The Payments Association (“TPA”) welcomes the opportunity to respond to the Bank of
England and Financial Conduct Authority’s joint approach to regulation of systemic stablecoin
issuers, closing on 30 September 2026. This is one of two related consultations as part of the
wider regulatory package for sterling-denominated systemic stablecoins; the Bank’s
consultation on its draft Code of Practice for systemic stablecoin issuers closed earlier, on 22
September 2026, and TPA submitted a separate response to that consultation ahead of its
deadline. The two responses should be read together. 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 and FCA welcome responses to any of their questions without expecting each one
to be answered. Consistent with that, this response answers the ten questions posed by the
joint approach to regulation, directly, in order and in the Bank’s own wording, drawing on our
members’ evidence session.
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.
