Call for Input: Tokenised gold – opportunities and risk for UK wholesale markets

Key dates

2026-09-14

FCA published the Call for Input on tokenised gold.

2026-10-23 Deadline

Deadline for stakeholders to submit responses to the FCA.

Suggested considerations

• Firms developing or considering tokenised gold may wish to assess whether their proposed token, contractual rights and underlying custody arrangements could constitute a CIS, an AIF, a financial instrument or another regulated product under FSMA 2000 and the Regulated Activities Order.
• Potential issuers and platform operators should consider documenting the legal relationship between the token holder, the bullion custodian and the physical gold, including allocation, segregation, redemption, transfer, lien, insolvency and loss arrangements.
• Wholesale market participants may wish to evaluate specific collateral use cases in securities lending, repo and derivatives, including eligibility, valuation, margining, haircut, settlement finality, enforcement and treatment following a platform or custodian failure.
• Firms should consider whether their governance, outsourcing, operational-resilience, cyber-security, private-key management, ledger-access and business-continuity controls are appropriate for tokenised ownership records and programmable transfers.
• Asset managers and product sponsors may wish to review whether existing disclosures, fund constitutional documents, custody arrangements, valuation policies and investor protections adequately address tokenised gold.
• Industry participants may wish to submit evidence to the FCA by 23 October 2026, addressing practical use cases, barriers, risks, interoperability standards and the effect of CIS and AIF perimeter uncertainty.
• Compliance teams may wish to monitor subsequent FCA policy development, including possible guidance or a bespoke regime, rather than treating the Call for Input as confirmation that any particular tokenised-gold structure is currently permitted or outside regulation.

What changed

No binding rule, authorisation requirement or supervisory obligation has been introduced. The FCA has begun an evidence-gathering exercise that may inform future guidance or a bespoke regime for tokenised gold. The regulator is examining whether digital tokens representing ownership of physical gold can support wholesale collateral, including potential use in securities lending, repo and derivatives transactions, while preserving market integrity, consumer protection and the existing strengths of London's gold-market infrastructure. Market commentary indicates that the principal near-term regulatory issue is legal certainty over whether tokenised gold arrangements constitute a CIS or AIF, together with controls covering custody of bullion, title and redemption rights, valuation, default an

Who is affected

• UK gold-market participants and clearing members
• Firms issuing, arranging, distributing or operating tokenised-gold products
• Asset managers operating gold-backed collective investment schemes
• UK alternative investment fund managers and firms marketing gold-related AIFs
• Banks, broker-dealers and other wholesale firms considering tokenised gold as collateral in securities lending, repo or derivatives
• Digital-asset platform, distributed-ledger technology and custody providers
• Consumer groups and investors interested in gold-backed investment products

Related regulations

• Financial Services and Markets Act 2000
• Financial Services and Markets Act 2000 (Regulated Activities) Order 2001
• UK collective investment scheme regime
• UK Alternative Investment Fund Managers regime
• UK MiFID framework
• Client Assets Sourcebook (CASS)