The FCA’s September call for input examines whether tokenising gold could improve transfer and collateral workflows in UK wholesale markets. Its questions reach beyond ledger technology to the legal rights represented by a token, the handling of underlying bullion and the boundary between existing fund rules and future guidance. FCA: Call for Input on tokenised gold in UK wholesale markets, 14 September 2026
Follow the evidence
Trace how the event could reach markets, then inspect a competing explanation.
Compare explanations
Switch lenses to see what each account explains—and what remains uncertain.
The FCA is collecting evidence about both operational benefits and legal-perimeter risks before setting a future approach.
The FCA is collecting evidence about both operational benefits and legal-perimeter risks before setting a future approach.
Legacy wholesale systems may be more mature for some uses; the call itself makes no determination that a new regime is needed.
The FCA is gathering evidence on use cases and risks
The FCA published its call for input on 14 September 2026 and set 23 October 2026 as the response deadline. It asks how tokenisation might improve trading, transferring, pledging and holding gold in UK wholesale markets. FCA: Call for Input on tokenised gold in UK wholesale markets, 14 September 2026
The regulator says tokenisation creates digital tokens representing ownership of physical gold that can be transferred electronically. Its questions include wholesale use cases, practical challenges and uncertainty around the collective-investment-scheme and alternative-investment-fund regulatory perimeter. FCA: Call for Input on tokenised gold in UK wholesale markets, 14 September 2026
The FCA says it will review responses to shape a future approach, which could include guidance or consideration of a bespoke regime. The call does not establish that any token is backed, redeemable, legally equivalent to bullion ownership or authorized by the regulator. FCA: Call for Input on tokenised gold in UK wholesale markets, 14 September 2026
A token’s transferability does not answer what ownership means
A brokerage or venue assessing a gold token needs to trace rights across the token, issuer, custodian, vault and underlying metal. Transfer on a ledger may be technically fast while legal settlement, redemption, liens or insolvency treatment remain dependent on contracts and jurisdiction.
If the token is used as collateral, operational design must also specify valuation, margin calls, substitution, access to the asset and what happens when a transfer fails. The FCA’s call flags wholesale collateral as a possible use case, not a finding that these arrangements already work at scale.
The perimeter question matters because different structures can create different investor rights and regulatory obligations. A token that references gold does not by itself prove direct ownership, segregation, redemption rights or a particular treatment under UK rules.
Respond to the questions about rights, custody and market plumbing
Read the FCA’s full call and identify which questions apply to the firm’s role: issuer, custodian, broker, venue, fund manager or technology supplier. Submit evidence on actual workflows, failure handling, legal rights and costs rather than general claims about blockchain efficiency.
For a product review, reconcile token supply to independently verified bullion records; inspect custody terms, title, segregation, audit cadence, redemption conditions, transfer restrictions and insolvency protections. Check how disputes and lost keys are handled.
A competing view is that existing wholesale bullion infrastructure may remain more efficient for many uses, while tokenisation adds new custody and perimeter risks. The call is designed to gather evidence on both benefits and constraints before the FCA decides what, if anything, should follow.