Does the Consumer Duty apply to cryptoasset firms?

Yes. From 25 October 2027 the Consumer Duty (PRIN 2A) applies to the retail market business of firms authorised under the FCA's cryptoasset regime, confirmed in PS26/13 on 30 June 2026. The FCA consulted on how through GC26/2 (published 23 January 2026, closed 12 March 2026). Carve-outs exist for admissions and disclosures and for participant trading.

For three years crypto firms watched the Consumer Duty from the shore. It applied to banks, insurers, platforms and advisers; cryptoasset business sat outside the perimeter, governed by little more than the financial promotions rules.

That gap closes on 25 October 2027. PS26/13, published on 30 June 2026, confirmed that the Duty applies to authorised cryptoasset firms, while GC26/2 (the guidance consultation that ran from 23 January to 12 March 2026) set out how the FCA expects it to work in practice. Firms applying for authorisation from 30 September 2026 are expected to show up with the Duty already built in.

The Duty attaches to the retail market business of firms carrying on regulated cryptoasset activities under the new regime: trading platforms, intermediaries, custodians, lending and staking providers and stablecoin issuers, wherever retail customers are in the chain. Two carve-outs matter. The admissions and disclosures activity is excluded, as is participant-only trading between non-retail parties. Purely institutional business falls outside "retail market business" in the ordinary way. Everyone else in the distribution chain owes the Duty even without a direct customer relationship.

The Duty is one principle (act to deliver good outcomes for retail customers), two cross-cutting obligations and four outcomes. The outcomes are where evidence lives. Each translates concretely to cryptoasset business.

The cross-cutting obligations (act in good faith, avoid foreseeable harm, enable pursuit of financial objectives) bite hardest on the practices the FCA has already named in crypto: engagement-driven app design, gamified trading prompts and promotions that reach customers the product was never designed for.

The board report discipline from traditional finance arrives intact: a Consumer Duty champion, outcome monitoring MI reviewed by the board and an annual board report assessing whether the firm is delivering good outcomes. For crypto firms the practical work is metric design. What is the outcome metric for a custodial wallet? Time-to-recover-access is measurable. For a staking product? Realised versus advertised yield, plus the comprehension rate on lock-up terms. For a trading app? The share of retail customers whose first trade followed a push notification. Firms that can answer with numbers have outcome monitoring; firms that answer with policies have paperwork.

Most applicants are retrofitting Duty sections into authorisation packs drafted by external counsel, which reads as exactly that. Firms with traditional finance heritage are adapting their existing Duty MI, which works better but misses crypto-specific outcomes like custody recovery and staking transparency. Our Gap Analyser includes the PRIN 2A obligations mapped to cryptoasset activities, so the Duty rows sit in the same register as CASS 17 and PS26/10. Whatever the approach, the FCA's question at the gateway will be the one it has asked every other sector since 2023: show me the outcomes, not the intentions.

Volatile. Re-verify before each republish: the final GC26/2 guidance text and any post-consultation changes · the exact scope of the participant trading carve-out · authorisation window dates · any transitional relief announced for the 25 October 2027 start.