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Custody, Settlement and Investor Redress in the FCA's Permanent Operating Regime for Digital Securities

1 September 2026 · CurveBlock · Context: Financial Conduct Authority
Custody, Settlement and Investor Redress in the FCA's Permanent Operating Regime for Digital Securities

As the FCA moves from sandbox testing toward an enduring framework for digital securities, established investor-protection concepts—safeguarding assets, clear ownership records and complaints handling—remain core. Custody in a tokenised world can mean segregated electronic records, regulated custodians holding private keys, or legal arrangements ensuring entitlement to a share in the underlying asset. The regulator has signalled that firms must have robust arrangements that prevent commingling, enable reconciliation and provide continuity in the event of operational failure.

Settlement finality and clear transfer mechanics are important for investor confidence. POP expectations will likely emphasise operational resilience, audit trails and transparent transfer processes that align with existing company and trust law. Equally important are firms' obligations on disclosures and complaints handling; retail investors should be able to understand the mechanisms for raising disputes, the timelines for resolution, and the role of established redress bodies where relevant.

Regulatory oversight under POP will interact with existing protections such as client money/client asset rules and the Financial Services Compensation Scheme where applicable. Retail investors should note that the applicability of those protections depends on the regulated activity being carried out and the legal model used to represent investor interests in the asset.

For everyday UK savers exploring fractional digital share investing, assess whether platforms describe custody arrangements, settlement mechanics, and complaint routes clearly. Transparent operational and redress frameworks make it easier for retail investors to compare platforms and understand how their holdings are protected within the new regulatory regime.

Reference source: Financial Conduct Authority

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