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FCA Cryptoasset Market Abuse Regime: What PS26/9 Says About MARC

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The phrase FCA cryptoasset market abuse regime is used here to explain the FCA’s published final framework in PS26/9. The article stays within the FCA’s own descriptions of the Market Abuse Regime for Cryptoassets (MARC) and does not make findings about real-world conduct or entities.

PS26/9 is part of the FCA’s wider cryptoasset-policy package. This explainer distinguishes its final-rule framing from the separate questions that arise when applying rules to particular facts, which are outside the scope of this article.

Editorial scope: This is general public information based only on FCA publications. It does not assess any person, platform, asset, transaction, communication or alleged event, and it is not investment, legal, tax, compliance or regulatory advice.

Abstract blockchain network, protective shield and magnifying glass for FCA cryptoasset market abuse regime public-information article

FCA source boundary

This article is general editorial information based on FCA publications. It does not assess any person, platform, asset, transaction, communication or alleged event. It is not investment, legal, tax, compliance or regulatory advice.

The content that follows draws only on the two FCA documents authorised for this piece: the FCA’s overview of its cryptoassets regime policy statements and the PS26/9 policy statement document. Where the piece refers to defined terms, statutory references or the structure of rules, those references reflect the language and framing used in those two sources. No material beyond those two documents has been used to inform the explanatory narrative.

The boundaries of this article are therefore limited. It explains how the FCA frames the Market Abuse Regime for Cryptoassets (MARC) within the published rule set, and it clarifies the status and sequencing the FCA itself gives to those rules. It does not draw or imply findings about specific conduct, nor does it describe the application of the rules to particular cases or entities.

What PS26/9 is

PS26/9 is the FCA policy statement that sets out final material on two linked areas: admissions and disclosures, and the Market Abuse Regime for Cryptoassets (MARC). The document contains the FCA’s final rules and supporting text as issued in June 2026. It identifies the regulatory provisions included in CRYPTO 4 and describes the prohibitions and obligations that CRYPTO 4 introduces for market participants within its defined scope.

The policy statement explains that the MARC framework prohibits insider dealing, unlawful disclosure of inside information and market manipulation as defined in the CRYPTO 4 provisions. It sets out expectations regarding proportionate systems and controls for UK qualifying cryptoasset trading platforms and their permitted operators (UK QCATPs) and intermediaries. PS26/9 also specifies additional obligations for entities categorised by the FCA as large UK QCATPs, including measures the FCA describes as on-chain monitoring and enhanced information sharing across platforms.

Readers who wish to consult the source document can access the PS26/9 policy statement directly from the FCA’s publication of the final rules. The policy statement is the authoritative record of the final-rule text and the FCA’s explanatory material for these measures.

For the FCA’s published overview of the whole cryptoasset regime, readers should consult the FCA’s separate overview publication, which explains how PS26/9 sits alongside other CRYPTO modules and the FCA’s timetable for the regime’s broader implementation.

PS26/9: Crypto Regime: Admissions & Disclosures and Market Abuse Regime for Cryptoassets

How MARC sits within the FCA cryptoasset regime

MARC is the FCA’s market-abuse-focused component of the broader cryptoasset rule package. In the FCA’s published structure, MARC appears as CRYPTO 4. It complements other CRYPTO modules that cover admissions, disclosures and due diligence processes for cryptoasset offers and platforms, which are set out separately in the FCA materials.

The CRYPTO 3 and CRYPTO 4 distinction matters for scope: CRYPTO 3 addresses admissions and disclosures while CRYPTO 4 sets out market-abuse prohibitions and accompanying systems and controls expectations. PS26/9 therefore states that MARC should be read as part of the overall cryptoasset regime but with a specific market-integrity purpose and a distinct set of obligations aimed at market-abuse risks in cryptoasset markets.

Within that architecture, the FCA identifies particular regulated persons and activities that fall within MARC’s reach. The terminology used in the published material includes UK QCATP for qualifying cryptoasset trading platforms and their permitted operators, and a further category of large UK QCATP that the FCA treats as subject to additional duties. Intermediaries that participate in cryptoasset trading ecosystems are also referenced in relation to obligations under CRYPTO 4.

MARC therefore occupies a defined place in the FCA’s rule map: it is the module that places market-abuse prohibitions and associated controls on specified entities and activities, operating alongside the admissions and disclosure rules that govern offers and platform authorisations.

The FCA’s stated market-integrity purpose

The FCA frames MARC with a stated market-integrity purpose. The policy statement and overview materials explain that the regime is intended to address risks to market integrity arising in cryptoasset markets, including risks the FCA characterises as comparatively higher than in more established markets.

To pursue that purpose, PS26/9 sets out prohibitions on insider dealing, unlawful disclosure of inside information and market manipulation, and it describes systems and controls expectations for affected firms. The FCA also explains why certain additional measures apply to larger platforms and intermediaries, linking those measures to the FCA’s view of differential risk and the need for proportionate responses.

In its overview of the wider cryptoasset regime, the FCA gives contextual commentary on the residual risks it sees in cryptoasset markets and on the intended public-interest rationale for bringing market-abuse rules into the cryptoasset rule book. That framing is present to explain why the FCA has chosen to apply market-abuse constructs to cryptoasset activities, while recognising the technical and market-structure differences between cryptoasset markets and more established financial markets.

That stated market-integrity purpose underpins the content and structure of CRYPTO 4 as published in PS26/9, and the FCA’s explanatory materials set out how obligations under MARC relate to broader disclosure and admissions rules in the cryptoasset regime.

The final-rule status of PS26/9

The FCA’s published PS26/9 contains final rules and explanatory material. The document is explicit in presenting this content as final policy material, indicating the rule text the FCA has decided to make and the accompanying guidance it has chosen to publish at the time of issue.

As the FCA’s final policy statement on these topics, PS26/9 records both prohibitions and specified obligations that will apply to regulated persons and activities within the regime’s defined scope. The statement outlines changes introduced at final rule stage compared with earlier consultations, including adjustments described by the FCA to on-chain monitoring obligations, clarifications on unlawful disclosure of inside information, intermediary notification processes and refinements to examples of legitimate market practices and inside information.

Readers should note that final-rule status in PS26/9 means the FCA has completed its policymaking steps for the content captured in that statement; it does not, however, mean that every element of the broader cryptoasset regime is immediately in force for all entities. The FCA’s own overview material explains the sequencing and timing for the wider roll-out of the regime’s applied scope.

What the wider 2027 date means in the FCA overview

The FCA’s overview of its cryptoassets regime policy statements sets out a timetable and sequencing for the regime’s full application. That overview explicitly states that the broader regime’s full scope expands from 25 October 2027. This date is the FCA’s stated milestone for the expansion of regulated activities within the regime as set out in the overview publication.

The overview also explains that, while PS26/9 contains final rules on MARC and admissions and disclosures, the FCA regards some aspects of the overall cryptoasset regime as phased in or subject to transitional arrangements. The 25 October 2027 date in the FCA overview therefore functions as a forward marker for when the FCA expects the regime’s wider set of regulated activities to be in scope in the way the overview describes.

It is important to observe the distinction between the legal status of PS26/9 as a final policy statement and the FCA’s separate timetable guidance in the overview document. The overview explicitly signals that the full scope of regulated activities broadens from the stated 2027 date; the FCA uses that forward sequencing to explain how different modules of the cryptoasset regime interact across time.

Accordingly, the overview should be read alongside PS26/9 to understand both the content of final rules and the FCA’s intended sequencing for broader regime application. For the FCA’s published explanation of timing and scope, consult the FCA’s overview page on its cryptoasset regime policy statements.

Overview of our cryptoassets regime policy statements

Why this article does not make conduct findings

This article explains the content and status of FCA publications. It does not make conduct findings about any person, platform, asset, transaction, communication or alleged event. The source materials themselves set out statutory definitions and regulatory propositions; whether a particular fact, communication or person falls within a statutory definition is a matter for case‑specific application and, where appropriate, regulatory or legal processes.

The FCA publications cited here describe prohibitions and obligations in abstract and rule terms. Applying those provisions to individual circumstances requires fact-finding, evidence and, where relevant, formal processes that lie beyond the scope of a descriptive explainer. For that reason, this piece does not categorise any behaviour, communication or event against the regime’s prohibitions.

Readers should therefore use this written material only to understand how the FCA has framed MARC within its published rule set, the status of PS26/9 as final policy material, and the FCA’s stated timetable for wider regime application. It is not a substitute for determinations that arise from regulatory action, litigation or case-specific analysis carried out by competent authorities or advisers in appropriate forums.

The article also avoids instruction on compliance steps, monitoring techniques, reporting or other operational matters. Those implementation questions are matters for regulated persons, advisers and the FCA’s own supervisory work, and they require specific, context-sensitive treatment not provided in this explanatory narrative.

What MARC means in the FCA material

This section explains the Market Abuse Regime for Cryptoassets (MARC) as presented in recent FCA policy material. Scope: This is general editorial information based on FCA publications and does not assess any person, platform, asset, transaction, communication or alleged event. It is not investment, legal, tax, compliance or regulatory advice.

The FCA’s final policy statement on cryptoassets, PS26/9, sets out MARC within the CRYPTO 4 chapter of the regulatory framework. PS26/9 is the final policy document for admissions, disclosures and the market-abuse framework for cryptoassets, and it identifies the specific prohibited categories and the firm-level obligations that accompany them. The FCA’s separate overview of its cryptoassets regime explains that the wider regulatory architecture will expand from 25 October 2027; that date is part of the published status language and this explainer preserves it.

For readers who wish to consult the underlying material directly, the FCA overview of its cryptoassets regime policy statements is available from the FCA, and the PS26/9 policy statement document contains the detailed final rule text and accompanying discussion. Those two FCA publications are the approved primary sources for this explainer.

Market-abuse categories in the published framework

PS26/9 identifies the components of MARC by reference to three prohibited categories. The published framework uses statutory and regulatory language to describe the areas covered: the prohibited use of inside information, prohibited disclosure of inside information and market manipulation. In the FCA material these broad headings structure CRYPTO 4 and the related rule provisions.

The FCA characterises “market abuse” in its source material as behaviour that falls within those provisions. The framework therefore organises obligations and prohibitions around the use and dissemination of what the Cryptoassets Regulations treat as inside information, and around conduct that the rules characterise as manipulation of cryptoasset markets. PS26/9 explains the conceptual boundaries between those categories, and it includes examples and refinements intended to reflect cryptoasset market features.

Within the published framework, the FCA sets out obligations for UK qualifying cryptoasset trading platforms and their permitted operators (UK QCATPs). PS26/9 describes proportionate systems and controls that such firms should have. The policy statement also creates an additional category of obligations for those identified as large UK QCATPs, including specific duties that relate to on-chain monitoring and cross-platform information sharing. The document refines the obligations and provides examples to support understanding of the boundaries of the three prohibited categories.

Insider dealing in the source boundary

PS26/9 treats insider dealing as a prohibited use of inside information. As a matter of published policy, MARC prohibits the use of inside information in ways set out in the regulatory text. The PS26/9 material describes the statutory concept in relation to cryptoassets and provides examples of facts or circumstances that the FCA considers illustrative of inside information for cryptoasset markets.

The policy statement emphasises that platform operators have a role under MARC in relation to systems and controls that seek to reduce the risk that persons will use inside information for trading purposes. For all UK QCATPs PS26/9 sets out proportionate systems and controls; for large UK QCATPs the statement adds specified obligations reflecting their scale and market position. Those additional obligations include targeted on-chain monitoring and expectations for information sharing across relevant trading venues in the cryptoasset ecosystem.

PS26/9 also refines several aspects of the insider-dealing boundary to account for cryptoasset market mechanics. The statement narrows the scope of required on-chain monitoring compared with earlier proposals, and it clarifies examples of information that may qualify as inside information in a cryptoasset context. The published material therefore establishes both prohibitions and firm-focused requirements intended to manage the risks identified by the FCA within the statutory and regulatory boundary.

Unlawful disclosure of inside information in the source boundary

The PS26/9 framework includes unlawful disclosure of inside information among the prohibited categories. The FCA’s final policy text addresses disclosures in multiple contexts and provides detail on how disclosure-related obligations interact with platform and intermediary roles. The material also clarifies the relationship between disclosure provisions and the statutory definition of inside information.

In PS26/9 the FCA sets out that intermediaries and platform operators have notification and record-keeping roles in relation to information that may amount to inside information. The statement clarifies how notifications to the FCA and intermediation-related communications feature in the framework. It also describes examples of disclosures and the circumstances in which those examples are relevant to the statutory and regulatory provisions.

The policy statement narrows and refines earlier drafting on disclosure obligations, and it provides additional explanation on intermediary notifications and the circumstances that may give rise to an obligation to consider disclosure questions. Those clarifications are expressed in the context of the statutory concept of inside information, which remains the baseline legal term governing the disclosure-related prohibitions in CRYPTO 4.

Market manipulation in the source boundary

Market manipulation forms the third published category of prohibited conduct in PS26/9. The policy statement describes manipulative conduct in terms aligned with the market features the FCA has identified as distinctive to cryptoasset trading and infrastructure. The framework identifies both explicit examples of manipulative techniques and a set of refined legitimate market practices intended to distinguish permitted conduct from the sorts of trading or activity the rules target.

CRYPTO 4, as set out in PS26/9, includes a range of firm-focused obligations designed to mitigate the risk of manipulation arising on qualifying trading platforms. For UK QCATPs the requirement is for proportionate systems and controls; for large UK QCATPs the final rules add obligations that are tailored to scale and connectivity, including clearer expectations about on-chain monitoring and about sharing information across platforms where appropriate. The final text narrows earlier, broader proposals on monitoring and refines descriptions of legitimate practices.

PS26/9 includes examples intended to aid interpretation of the manipulation provisions. The examples aim to show where trading patterns, order-book activity or on-chain events might fall within the scope of the manipulation rules, and where activity may instead be an example of a legitimate market practice. The FCA’s examples are illustrative and are presented as part of the material that supports the final rules rather than as an exhaustive catalogue of cases.

Inside information as a statutory term

The FCA material makes clear that inside information is a statutory term. The definition of inside information for the purposes of the Cryptoassets Regulations appears in regulation 18 of those regulations. That statutory definition provides the legal baseline that CRYPTO 4 uses when it describes prohibited use and disclosure of inside information.

PS26/9 supplements the statutory definition with examples and explanatory text intended to help readers understand how the statute applies in a cryptoasset context. The policy statement identifies illustrative scenarios and facts that the FCA regards as likely to meet the statutory definition in particular circumstances. Those illustrative materials are presented to assist interpretation of the statutory term within CRYPTO 4, not to displace the statutory text itself.

Because the term is statutory, PS26/9 emphasises that determinations about whether specific facts or communications meet the legal definition of inside information are matters for assessment under the statute. The FCA’s illustrative examples are part of the published guidance surrounding the final rules, and they operate alongside the statutory language in regulation 18.

Why statutory terminology does not decide individual cases

Statutory definitions and policy examples set out in PS26/9 provide a framework for understanding the scope of MARC, but they do not determine the outcome of any particular factual scenario. The FCA’s published material explains concepts, refines rule text and supplies examples; it does not pronounce on the legal status of specific communications, transactions or persons outside the formal processes that consider individual matters.

The PS26/9 document is final policy material for the market-abuse framework applicable to cryptoassets and it describes the obligations that will apply within CRYPTO 4. The FCA’s overview of its cryptoassets regime also explains that the full scope of the wider regime expands from 25 October 2027. Those status statements are part of the published record and should be read as the FCA’s description of timing and policy finality, rather than as case-by-case determinations.

Where an application of statutory terms to particular facts is required, the outcome depends on the precise factual matrix and any applicable legal tests. PS26/9 provides the rules, examples and clarifying material that firms, advisers and interested parties can read alongside the statutory language, but determinations about individual conduct are not made by this explainer. To read the FCA’s policy statements and the underlying CRYPTO 4 text, consult the FCA overview of the cryptoassets regime policy statements and the PS26/9 policy statement document.

The FCA’s systems-and-controls framing

This is general editorial information based on FCA publications and does not assess any person, platform, asset, transaction, communication or alleged event. It is not investment, legal, tax, compliance or regulatory advice.

The FCA’s final policy statement PS26/9 sets out the Market Abuse Regime for Cryptoassets (MARC) within a systems-and-controls framework. PS26/9 contains final rules that prohibit insider dealing, unlawful disclosure of inside information and market manipulation, and it frames the regulated response in terms of proportionate systems and controls for relevant firms. The regime is set out in CRYPTO 4 and operates alongside the admissions and disclosures material in CRYPTO 3.

The FCA describes the controls expectation as proportionate to the nature, scale and complexity of the relevant trading platform or intermediary activity. PS26/9 places emphasis on operational arrangements that support detection, assessment and escalation of matters that potentially engage the MARC provisions, while noting that cryptoasset markets retain residual risk that the FCA judges comparatively higher than in more established markets.

The FCA’s overview of its wider cryptoassets regime explains that the final policy package covers disclosure requirements for offers and admissions, due diligence and admission standards, and market-abuse controls. The overview also signals that the broader regulatory perimeter and the full scope of regulated activities expand from 25 October 2027.

UK QCATPs and intermediaries in PS26/9

PS26/9 addresses systems and controls for UK qualifying cryptoasset trading platforms and their permitted operators, referred to in the material as UK QCATPs, and for intermediaries that interact with such platforms. The regulation relies on specialist terminology defined in the Cryptoassets Regulations; the definition of inside information itself appears in regulation 18 of those Regulations and is a statutory term.

The policy statement distinguishes the MARC provisions from admissions-and-disclosures requirements in CRYPTO 3, while making clear that both sets of rules form part of the FCA’s wider cryptoassets framework. PS26/9 sets out the types of market conduct the MARC covers and describes the expectations that regulated platforms and intermediaries will have systems in place to address those risks.

For intermediaries, PS26/9 includes provisions that affect their operational relationship with UK QCATPs. The final text includes clarifications about intermediary notifications and the responsibilities that arise when intermediaries interact with or facilitate access to cryptoasset trading activity governed by the MARC framework. The FCA identifies these measures as part of an integrated supervisory approach across trading venues and service providers.

Additional obligations for large UK QCATPs

PS26/9 creates a distinction within the category of UK QCATPs by identifying a subset described as large UK QCATPs that are subject to additional obligations. The policy statement explains that these additional measures reflect the greater potential market impact and systemic considerations associated with larger trading platforms.

Among the further obligations identified for large UK QCATPs are enhanced arrangements for monitoring activity and mechanisms for sharing information across platforms and with relevant parties. PS26/9 sets these out as part of a calibrated regulatory approach rather than as blanket requirements for all platforms.

The final rules do not in the published text apply an external threshold to name or rank businesses; instead, PS26/9 describes the category in the abstract and reserves detailed sizing or classification matters to supervised persons and supervisory processes. The document notes that the nature and extent of the additional obligations are proportionate and tailored to the scale and operational context of the platform.

On-chain monitoring as described in the final policy statement

On-chain monitoring is identified in PS26/9 as one of the operational measures relevant to the MARC framework, particularly for large UK QCATPs. The policy text treats on-chain monitoring as part of a broader set of systems and controls that can support detection and assessment of activity within cryptoasset markets.

In the transition from consultation to final policy, the FCA narrowed the on-chain monitoring element. PS26/9 therefore sets a more limited scope for on-chain monitoring obligations in the final rules than appeared in the earlier consultation documents. The change reflects the FCA’s decision to refine how on-chain monitoring is described and where it sits within the overall controls framework.

The statement does not mandate a single technical approach; rather, it embeds on-chain monitoring within the principle of proportionate systems and controls. PS26/9 describes how on-chain monitoring can be one element among others that platforms and intermediaries may use to identify, investigate and escalate matters that potentially fall within the MARC provisions.

Cross-platform information sharing

PS26/9 sets out measures to encourage and, in some instances, require cross-platform information sharing as part of the operational response to market conduct risks. This element is particularly prominent among the additional obligations that apply to large UK QCATPs and is intended to improve visibility and coordination across distinct trading venues and service providers.

The final policy statement explains that cross-platform information sharing is designed to complement other systems and controls, allowing platforms and intermediaries to communicate relevant operational intelligence within the bounds of the regulatory framework. The FCA positions such sharing as a means to support detection and response across market participants subject to the MARC provisions.

PS26/9 also clarifies aspects of intermediary notifications that interact with cross-platform arrangements. These refinements in the final rules aim to make clearer how information exchange fits with the notification and escalation pathways that the FCA considers necessary to give effect to the MARC framework in an interconnected market environment.

Legitimate market practices in the final-rules context

PS26/9 refines the treatment of what it describes as legitimate market practices within the MARC context. The final policy includes an updated set of considerations intended to help delineate behaviours that fall outside the prohibited use of inside information, prohibited disclosure of inside information and manipulation provisions as those provisions are drafted in CRYPTO 4.

The policy statement provides examples and clarifications to improve practical understanding of how the MARC provisions interact with routine market activity. PS26/9 sets out illustrative material to aid supervised persons and market participants in interpreting the boundaries of the regime, while emphasising the statutory nature of the underlying definitions, such as the definition of inside information in regulation 18.

The FCA notes that refining legitimate market practices in the final rules was intended to provide greater clarity following consultation. The statement therefore presents these refinements as part of the package that forms the final MARC framework, rather than as standalone guidance or exhaustive lists.

The FCA’s refinements from consultation to final policy

PS26/9 records a number of changes made between the consultation stage and the final policy. The FCA narrowed the scope of on-chain monitoring provisions, clarified elements related to disclosure of inside information and intermediary notifications, and refined the treatment of legitimate market practices. The statement also includes examples of inside information to assist interpretation within the regime’s statutory terms.

The policy statement is described by the FCA as final A&D and MARC material. PS26/9 therefore contains final rules for both admissions and disclosures and for the MARC provisions within CRYPTO 4; the FCA’s overview of its cryptoassets regime sets out how these elements sit together within the wider package. The overview additionally notes that the broader regulatory perimeter will expand from 25 October 2027.

These refinements reflect the FCA’s approach to calibrating rule text against observed market characteristics and supervisory objectives. The final-policy adjustments are presented in PS26/9 as intended to balance clarity and proportionality across a range of platform types and intermediary models, while recognising residual comparative risk in cryptoasset markets.

For reference to the source materials used in this summary, see the FCA overview of our cryptoassets regime policy statements and PS26/9: Crypto Regime: Admissions & Disclosures and Market Abuse Regime for Cryptoassets.

Residual risk in the FCA’s description of cryptoasset markets

This section summarises how the FCA characterises residual market-abuse risk in the context of its policy on cryptoassets, drawing only on the regulator’s published material. The FCA’s overview of its cryptoasset regime notes that the wider regime expands from 25 October 2027 and explicitly flags residual market-abuse risk in cryptoasset markets as comparatively higher than in more established markets. The regulator’s description is presented as an observation about market characteristics and risk profile, not as a determination about any specific actor, platform, asset or event.

The FCA identifies factors that, in its view, can contribute to comparatively higher residual risk across cryptoasset markets. PS26/9 sets out the final Market Abuse Regime for Cryptoassets (MARC) within CRYPTO 4 and frames a set of prohibited behaviours alongside systems and controls that fall to regulated entities. The FCA indicates that, despite regulatory measures, some features of cryptoasset markets mean the potential for residual risk will remain comparatively elevated relative to more established markets.

Residual risk is therefore described in the sources as a comparative, system-level point: regulatory rules and firm-level controls can reduce but not necessarily eliminate all market-abuse risk in these markets. The FCA’s material treats that residual as a policy consideration that influenced the design of MARC, including calibrations such as proportionate systems and controls, additional obligations for large UK QCATPs and targeted on-chain monitoring measures. That framing should be read as an account of the regulator’s policy and risk judgement, based on the sources cited.

Why MARC is not a guarantee about any market

PS26/9 establishes a regulatory framework intended to prevent and deter certain forms of prohibited behaviour defined in the Cryptoassets Regulations. It sets out final rules that prohibit insider dealing, unlawful disclosure of inside information and market manipulation within the scope of CRYPTO 4. However, the existence of MARC in the rulebook does not guarantee outcomes for any particular market, asset or participant.

The FCA’s rules describe prohibited conduct and define obligations for entities within scope, including UK QCATPs and intermediaries. The regime prescribes duties and examples of systems and controls, and recognises differing obligations for large UK QCATPs. Those statutory and rule provisions operate at the level of regulated activities and entities; they are not assertions that any given set of market facts will be free of residual risk or entirely consistent with compliance expectations.

Put another way, MARC is a legal and supervisory framework. It creates prohibitions, compliance obligations and enforcement pathways as set out in PS26/9, but it does not operate as a blanket assurance of specific market outcomes. The regulator’s own overview highlights that the broader regime’s scope expands in future, and it treats residual risk as a persisting policy concern. The sources therefore present MARC as part of the regulatory architecture, not as a guarantee that risk will be eliminated.

What readers should not infer from PS26/9

Readers should avoid inferring, from the existence of PS26/9, any case-specific conclusions about conduct, communications or particular market events. The FCA’s documents set out legal definitions, prohibited categories and obligations for entities within scope; they do not identify or adjudicate on individual instances. The article is limited to explaining the published framework and must not be read as an assessment of any person, platform, asset, transaction, communication or alleged event.

PS26/9 contains final rules and policy statements concerning MARC. That status should not be taken as evidence that future elements of the wider cryptoasset regime already apply universally; the FCA’s overview specifies that the full scope of regulated activities expands from 25 October 2027. Readers should not construe the timing language in the sources as implying retrospective or universal application beyond what the regulator states.

Nor should readers infer operational or compliance instructions from the narrative of the rules. PS26/9 describes proportionate systems and controls, additional measures for large UK QCATPs and examples intended to clarify concepts such as inside information and legitimate market practices. These explanations are part of the regulator’s policy framing and examples, not prescriptive implementation guidance for any specific organisation in this article.

Why the article excludes platforms and assets

This explainer intentionally excludes naming, assessing or comparing any platform, firm, cryptoasset or transaction. The sources provide a regulatory framework that applies to categories of entities and to defined forms of conduct, but the policy material does not authorise public assessments of specific market participants here. The manuscript must not, and does not, identify or evaluate any particular marketplace, asset or operator.

That boundary preserves the article’s scope as a source-limited description of regulatory text and policy intent. The approved FCA documents refer to UK QCATPs and large UK QCATPs as defined categories; PS26/9 sets out differential obligations for those categories. The article explains those categories and the regulatory approach without applying thresholds, naming entities, or making factual claims about particular platforms or assets.

Readers seeking firm-specific determinations should consult regulatory filings, supervision outcomes or enforcement notices published by the FCA itself. This article does not attempt to interpret or extend the regulator’s actions into commentary about individual market participants and avoids doing so in order to remain strictly within the public-policy material cited.

Why the article excludes trading and investment commentary

The article does not provide trading, investment, tax, legal, compliance or regulatory advice. The FCA sources describe a rule framework for prohibited conduct and for the systems and controls expected from regulated entities. Translating those materials into investment or trading recommendations would exceed the manuscript’s editorial purpose and the limits set by the source pack.

PS26/9 includes clarifications on concepts such as inside information, intermediary notifications and legitimate market practices. Those clarifications are aimed at readers who need to understand the regulatory text; they are not intended as input to trading or investment decisions. Accordingly, the article excludes commentary of that kind and avoids characterising behaviours or practices in ways that would amount to advice.

The narrative focus remains on what the regulator has published about the FCA cryptoasset market abuse regime, including the statutory and rule definitions, calibrated obligations for different categories of UK QCATPs and the recognisable policy choices embedded in MARC. The manuscript purposefully stops short of applying those elements to investment or trading scenarios.





How to read PS26/9 without making an individual determination

How to read PS26/9 without making an individual determination

Scope statement: This is general editorial information based on FCA publications and does not assess any person, platform, asset, transaction, communication or alleged event. This material is not investment, legal, tax, compliance or regulatory advice.

PS26/9 is published as final policy material describing a regulatory framework rather than adjudicating facts about any particular person or event. A policy statement performs a rule‑setting and explanatory role: it defines categories, sets out expectations for systems and controls, and states the regulator’s aims for market integrity. That task is different from making individual determinations, which require factual investigation and the application of statute or rules to the circumstances of a named person, platform or event. Readers should therefore treat PS26/9 as the FCA’s statement of how the market‑integrity regime for cryptoassets will be structured and interpreted, not as a finding about any real‑world matter.

At the level of structure, a final policy statement can list the categories of activity and the kinds of information that fall within a regime, explain the kinds of governance and control measures expected of firms, and describe the regulator’s enforcement priorities and market‑integrity objectives. Those elements are conceptual and normative: they communicate what the regulator regards as the contours of a regime and how regulated entities should expect the regime to operate. They do not replace case‑by‑case fact‑finding, which remains necessary to determine whether a specific communication, transaction, person or platform meets a statutory test.

There are practical reasons for this separation. Rule texts and accompanying guidance must be sufficiently clear and general to apply across a range of circumstances and business models; they therefore describe categories and examples rather than catalogue every possible factual permutation. Conversely, individual determinations rely on evidence and the application of legal definitions to particular behaviour or events. The FCA can therefore publish binding rules and explanatory material that signal regulatory intent and set out obligations, while reserving decision‑making about particular occurrences to processes that evaluate the facts of those occurrences against the statutory standards.

PS26/9’s final material also clarifies expectations for different types of firms, including differentiated obligations for larger platforms. That delineation is typical in financial regulation: a rulebook can impose baseline requirements and additional controls for entities whose scale, risk profile or market role justify heavier requirements. Explaining those distinctions in a policy statement helps firms and market participants understand regulatory design and prepare for compliance, without the policy statement itself determining whether any specific firm currently meets a threshold or has breached an obligation. Any such assessment requires separate factual and legal analysis under the applicable rules.

When reading PS26/9, it is useful to keep the temporal and scope distinctions in mind. PS26/9 is final policy material; the broader timetable for the cryptoasset regime is set out in the FCA’s overview. In particular, the FCA’s summary material notes that the regime’s full regulated‑activity scope expands from 25 October 2027. That means the policy statement can be final and authoritative about standards and design while parts of the wider regulatory architecture come into full effect according to the timetable the FCA has published. The two publications therefore perform different but complementary functions: the policy statement establishes the detailed framework now, and the overview sets out the staged implementation and the point at which the regime’s full scope will apply.

Readers should therefore use PS26/9 to understand the content of rules, the kinds of systems and controls the FCA expects, and the regulator’s stated market‑integrity aims, while recognising that confirming whether a particular fact pattern or participant falls within those rules requires a separate, evidence‑based determination. For those seeking the authoritative presentation of the final framework, consult the policy statement itself; for the staged implementation timetable and summary context, consult the FCA’s overview of the cryptoasset regime.

Further reading (FCA sources): PS26/9: Crypto Regime: Admissions & Disclosures and Market Abuse Regime for Cryptoassets (final policy statement) — https://www.fca.org.uk/publication/policy/ps26-9.pdf. Overview of our cryptoassets regime policy statements — https://www.fca.org.uk/publications/policy-statements/cryptoasset-regime.


Related FCA policy context

The FCA cryptoasset market abuse regime is one component of the FCA’s wider final cryptoasset-policy package. Its public-information purpose in this article is to explain the FCA’s published framework, not to decide how that framework applies to a particular fact pattern.

For a separate source-limited discussion of another FCA policy statement, see OGM’s FCA cryptoasset custody and CASS 17 explainer. The FCA cryptoasset market abuse regime and the custody material concern different FCA policy areas; this internal link is for Crypto-silo navigation only.

Within PS26/9, the FCA cryptoasset market abuse regime is described through final-rule categories and controls. A published description of those categories does not resolve an individual legal or regulatory question.

Readers using the focus phrase FCA cryptoasset market abuse regime should treat it as a route to FCA public materials, not as a label for a real-world case or an instruction about trading, reporting or compliance.

Official FCA sources

This explainer is based on the FCA’s published material. The two primary documents used are the FCA’s overview of its cryptoasset regime policy statements and the PS26/9 policy statement containing final rules. Both are available on the FCA website and are linked below for reference.

Readers should consult those two documents for the regulator’s full wording, legal definitions and the formal status statements that accompany the final rules and the broader regime timetable.

Conclusion: a source-limited reading of the FCA cryptoasset market abuse regime

This article has explained, within a narrowly defined scope, how the FCA frames residual risk and what PS26/9 establishes about MARC. The material in PS26/9 is final policy on the Market Abuse Regime for Cryptoassets and sets out prohibitions, compliance expectations and differential obligations for categories of regulated entities such as UK QCATPs and large UK QCATPs. The FCA’s overview situates those rules within a wider timetable that expands the regime’s scope from 25 October 2027 and emphasises that residual market-abuse risk in cryptoasset markets is comparatively higher than in more established markets.

Readers should view MARC as a statutory and regulatory framework intended to address and deter certain prohibited behaviours, rather than as a universal assurance about specific markets or outcomes. The presence of final rules creates legal obligations and enforcement levers, but the sources present residual risk as a policy reality that informed rule design and calibrations such as proportionate systems and controls and targeted obligations for larger platforms.

Importantly, this article is general editorial information based on FCA publications and does not assess any person, platform, asset, transaction, communication or alleged event. It is not investment, legal, tax, compliance or regulatory advice. For definitive legal interpretation, firm-specific guidance, or enforcement determinations, readers should consult the FCA’s published documents and, where appropriate, authoritative legal or professional advisers outside this explanatory piece. The links above point to the FCA materials that underpin the description given here.