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Core taxonomy (qualifying cryptoassets, qualifying stablecoins, specified investment cryptoassets) is legislated. Qualifying stablecoins are excluded from the general qualifying cryptoasset definition and given dedicated issuance rules; electronic money, fiat, CBDCs and limited-network cryptoassets are excluded outright; specified investment cryptoassets (e.g. security tokens) are already within the perimeter. Final PERG perimeter guidance for hybrid/decentralised/smart-contract cases remains pending, expected autumn 2026.
The regime also draws exclusions at the boundary of the taxonomy: electronic money, fiat currency, central bank digital currencies, and limited-network cryptoassets are all excluded from the definition of 'qualifying cryptoassets,' keeping them outside the new perimeter entirely. At the other end of the spectrum, 'specified investment cryptoassets' -- cryptoassets falling within pre-existing specified investment categories such as security tokens -- are defined as already within the FCA's perimeter under existing rules, meaning the new regime does not change their treatment.
What remains unresolved is the classification of harder cases: tokens involving smart contracts, decentralisation, or hybrid features sit in an area where the FCA's final PERG perimeter guidance is still pending, expected in autumn 2026. Until that guidance is published, market participants building products with decentralised or hybrid characteristics are working against a taxonomy that is settled at its core but unclear at its edges.
Outlook
The autumn 2026 PERG perimeter guidance is the key date to track for this module. Its publication will determine how the boundaries between qualifying cryptoassets, qualifying stablecoins, and specified investment cryptoassets are applied to smart-contract-based and hybrid token structures -- an area presently left open by the core legislation. Until that guidance lands, classification decisions for novel token designs carry residual uncertainty that the core October 2027 commencement date does not, by itself, resolve.
Token Classification
SI 2026/102 gives statutory definition to "qualifying cryptoasset" and "qualifying stablecoin" as distinct categories under the Regulated Activities Order, replacing what had previously been a regime built primarily around AML registration rather than activity-specific classification. These definitions underpin the wider licensing perimeter, since regulated-activity status and the specific compliance obligations that attach to a firm depend on which category its tokens or services fall into. The Commission's, that is, the FCA's, sub-taxonomy guidance beneath these two headline categories is being issued in tranches rather than as a single completed package, so firms operating at the margins of the qualifying-cryptoasset definition, particularly around utility tokens, NFTs, or hybrid instruments, do not yet have a fully settled classification framework to rely on even though the headline categories themselves are now fixed in statute.
Outlook
Further FCA guidance tranches refining the boundaries of "qualifying cryptoasset" and "qualifying stablecoin" should be expected before the regime enters force on 25 October 2027. Firms with borderline token structures should treat the current classification picture as directionally settled but not yet complete.
1 earlier distinct update(s)
Token Classification
The UK's token-classification architecture has been given a clearer structural shape this cycle. The Regulated Activities Order is expanded by the Cryptoasset Regulations 2026 to bring 'qualifying stablecoins' within the FCA's regulatory perimeter as a category distinct from other regulated cryptoasset activities. This is a taxonomic move rather than a substantive rulemaking exercise in its own right: it establishes that stablecoins are treated differently in kind from other cryptoassets under the expanded perimeter, which in turn is what allows the separate stablecoin-specific regime (FCA authorisation plus, where systemic, joint Bank of England supervision) to attach specifically to that category rather than to cryptoassets generally.
The classification itself is settled as a matter of legal structure, but supporting perimeter guidance that would spell out the practical boundaries of what counts as a 'qualifying stablecoin' versus other regulated cryptoasset activity is still pending. That guidance gap is the main source of residual uncertainty in this module: the category exists, but its edges are not yet fully drawn in published guidance. The governing framework is the FSMA 2000 (Regulated Activities) Order 2001 as amended by the Cryptoasset Regulations 2026, supervised by the Financial Conduct Authority.
Outlook
The supporting perimeter guidance that would firm up the practical boundaries of the qualifying-stablecoin category is the item to watch here, expected around the same broad window as the licensing gateway's operational milestones. Until that guidance lands, classification questions at the margin -- which specific token structures fall inside versus outside the qualifying-stablecoin category -- remain open.
Sources and findings (4)
- T1 · FCAQualifying stablecoins — a distinct regulated category, excluded from the general qualifying cryptoasset definition used for dealing/arranging purposes but subject to dedicated stablecoin issuance rulesretrieved M5bindingenacted not yet effectivenew
- T1 · FCAElectronic money, fiat currency, CBDCs, and limited-network cryptoassets — the definition of 'qualifying cryptoassets' under the Cryptoassets Regulationsretrieved M4bindingenacted not yet effectivenew
- T1 · FCA'Specified investment cryptoassets' — cryptoassets that fall within pre-existing specified investment categories (e.g. security tokens), already within the FCA perimeterretrieved M4bindingin force
- T1 · FCAFCA final PERG perimeter guidance — autumn 2026, to clarify classification boundaries for tokens involving smart contracts, decentralisation, or hybrid featuresretrieved M3non-bindingnew