The Payments Association (“TPA”) welcomes the opportunity to respond to the Bank of
England’s consultation on its draft Code of Practice for systemic stablecoin issuers, published
on 22 June 2026 and closing on 22 September 2026. This is one of two related consultations
as part of the wider regulatory package for sterling-denominated systemic stablecoins; the
Bank and FCA’s joint approach to regulation of systemic stablecoin issuers closes later, on 30
September 2026, and TPA is submitting a separate response to that consultation ahead of its
own deadline. Our members consider this package among the most consequential steps yet
taken in UK digital money policy and have engaged with urgency and depth.
This response reflects views expressed by TPA members and industry experts who
contributed through a dedicated members’ evidence session held on 8 September 2026,
together with follow-up written submissions. As TPA’s membership spans the full stablecoin
and payments value chain, including prospective issuers, custodians, banks, non-bank PSPs,
and their legal and other advisers, and holds a correspondingly diverse range of views, this
response cannot and does not claim to represent the position of every member on every
question.
We are grateful to the contributors to this response, which has been drafted by Robert
Courtneidge on behalf of TPA’s Policy team. We would also like to thank the Bank of England
and the FCA for their continuing engagement with industry throughout this process. We hope
this response supports the shared goal of ensuring the UK remains the best place in the world
for payments and digital asset businesses to establish, invest and grow.
The Bank welcomes responses to any of its questions without expecting each one to be
answered. Consistent with that, this response answers the five questions posed alongside the
draft Code of Practice, directly, in order and in the Bank’s own wording, drawing on our
members’ evidence session. Our answer to the Equality Act 2010 question the Bank has asked
(Q5) appears below.
In accordance with the Bank’s request, The Payments Association confirms that it consents
to the Bank publishing its name, and the name of The Payments Association, as a respondent
to this consultation paper.
