Tokenising the future: FCA consults on progressing fund tokenisation

On 14 October 2025, the FCA published a consultation paper (CP25/28) setting out its proposals to facilitate the adoption of tokenisation by the asset management industry in the UK. The proposals apply to managers and depositories of authorised funds, but some of the proposals will be of interest to fund and asset managers more broadly, including managers of non-authorised funds.

The proposals align with the FCA’s broader digital assets agenda, as set out in their Crypto Roadmap which we explored in our previous blog post. The consultation specifically sets out guidance for:

• operating a tokenised fund under the Blueprint model;

• a streamlined ‘direct to fund’ (D2F) dealing model; and

• a roadmap for future regulatory evolution.

The FCA is supporting the adoption of tokenised fund registers through the Blueprint model. The model allows firms to use DLT to run a tokenised register of fund unitholders within existing legal and regulatory rules. Both private and public DLT networks can be used, provided firms have strong controls in place to meet regulatory requirements such as data privacy. 

The FCA is also proposing a new optional D2F dealing model allowing unitholders to deal directly with the fund or its depositary, rather than through the authorised fund manager. This model aims to simplify fund operations. The D2F model will require a dedicated bank account - an Issues and Cancellations Account (IAC) - for handling investor payments. The FCA proposes allowing firms to operate the IAC at an “umbrella” fund level, provided risks are managed. 

Finally, the FCA is exploring how DLT and tokenisation could support more personalised investment services, especially for younger investors who expect instant, direct access to their money. The FCA outlines a three-stage roadmap for tokenisation.

• Tokenised funds - using DLT to manage fund registers is being supported by the FCA through guidance on the Blueprint model.
• Tokenised assets - allowing investors to hold individual tokenised assets directly in digital wallets. Asset managers could manage these through model portfolio smart contracts, offering improved customisability and reduced complexity.
• Tokenised cash flows - breaking down assets into tokenised cash flows tailored to specific financial needs. Advisers could assign these tokens to meet lifestyle goals, enabling highly customised portfolio management.

The FCA is seeking feedback on Chapters 2-4 by 21 November 2025 and the consultation period for Chapter 5 ends on 12 December 2025. Following the consultation, a policy statement is expected in the first half of 2026. Read our full briefing note for further guidance.