FCA's New Crypto Rules: What IFAs Need to Know About Client Conversations
The FCA has published its landmark cryptocurrency regulations, and while you might think this only affects crypto exchanges, the ripple effects will reach your client meetings sooner than you expect.
The new framework requires firms supporting people to buy, trade and hold crypto to meet clear regulatory standards for the first time. But here's what matters for IFAs: the rules also tighten requirements around how crypto is discussed, promoted, and recommended—even by advisers who don't directly deal in digital assets.
What the New Rules Actually Say
The FCA's framework brings crypto firms under the same supervisory regime that governs traditional financial services. Firms will need to demonstrate:
- Clear governance and accountability structures
- Robust systems and controls
- Consumer protection measures including risk warnings and cooling-off periods
- Compliance with financial promotion rules
That last point deserves your attention. The financial promotion requirements now explicitly cover crypto-related communications, including those made by authorised firms discussing digital assets with clients.
Why This Affects Your Practice
You might not recommend Bitcoin to clients. But you're almost certainly fielding questions about it.
A 2025 FCA survey found that 12% of UK adults now hold cryptoassets, up from 10% the previous year. Among your client base—typically higher net worth individuals—that percentage is likely higher. These clients are reading about crypto in the financial press, seeing it discussed on social media, and asking you what you think.
How you respond to those questions now falls squarely within the new regulatory framework.
The Financial Promotion Angle
The FCA has been clear: any communication that could influence someone's decision to buy, sell or hold a cryptoasset is potentially a financial promotion. This includes:
- Social media posts discussing crypto performance
- Newsletter content mentioning digital assets
- Email responses to client queries about crypto
- Website content that references cryptocurrency
The standard you're already familiar with applies: communications must be fair, clear and not misleading. But crypto adds specific requirements. Risk warnings must be prominent. Claims about potential returns need substantiation. And any suggestion that crypto is suitable for particular client types needs careful handling.
Practical Steps for Your Compliance
1. Review your website and marketing materials
Do you mention crypto anywhere? Even a passing reference in a market commentary could trigger financial promotion requirements. Check your:
- Blog posts and articles
- Newsletter archives
- Social media history
- Client-facing presentations
2. Create a standard response for crypto queries
When clients ask about crypto—and they will—have a compliant response ready. This should:
- Acknowledge the asset class exists
- Note the high-risk nature and potential for total loss
- Explain your firm's position on crypto advice
- Avoid anything that could be construed as a recommendation
3. Train your team
Everyone who communicates with clients needs to understand the boundaries. A casual comment in an email like "crypto's had a good run lately" could land you in trouble under the new rules.
4. Document everything
If you do discuss crypto with clients, record what was said. The FCA expects firms to maintain records of financial promotions and related communications. This protects you if questions arise later.
What About Clients Who Already Hold Crypto?
Here's where it gets interesting. Many clients now hold crypto as part of their overall wealth. When reviewing their financial position, you'll need to acknowledge these holdings without straying into advice territory.
The sensible approach: treat crypto holdings as a fact to be noted in suitability assessments and cash flow planning, but make clear that any crypto-specific decisions sit outside your advisory remit unless you're specifically authorised and competent in that area.
The Enforcement Reality
The FCA isn't publishing these rules for decoration. Enforcement action in financial promotions has increased substantially, with fines reaching into the millions for firms that get it wrong. The regulator has specifically highlighted social media as an area of focus.
For IFAs, the risk isn't just regulatory. A poorly worded social media post about crypto could expose you to complaints from clients who subsequently lose money—regardless of whether you intended to give advice.
Looking Ahead
These rules represent the FCA's opening position. Expect further guidance as the regulator sees how firms respond. The direction of travel is clear: crypto is being brought into the mainstream regulatory framework, and everyone in financial services needs to adapt.
For IFAs, the immediate action is straightforward. Audit your communications, train your team, and establish clear boundaries around crypto discussions. The rules may be new, but the underlying principle isn't: know what you're saying, to whom, and make sure it meets the FCA's standards.
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