Our Response to the FCA’s CP26/32 on the Backbook Deferral

This week, Eunice AI submitted its response to the FCA’s CP26/32, focusing on deferral arrangements for the UK cryptoasset regime.

The FCA proposes giving platforms up to six months after authorisation to bring their existing assets (the “backbook”) in line with the new admissions and disclosures rules. We support a deferral, but have asked the FCA to consider giving firms more time. Our proposal of at least 12 months came out of conversations with the platforms we work with, many of whom are simultaneously resourcing for the 2027 MiCA whitepaper deadline.

We also noted that, in our experience, drafting the disclosure itself is not typically the most time-consuming part. The time goes on the work around it: the pre-admission assessment each asset still needs, legal and compliance sign-off where platforms are preparing their own qualifying cryptoasset disclosure documents (“QCDDs”), and outreach to issuers, whether to confirm information or to have them prepare the QCDD themselves.

Overall, a longer window lets those judgements be made properly, which we believe would lead to better disclosures.

Originally posted on LinkedIn by Chrislyn Pereira.