Legal development

Further, Faster, and Action: UK Wholesale Markets Digital Champion's catalytic plan

    Need to know

    • UK Wholesale Digital Markets Champion (WDMC) delivers his 14 July 2026 first report (Report). The Report Taskforce comprises more than fifty firms from across the industry, spanning traditional finance (TradFi) and digital natives.
    • A key Report headline is that tokenisation could increase UK economic output by up to £33bn and generate an extra £14bn of taxes in the next decade (Barclays and PwC estimates). 
    • The Report seeks to corral the UK Government, regulators, and industry. Its 12 month roadmap seeks to ensure that UK tokenised assets, infrastructure, and financial markets are world-leading while maintaining regulatory integrity. 
    • Further and faster was the (now former) Starmer Government's clarion call since 2024. The Report has the ambition and support to deliver.  
    • Landing among a flurry of other 2026 UK digital assets activity (for example here, here, here, here, and here, comments are open until 4 September 2026.
    • For more background: Digital Assets 101

    Why this really matters

    There has been a notable mindset shift by UK policymakers and regulators (from the beginnings of 2025's thaw, to the regulators' watershed 2026 tokenisation joint vision reset). Tokenisation and digital assets are now mainstream, a fundamental financial pillar, and a key growth engine. 

    The benefits of distributed ledger technology (DLT) are clear; the challenge is implementation. Recognising the many DLT milestones and landmark initiatives, the Report provides a broad, strategic, and coordinated plan for full-stack tokenisation. 

    The Taskforce's work cannot come too soon. Industry's cadence was already high, and UK policymakers and regulators are catching up (eg the cryptoassets regime, systemic stablecoins, and the UK/US stablecoins statement). The Taskforce provides vital coordination to enable the sector to move ahead swiftly and pragmatically. 

    Full lifecycle

    The Report correctly identifies that to scale, create network effects, and realise DLT's benefits, there must be an end-to-end lifecycle.

    Despite many existing groundbreaking and world-first projects, including the UK Government's DIGIT on-chain bond issuance and the Digital Securities Sandbox (DSS), challenges remain. For example, engaging the buy- and sell-side, liquidity and secondary markets, capital utilisation and mobility, interoperability, post-trade, and settlement infrastructure.

    The lack of a universal and interoperable digital cash leg remains a key challenge. While there are differing views for each of the current candidates - stablecoins, tokenised deposits, and central bank digital currencies (CBDCs) - many initiatives are in train. For example, UK systemic stablecoins (here and here), GBTD tokenised sterling deposits, EU Pontes and Appia, the USA's GENIUS Act and Clarity Act, the OUSD stablecoin, Swift’s tokenised deposit blockchain, the UK-US Joint Statement on Stablecoins, and BIS publications (eg here and here).

    The Report recognises the importance of on-chain settlement, including the need for UK stablecoin regulation. We think that the outcome will be a multi-moneyverse: co-existing forms of digital money which aim to be freely exchangeable. (For a deeper dive: GFMA's The Role of Digital Money in Capital Markets). 

    The Taskforce will play a vital role; an end-to-end repo use case on blockchain with interoperability is a key practical Taskforce deliverable. Repo is a good starting use case. The Global Financial Trade Associations' 2025 Distributed Ledger Technology in Capital Markets paper (which shares many of the Report's conclusions) found that repo and collateral was one of three categories where DLT adoption is most advanced. 

    Law, regulation, common standards

    Legal and regulatory constraints and uncertainty were widely seen as blockers to broader DLT adoption. That perception is changing; there has been a significant 2026 uptick from UK policymakers and regulators (see 'Why this really matters') and the Law Commission and the UK Jurisdiction Taskforce are making important contributions. However, important gaps remain. 

    For example, settlement finality (the point at which a transaction cannot be reversed (insulating from a counterparty's insolvency)) is critical in on- and off-chain financial markets. Digital settlement differs from traditional finance; based on the blockchain's consensus mechanism. Both EU and UK settlement finality legislation only cover traditional finance. While the EU is progressing DLT settlement finality, we agree with the Report that UK legislation must be updated. 

    UK tax law was not designed for DLT. Even when on- and off-chain transactions are substantively the same, tax treatment can differ. While there are some legislative proposals in progress, we agree that the Government needs to ensure that all UK tax law is technology neutral.

    Permissionless blockchains continue to be a hot regulatory topic. Partly as a result of the Global Financial Trade Associations' call for recalibration (including technology neutral treatment of permissioned and permissionless blockchains), the BCBS is conducting a targeted review of its cryptoasset exposures standard. The global regulatory trend is technology neutral (and even technology positive by the FCA). The Report's call for a comprehensive approach towards permissionless networks in the "medium-term” may prove too conservative if market adoption continues at its current pace. We suggest that the Taskforce keep this timeline under active review. 

    New technology and use cases can pose novel, and sometimes systemic, risks. Policymakers and regulators have a fine line to tread: over-regulation will likely stifle innovation and drive activity to unregulated jurisdictions. Under-regulation exposes end-users, and could also have systemic effects. We wait to see whether the new UK Government continues a pro-digital policy

    As with traditional finance, common standards and interoperability are crucial. The Report notes strong industry consensus that standards, rather than any technology, are key to interoperability. This aligns with policymakers' and regulators' longstanding preference for industry-led solutions (for example the USA, European Commission, and UK). In addition, trade associations (such as ICMA and AFME) will continue to be closely involved. 

    International cooperation and competition; a paradox?

    Digital assets are nowhere and everywhere at the same time, and stakeholders have jurisdictional choices. Competition to be a leading digital assets financial centre is intense. At the same time, and for the same reason, international cooperation is crucial. 

    The Report notes that the UK and US are on "similar timelines" for stablecoin regulation, both targeting full regimes in 2027. And that the UK is further advanced with a cryptoasset regime published, while the US Clarity Act is still in the legislative process. This is correct, and one could go further. There is an argument that the EU's Markets in Crypto-Assets Regulation (MiCA) has, in some respects, suffered from first-mover disadvantage.

    The Report posits that international standard setters are lagging market developments, in effect, providing the UK with a window of opportunity. The precedents suggest that this is harder than it appears. While the BCBS is behind the curve (see 'Law, regulation, common standards'), the EU's MiCA has not precipitated extra-territorial legislative gravitational pull (the 'Brussels effect'), and the USA is taking its own regulatory tack. We support the Report's aspiration, but UK-led international consensus could be challenging. 

    And AI & quantum

    DLT and AI can enhance each other's technological strengths, with the potential for unique collaborative use cases. Quantum risk is a board-level, strategic, and existential issue; assessment, planning and action should start now.

    The Report acknowledges DLT's interaction with UK Government AI and quantum initiatives, but AI and quantum warrant only three references each. The Taskforce will identify the most prevalent and impactful crossovers, and engage to help enable these "distinct but related initiatives to work together". 

    Artificial intelligence is "the most impactful technological development of our time - more impactful than computers or the internet" (Geoffrey Hinton). "The real Q[uantum]-day may occur before the world becomes aware of it" (Citi Institute). 

    The Taskforce has an enormous worklist and short timeframe; adding considerably to participants' already very busy day jobs. However, given their importance, adequate time must be found for AI and quantum.

    No time to lose

    The Report recognises the scale of work needed and the timing imperative. There are three key potential headwinds (or tailwinds). 

    First, UK Government and regulator support is critical. We wait to see if the Burnham administration places digital markets at the core of its growth program. 

    Second, industry support from over 50 firms demonstrates unprecedented buy-in and breadth of commitment. However, coordinating so many participants across nine Action Groups within a 12 month horizon is ambitious. The Taskforce's governance and delivery mechanisms will need to match that ambition. 

    Third, although international cooperation is essential, the world faces a new competitive order with impact across multiple concurrent risk domains.

    Authors: Etay Katz, Partner; Alex Biles, Partner; Bradley Rice, Partner; Sid Ulker, Counsel; and Simon Williams, Counsel.

    The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
    Readers should take legal advice before applying it to specific issues or transactions.