FCA PS26/10 Final Stablecoin Rules: What Changed for Issuers

By the Guardian team Updated November 2026 6 min read

Quick answer. From October 25, 2027, PS26/10 requires UK issuers to back every minted coin, reconcile daily and redeem by T+1 from receiving the coin. Versus CP25/14, it simplified backing and allowed a 5% excess and limited intragroup custody.

Watch: FCA PS26/10 Final Stablecoin Rules: What Changed for Issuers 1:32

Video transcript

Here is what changed for UK stablecoin issuers. From October 25, 2027, they must back every minted coin, reconcile daily and redeem by T plus one.

The FCA kept its consultation framework, with targeted changes: confirmed statutory trusts, up to 5 percent excess in the pool, KYC before the redemption clock, and limited intragroup custody.

Backing starts at mint, not at sale. Coins in the issuer's own wallets count too, so burn inventory you do not want to back.

Every business day, check the pool against your own records, and your records against every bank and custodian statement. Close any gap that day. If you cannot, tell the FCA.

KYC checks come first. Once the coin is received, payment is due by the end of the next business day. Within 24 hours, burn it, or record and back it.

Applications describe systems that run on day one. Build and test a multichain mint and burn ledger, daily reconciliation, same-day burn and mint paths, redemption monitoring and a design risk review.

Guardian has run more than 50 engagements on USDT zero, Tether's omnichain stablecoin. On Polygon, it caught a migration plan that would have left more coins circulating than USDT available to redeem.

Read the full article, and confirm how it applies with counsel. To build your stablecoin to these rules, talk to Guardian.

The FCA published PS26/10 on June 30, 2026. It sets the final rules for issuing qualifying stablecoins in the UK, in force from October 25, 2027.

It covers non-systemic issuers. If HM Treasury recognizes an issuer as systemic, Bank of England rules apply as well, as our post on the Bank's systemic stablecoin policy explains.

The FCA's application window opened on September 30, 2026 and is scheduled to close on February 28, 2027.

This article explains the technical and security side of the FCA's PS26/10 and FG26/6. It is not legal advice; confirm how it applies to you with counsel.

What Changed From CP25/14

The FCA consulted on these rules in CP25/14, published May 28, 2025. It kept that framework and made targeted changes:

Area	CP25/14 proposal	PS26/10 final rule
Core backing test	Forecast peak redemptions; every 14 redemption days	Higher of 5% or past 180-day peak; every redemption day
Statutory trust	Proposed	Confirmed, one trust per product
Incoming funds	Unallocated backing funds accounts	Removed; paid straight into backing accounts
Excess in the pool	Withdraw any excess	Up to 5% may stay, on trust
Redemption clock	T+1 from a full request, KYC inside	T+1 from receipt of the coin, KYC before
Custodians	Unconnected to the issuer's group	Intragroup allowed for up to 20% of the pool
Issuer-held coins	Must be backed	Kept: backed from mint until burned

The core backing test applies only to issuers holding expanded backing assets, such as longer-dated government debt.

The interest ban stayed, and it covers rewards tied to how long a coin is held.

One piece is still open: the trust terms if an issuer fails. PS26/10 leaves them to a later consultation.

Backing Every Minted Token

Backing starts at mint, not at sale. The FCA rejected calls to back coins only once issued.

Every minted coin is backed until it is burned, including coins in the issuer's own wallets. To avoid backing inventory, burn it.

The pool is a ledger

CASS 16.2.8R defines the stablecoin pool as coins ever minted, minus coins ever burned, minus redeemed coins from the last 24 hours not yet recorded or burned.

It counts coins minted before October 25, 2027, and coins minted or burned by anyone other than the issuer.

Issuers must keep running totals of mints and burns at all times. For a multichain coin, every chain and bridge feeds that one ledger.

The issuance trade-off

CRYPTO 2.4.4R requires a buyer's coin to be sent immediately. Pre-minted inventory makes that fast, but it is backed from the moment it is minted.

At least 5% of each backing pool must sit in on-demand deposits. The whole pool must be in the coin's reference currency.

Our stablecoin security guide covers the mint caps that stop an unbacked mint in the first place.

Daily Reconciliations

CASS 16.4 requires two checks, each at least once every business day.

Internal: what the pool holds against what it should hold, from the issuer's own records.
External: the issuer's records against each bank and custodian statement, by quantity and value.

A gap between the pool's value and the coins in issue must be closed as soon as possible, and by the end of the business day it is found. There are two ways:

Adjust the backing: pay in a shortfall or withdraw an excess.
Adjust the coins: burn unbacked coins, or mint coins to match excess value.

The second route is onchain, so the burn and mint roles must be usable, safely, on any business day.

Up to 5% of excess may stay in the pool, on trust. Statement mismatches must be resolved without undue delay, unless they are only timing differences.

Notify the FCA without delay if a reconciliation cannot run or a gap cannot be closed.

Redemption by T+1

CP25/14 started the clock at a full redemption request, with KYC inside it. PS26/10 moves the start.

Under CRYPTO 2.4.14R(3), redemption is due as soon as practicable, and no later than the end of the business day after the coin is received.

Before the clock: anti-money laundering and KYC checks.
Complete: when the payment order is made.
Exceptions: a legal requirement or court order, another currency requested, or a suspension.
Limits: no minimum amount; fees cover operational costs only.

Within 24 hours of receiving a redeemed coin, the issuer must record it in the pool, and back it, or burn it.

What that means for the build

Watch every redemption address on every chain: an inbound transfer starts the clock.
Have partners who redeem for you share the addresses holders send to.
Log arrival, checks and payment order for each redemption.
Burn received coins inside 24 hours, or flag them for re-backing.

Suspension is for exceptional cases, such as a ledger failure. Restarting needs a reconciliation confirming full backing, and a plan sent to the FCA at least five business days ahead, unless it agrees less.

Custody, Design and Resilience

Custody of backing assets

Intragroup custodians may now hold up to 20% of the backing pool's value. A firm may exceed that only if an assessment shows the limit is disproportionate, for example for a small pool, and it notifies the FCA first.

Review periodically whether to spread backing across more custodians.
Publish the name of any third party holding more than 20% of the pool.

Each custodian signs an acknowledgement letter before it holds backing assets, reviewed at least annually.

Design and build risk

CRYPTO 2.2.1R says a firm must understand and appropriately manage the risks of a coin's design and build, and show it through a process before offering the coin.

For coins already in issue, that process runs as soon as reasonably practicable after October 25, 2027.

PS26/10 sets no freeze duty. FG26/6's example issuer embeds freeze logic for stolen coins or coins linked to illicit activity.

Operational resilience

FG26/6 is the FCA's finalized guidance on applying SYSC 15A to crypto firms. Its example issuer treats redemption as an important business service.

It maps the contracts, custodians and banks behind redemption, and tests a long chain outage. See our FG26/6 checklist.

What to Build Before Applying

An application describes systems that must run on day one. Build and test these first:

A mint and burn ledger per product, across every chain and bridge.
Automated internal and external reconciliation every business day.
Same-day burn and mint paths for closing gaps.
Redemption address monitoring that timestamps every inbound coin.
A 24-hour burn or record step for redeemed coins.
A documented design and build risk review of the contracts.
Resilience tests for a chain outage and a reconciliation failure.

Our UK crypto deadlines post covers the window and the savings provision.

How Guardian Helps

Guardian's regulatory readiness assessment lists each provision by citation, with the control that meets it. It writes an application's technical sections from the system as built.

Its privileged role map lists every role that can move value, upgrade, pause or freeze, read from the deployed contracts.

The operational resilience assessment tests scenarios such as key compromise, a chain halt and a depeg.

Since January 2025, Guardian has run more than 50 engagements on USDT0, Tether's omnichain stablecoin.

On Polygon, it found a migration plan that would have left more USDT0 circulating than USDT available to redeem. It was fixed before execution.

Frequently Asked Questions

When do the FCA's stablecoin issuance rules apply?

The rules made in PS26/10 come into force on October 25, 2027. The FCA's application window opened on September 30, 2026 and is scheduled to close on February 28, 2027.

How fast must a UK stablecoin be redeemed under PS26/10?

As soon as practicable, and no later than the end of the business day after the day the issuer receives the coin. Know-your-customer checks happen before that clock starts. Redemption is complete when the payment order is made.

Do stablecoins held by the issuer need to be backed?

Yes. Every minted coin counts in the stablecoin pool until it is burned, including coins in the issuer's own wallets. An issuer that does not want to back inventory can burn it.

Sources

Build your UK stablecoin to PS26/10

Guardian reviews the mint, burn and redemption paths behind a UK stablecoin and maps them to the rules they must meet.

Talk to Guardian Explore regulatory compliance