FCA feedback puts post-trade and collateral at heart of wholesale tokenisation

FCA wholesale tokenisation feedback puts post-trade and collateral in focus

The UK Financial Conduct Authority (FCA) has published feedback on tokenisation in wholesale markets, reporting 123 responses from industry bodies, firms and legal academics. The central signal for asset managers, market infrastructure providers and tokenisation teams is practical: respondents most often pointed to post-trade activity, particularly improving how collateral moves between parties, as a near-term opportunity.

The feedback statement, FS26/1, follows a joint FCA and Bank of England call for input. The regulator says it will use the responses to develop a joint tokenisation roadmap later in 2026, with target dates for its wholesale-market work. It is also consulting separately on tokenised gold and plans to consult on safeguarding rules for relevant specified investment cryptoassets in the first half of 2027.

Why post-trade is drawing attention

Post-trade processes connect the legal and operational record of a transaction with settlement, custody, collateral and reporting. Tokenised instruments may give market participants a shared, programmable record, but the FCA’s summary points to the coordination problem as much as the technology: firms need arrangements that work across counterparties and existing market infrastructure.

For fund managers and issuers assessing a tokenisation project, this makes interoperability and operating design concrete diligence topics. A useful pilot should define which asset or fund interest is represented, who maintains the authoritative ownership record, how transfers and restrictions are controlled, and how cash, collateral and settlement interact. It should also make clear which parties can act, what happens when a workflow fails, and how records reconcile with existing books and controls.

These are implementation questions, not a promise that distributed-ledger systems will automatically improve liquidity, reduce costs or remove legal obligations. The FCA’s feedback statement records industry views and planned regulatory work; it is not itself a new authorisation or a blanket approval of tokenised securities.

What firms can do while the roadmap develops

Firms can use the roadmap’s development period to map a specific workflow and test it with relevant counterparties. For a collateral use case, that means documenting eligibility rules, valuation inputs, transfer conditions, custody responsibilities, settlement finality and exception handling. For tokenised funds, it also means keeping the fund’s legal rights, investor register, dealing process and service-provider responsibilities aligned with the chosen technical model.

The FCA notes that its work builds on the UK’s Digital Securities Sandbox and its earlier policy statement on fund tokenisation. Those initiatives address different parts of the market; firms should assess which regime and rule set applies to their own activity rather than treating “tokenisation” as one regulatory category.

Source: FCA, FS26/1: Tokenisation in wholesale markets, published 14 September 2026. See also the FCA’s Digital Securities Sandbox and PS26/7 on progressing fund tokenisation.

Fundshing News provides market and regulatory information for industry professionals. This article is general information, not legal, regulatory or investment advice.

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