UK FCA Weighs Fund-Rule Exemptions for Tokenized Gold as Wholesale Collateral Use Case Grows

UK FCA Weighs Fund-Rule Exemptions for Tokenized Gold as Wholesale Collateral Use Case Grows

The United Kingdom’s Financial Conduct Authority is seeking feedback on whether some tokenized gold products should be exempt from fund rules, as regulators examine how tokenization could reshape the way gold is traded, transferred, pledged and held in UK markets.

In a call for input published Monday, the FCA said it is studying tokenized products that represent ownership of physical gold with transparent backing, clearly defined ownership rights and reliable redemption arrangements, including their potential use as wholesale collateral. The consultation is open until Oct. 23.

The Classification Problem

At the heart of the review is a classification question. The FCA said uncertainty over whether some tokenized gold products fall under the UK’s collective investment scheme (CIS) or alternative investment fund (AIF) perimeter may affect the development of certain use cases. If a tokenized gold product is classified as a CIS or AIF, or if its classification is unclear, this could affect whether some investors are willing or able to hold the token.

“The regulator’s concern is practical rather than theoretical,” market observers noted, since institutional holders of collateral often have strict eligibility rules about the instruments they can accept, and an ambiguous regulatory perimeter can be enough to keep a product out of collateral portfolios entirely.

Depending on industry feedback, the FCA said it may consider several policy responses. These include clarifying existing rules, developing a recognized classification for specific regulatory purposes, and assessing targeted rule or legislative changes. It may also consider whether a bespoke regime for tokenized gold or tokenized commodities is needed.

Bank of England Joins the Conversation

The consultation was published alongside a separate feedback statement from the FCA and the Bank of England on tokenization in wholesale financial markets. The two regulators said they received 123 responses to a May call for input and that firms were generally supportive of the UK’s work on wholesale tokenization.

Collateral was the most frequently mentioned use case. Respondents asked for more clarity on the eligibility of tokenized collateral, including tokenized money market funds, gold and stablecoins. The FCA and BoE said they will publish a tokenization roadmap later this year with details and target dates for each workstream.

The stakes are significant for London. The city remains the world’s dominant over-the-counter gold market, accounting for about 70% of global notional trading volume, according to the World Gold Council. How the UK treats tokenized gold could therefore set de facto standards for how the instrument is used well beyond British borders.

What Wholesale Collateral Would Unlock

Collateral mobility is the quiet prize in the tokenization race. Gold held in vaults moves slowly, with pledging and rehypothecation often requiring paper transfers and multi-day settlement windows. A token representing vaulted gold with verified ownership rights could, in principle, be pledged, recalled and redeployed within hours, freeing liquidity that currently sits locked in margin arrangements.

Wholesale market participants have already made the case for exactly this kind of eligibility clarity in other tokenized asset classes, and gold, with its deep liquidity and long collateral pedigree, is the natural next candidate. The FCA’s own feedback highlighted that firms want certainty not just on whether tokenized collateral is permitted, but on the conditions under which it counts for regulatory and risk-management purposes.

A Gradual Institutional Thaw

The FCA had already been discussing a potential tokenized gold framework with banks and other market participants, Cointelegraph reported in August. The UK has also been developing stablecoin rules and testing digital pound interoperability in cross-border payments, part of a broader effort to keep London competitive as other financial centers race ahead on tokenization.

Tokenized gold products have grown alongside the broader tokenization boom, with issuers combining the familiarity of a centuries-old store of value with 24/7 transferability and programmable settlement. But the fund-rules question has lingered as a brake on institutional adoption, since products that drift into CIS or AIF territory carry fund-management obligations that many token issuers never designed for.

The FCA’s openness to targeted exemptions suggests a preference for surgical fixes over a one-size-fits-all regime, an approach consistent with its broader strategy of regulating by use case rather than technology. Issuers, for their part, have long argued that a token backed by allocated physical gold with direct redemption rights behaves more like a warehouse receipt than a pooled investment fund, and should not inherit the full fund-management rulebook.

Bitcoin was trading around 77,709 USD at press time, while gold’s sustained rally over the past year has kept the metal at the center of portfolio discussions, adding to institutional interest in more efficient ways to hold and pledge it.

Market participants have until Oct. 23 to respond. The answers the FCA receives will shape not just the fate of tokenized gold in the UK, but potentially the template for how tokenized commodities are treated across major financial markets.