that the European Commission is drawing up plans to transfer the regulation of several areas of EU financial markets, including crypto, from national authorities to ESMA.

On 9 October 2025, the European Banking Authority (EBA) published a report on tackling money laundering (ML) and terrorist financing (TF) risks in cryptoasset services through supervision.

The report summarises lessons learned from actions taken by the EBA and by competent authorities responsible for anti-money laundering (AML) and counter-terrorist financing (CTF) relating to the identification and management of ML and TF risks associated with cryptoasset businesses. It considers the period before and immediately after the implementation of the regulatory framework introduced in December 2024 by the Regulation on markets in cryptoassets ((EU) 2023/1114) (MiCA) and the extension of the AML framework to cover custodian wallet providers and providers engaged in exchange services between virtual and fiat currencies made by the Fifth Money Laundering Directive ((EU) 2018/843) (MLD5).

The EBA calls on competent authorities to draw on the lessons learned from the report to manage the challenges and ML-TF risks associated with cryptoasset service provision. It considers that the new authorisation process should act as an effective "gatekeeper", as it enables competent authorities to verify compliance with regulatory requirements and ensure that key risks inherent in firms' business models are managed before granting authorisation.

The EBA will transfer its standalone AML and CTF powers and mandates to the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) on 31 December 2025. Following this, it intends to continue to play a key role in the crypto sector in relation to financial crime and supervisory convergence through its mandate under MiCA.