On the Record by Bitcoin Policy UK

Bitcoin Policy UK

The UK's Bitcoin policy conversation On the Record by Bitcoin Policy UK brings the organisation’s latest work and thinking to audio.  Listen to policy papers, consultation responses, research briefings, commentary, and interviews with members of the BPUK team.Covering Bitcoin regulation, CBDCs, financial freedom, digital finance trends, and more, the podcast helps policymakers, professionals, and those exploring Bitcoin stay informed on the issues shaping its future in the UK and beyond. Learn more at https://bitcoinpolicy.uk/

  1. Oct 16

    Open Letter to the FCA: Why Bitcoin Should Not Be Treated as a Generic Cryptoasset

    This episode is an AI-spoken version of Bitcoin Policy UK’s open letter to the Financial Conduct Authority, dated 8 October 2026. The letter argues that the FCA’s developing cryptoasset framework should recognise the fundamental differences between Bitcoin and cryptoassets with identifiable issuers, founders or controlling organisations. Bitcoin has no issuer or company that can alter its monetary policy, allocate supply to insiders or make disclosures on behalf of the network. Bitcoin Policy UK supports the principle of “same risk, same regulation”, but argues that this requires regulators to distinguish between genuinely different structures and risk profiles. Firms providing Bitcoin services can create risks that warrant regulation, including through custody, leverage, conflicts of interest and control of customer funds, but those risks should not simply be attributed to Bitcoin itself. The letter also considers the practical consequences for the UK Bitcoin industry. Rules designed around issuers or centrally controlled projects can impose costs on Bitcoin businesses that do not correspond to the risks they present, potentially making it harder for smaller firms to operate in the UK and pushing consumers towards overseas or less regulated alternatives. It highlights the importance of protecting open and non-custodial Bitcoin infrastructure. Bitcoin Policy UK welcomes the FCA’s clarification on self-custody and argues that regulation should avoid unintentionally capturing non-custodial wallet developers, open-source maintainers, node operators and miners where they do not have custody or control of customer funds. Finally, the letter puts five questions to the FCA, including whether it will provide guidance recognising Bitcoin’s distinct characteristics, assess the regulatory burden on smaller UK Bitcoin businesses, protect non-custodial infrastructure and reconsider Bitcoin’s classification as a Restricted Mass Market Investment. 📄 Read the full written letter here:  👉  Open Letter to the FCA:  Why Bitcoin Should Not Be Treated as a Generic Cryptoasset To find out more about Bitcoin Policy UK's work and how you can get involved, visit: https://bitcoinpolicy.uk/

    Open Letter to the FCA: Why Bitcoin Should Not Be Treated as a Generic Cryptoasset

  2. Oct 9

    Response to the Bank of England and FCA's Approach to Joint Regulation of Systemic Stablecoin Issuers

    In this AI-spoken episode, we hear Bitcoin Policy UK’s response to the Bank of England and Financial Conduct Authority’s proposed approach to jointly regulating systemic stablecoin issuers. While systemic stablecoins are a different asset class to Bitcoin, Bitcoin Policy UK argues that the coherence and predictability of the framework matters because it forms part of the wider regulatory environment in which UK Bitcoin businesses operate. The paper examines what happens when a stablecoin issuer becomes systemically important and moves into joint regulation by the Bank and FCA. It calls for clearer division of supervisory responsibilities, early certainty over which FCA rules will continue to apply, and transitional arrangements that avoid firms facing a regulatory "cliff edge" when they become systemic. It also considers the proposed 12-to-36-month transition period, arguing that the regime should take account of firms' different starting positions, including their banking relationships, access to settlement infrastructure and balance-sheet strength. Other issues covered include the 24-hour redemption requirement during transition, ensuring smaller and newer firms can benefit from proportionality measures, and the need to protect open Bitcoin infrastructure from rules intended for identifiable regulated businesses. In particular, Bitcoin Policy UK asks the Bank and FCA to confirm that the framework will not apply to open-source protocols, non-custodial wallets, node operators or decentralised payment routing infrastructure such as Lightning routing where there is no central controlling entity.  📄 Read the full written paper here: 👉  Response to the Bank of England and FCA's Approach to Joint Regulation of Systemic Stablecoin Issuers To find out more about Bitcoin Policy UK's work and how you can get involved, visit: https://bitcoinpolicy.uk/

    Response to the Bank of England and FCA's Approach to Joint Regulation of Systemic Stablecoin Issuers

  3. Sep 25

    Response to the Bank of England’s Consultation on Stablecoins Code of Practice

    The Bank of England is developing a new Code of Practice for sterling-denominated systemic stablecoins. Bitcoin Policy UK broadly welcomes changes that make the proposed regime less burdensome, including a move to a 70/30 backing model and the replacement of individual holding limits with a temporary £40 billion issuance guardrail. But it argues that significant questions remain about proportionality, competition and the Bank of England’s influence over privately issued money.  In this AI-spoken episode of On the Record, we present Bitcoin Policy UK’s response to the Bank of England consultation in full. The paper examines the substantial costs that could fall on stablecoin issuers, including the requirement to keep 30% of backing assets as unremunerated deposits at the Bank of England. BPUK argues that these costs could disproportionately affect smaller and newer entrants, potentially favouring large banks and established financial institutions. It also questions whether the 30% requirement should remain fixed when it is based partly on evidence from the unusual market stress surrounding Silicon Valley Bank and USDC in 2023.  The response also considers how the proposed regime compares with the rules governing commercial bank money. BPUK accepts that there are legitimate reasons for systemic stablecoins to be fully backed, but asks whether the proposed combination of central bank deposits, government securities, capital requirements and other reserves is the most proportionate way of achieving financial stability. It also notes that, as the stablecoin market grows, the rules could channel significant amounts of private capital into UK government debt.  A broader question is how distinct privately issued systemic stablecoins would ultimately remain from central bank money. Under the proposals, their backing, liquidity arrangements and thresholds would increasingly depend upon rules and infrastructure set by the Bank of England. BPUK draws a parallel with some of its concerns about a potential digital pound and asks the Bank to explain where the boundary between private and central bank digital money will sit.  The paper also addresses privacy and AML/KYC requirements, redemption times, custodian concentration, reliance on the gilt repo market and the transition from FCA to Bank of England regulation. 📄 Read the full written paper here: 👉  Response to the Bank of England’s Consultation on Stablecoins Code of Practice To find out more about Bitcoin Policy UK's work and how you can get involved, visit: https://bitcoinpolicy.uk/

    Response to the Bank of England’s Consultation on Stablecoins Code of Practice

  4. Sep 18

    Response to HMRC's Draft Legislation on Cryptoasset Loans and Liquidity Pools

    HMRC is proposing new rules for the taxation of cryptoasset lending, borrowing and liquidity pools, including a move to “no gain, no loss” treatment for qualifying arrangements. This would mean that lending Bitcoin and later receiving Bitcoin of the same type back should not itself trigger a capital gains tax charge. Bitcoin Policy UK supports this core approach, which reflects its longstanding position that lending Bitcoin should not be treated in the same way as disposing of it.  This is an audio version of Bitcoin Policy UK’s response to HMRC’s draft legislation in full. The response examines where the proposed rules work well for Bitcoin, as well as areas where BPUK believes the drafting needs further clarification. These include the “low risk of loss” test for Bitcoin lending, the potentially problematic tax treatment of forfeited collateral, and the complexity of the provisions dealing with defaults and repayments. BPUK also calls for plain-English guidance with Bitcoin-specific examples before the new regime takes effect on 6 April 2027.  The paper also considers an important distinction between native Bitcoin and wrapped or tokenised Bitcoin. While the two may receive similar tax treatment in some circumstances, BPUK argues that guidance should make clear that they have materially different characteristics and risks.  Finally, the response highlights an issue these reforms do not resolve: capital gains tax on everyday Bitcoin payments. BPUK continues to argue separately for a full CGT exemption for retail Bitcoin payments. 📄 Read the full written paper here: 👉  Response to HMRC's Draft Legislation on Cryptoasset Loans and Liquidity Pools To find out more about Bitcoin Policy UK's work and how you can get involved, visit: https://bitcoinpolicy.uk/

    Response to HMRC's Draft Legislation on Cryptoasset Loans and Liquidity Pools

  5. Sep 11

    Submission to the Crypto and Digital Assets APPG Parliamentary Inquiry into Access to Banking Services

    Access to banking services remains one of the biggest obstacles facing Bitcoin users and businesses in the UK. In this audio version of Bitcoin Policy UK’s August 2026 submission to the Crypto and Digital Assets APPG Parliamentary Inquiry into Access to Banking Services for the UK Crypto and Digital Assets Sector, we argue that, despite progress towards a comprehensive UK regulatory framework, blanket restrictions on lawful Bitcoin-related banking activity remain widespread and may actually be getting worse.  The submission examines evidence that UK banks continue to block or limit transfers to exchanges, restrict banking access for digital asset businesses and, in some cases, apply the same broad risk treatment to Bitcoin as to very different cryptoassets. Recent industry research cited in the paper suggests around 40% of bank-to-exchange transfers are blocked or delayed, while several major banks maintain outright blocks.  It considers why these restrictions persist, including genuine fraud concerns, AML obligations, regulatory uncertainty and institutional risk aversion. BPUK argues, however, that these concerns should lead to individual, risk-based assessment rather than blanket restrictions, particularly where customers are dealing with FCA-registered businesses.  The paper also looks at approaches taken in France and Hong Kong before setting out four recommendations for the UK: distinguish Bitcoin from other cryptoassets when assessing risk; require banks to explain restrictions and provide an appeal process; give banks clearer assurance that they can rely on FCA registration; and publish regular data showing the scale of banking restrictions affecting the sector. 📄 Read the full written paper here: 👉  Submission to the Crypto and Digital Assets APPG Parliamentary Inquiry into Access to Banking Services To find out more about Bitcoin Policy UK's work and how you can get involved, visit: https://bitcoinpolicy.uk/

    Submission to the Crypto and Digital Assets APPG Parliamentary Inquiry into Access to Banking Services

  6. Jun 19

    Bitcoin Policy UK Privacy Toolkit: Simple Steps to Protect Your Freedom to Speak and Transact Online

    Privacy is often framed as something only criminals or conspiracy theorists care about. But what if privacy is actually about freedom, security, and maintaining control over your own life? In this special AI-generated episode of On the Record, two AI hosts discuss Bitcoin Policy UK's latest Privacy Toolkit, exploring practical steps anyone can take to reduce surveillance, protect personal data, and reclaim a measure of digital independence. Drawing on the toolkit's recommendations, the conversation covers everything from password managers and private messaging apps to Bitcoin, VPNs, self-hosted services and censorship-resistant social media. It also examines the trade-offs involved, why privacy matters even if you have "nothing to hide", and how different people may choose different points on the privacy spectrum.  This episode is based on the Bitcoin Policy UK paper Privacy Toolkit: Simple Steps to Protect Your Freedom to Speak and Transact Online. The audio discussion was generated using AI from the original paper. What You'll Learn In This Episode Why privacy is fundamentally about control, not secrecy The real-world consequences of data breaches and surveillance How to think about privacy as a spectrum rather than an all-or-nothing choice The simplest privacy improvements most people can make in under ten minutes Why tools such as Signal, Proton Mail, Brave, Mullvad and GrapheneOS feature prominently in the toolkit The role Bitcoin can play in preserving financial privacy How censorship-resistant technologies such as Nostr are emerging as alternatives to traditional social media The difference between practical privacy measures and more advanced operational security Why Bitcoin Policy UK believes privacy underpins freedom of speech and freedom of transaction Resources mentioned include (see the original paper for the full list):  Bitcoin Policy UK Privacy Toolkit (April 2026)  Have I Been Pwned  Proton Mail  Proton Pass  Signal  Brave Browser  DuckDuckGo  Mullvad VPN  GrapheneOS  Tor Browser  Nostr  Phoenix Wallet  Bitrefill  Linux Mint  Umbrel  Start9 Read the original paper: Privacy Toolkit: Simple Steps to Protect Your Freedom to Speak and Transact Online To find out more about Bitcoin Policy UK's work and how you can get involved, visit: https://bitcoinpolicy.uk Note: This episode features an AI-generated discussion based on a written Bitcoin Policy UK publication. The views discussed are derived from the original paper, which remains the authoritative source material.

    Bitcoin Policy UK Privacy Toolkit: Simple Steps to Protect Your Freedom to Speak and Transact Online

  7. Jun 5

    Response to HM Revenue and Customs Call for Evidence: Taxation of Stablecoins

    In this episode we present an audio version of Bitcoin Policy UK’s response to HMRC’s Call for Evidence on the taxation of stablecoins, originally published on 6 May 2026.  The paper argues that if HMRC recognises stablecoins as payment instruments deserving lighter tax treatment, then the same logic should also apply to Bitcoin when it is used for everyday payments. 🔍 The Core Problem: Bitcoin Payments Trigger Capital Gains Tax Under current UK rules, every time someone spends Bitcoin, even buying a coffee, it can create a capital gains tax (CGT) event. That means users may need to:  Calculate sterling-equivalent acquisition and disposal values  Track transaction histories  Maintain detailed records  Potentially report activity to HMRC Bitcoin Policy UK argues that this creates:  Significant administrative friction  Deterrence to real-world payment usage  Very little meaningful tax revenue ⚖️ The Central Argument: Treat Payment Activity Like Payment Activity The submission argues that Bitcoin should not automatically be treated as a speculative investment when it is functioning as a medium of exchange. BPUK proposes a usage-based framework:  Retail payments → treated similarly to money/foreign currency  Speculative trading → taxed normally  Long-term investment → standard CGT rules apply The key point is that function should matter more than asset category. 💡 Why Bitcoin Qualifies The paper argues that Bitcoin already operates as a meaningful payment network in the UK:  Bitcoin accounts for a significant share of UK crypto payments activity  Lightning Network infrastructure enables instant, low-cost settlement  UK businesses already use Bitcoin payment processors and merchant networks The consultation’s rationale for stablecoin payment relief therefore applies equally to Bitcoin. 📉 “Regulatory Theatre” and the Bed-and-Breakfasting Problem One of the paper’s strongest claims is that the current regime creates complexity without generating meaningful revenue. Many users already lawfully:  Spend Bitcoin  Immediately repurchase the same amount  Reset their cost basis (“bed-and-breakfasting”) As a result:  HMRC collects very little CGT from genuine payment activity  Users still face substantial compliance burdens BPUK argues this is effectively “regulatory theatre”. 🌍 International Competition The paper also highlights how other jurisdictions are moving more aggressively:  The Czech Republic eliminated CGT on long-held Bitcoin  Germany exempts crypto gains after certain holding periods  Several US states have passed Bitcoin rights legislation The warning is clear - without reform, the UK risks losing:  Talent  Capital  Innovation  Payment infrastructure leadership 📈 The “Velocity Multiplier” A major economic argument in the submission is the idea of a velocity multiplier. BPUK argues that removing CGT friction would:  Increase transaction frequency  Encourage merchant adoption  Expand economic activity  Ultimately increase VAT receipts The paper suggests this could more than offset any minimal reduction in CGT collection. 🏛️ Policy Recommendation Bitcoin Policy UK strongly supports:  A full CGT exemption for cryptoasset payments used for goods and services  A framework based on economic function, not issuer or denomination  Inclusion of Bitcoin alongside stablecoins where genuine payment utility exists The submission warns that limiting relief only to sterling stablecoins would create artificial market distortions and ignore existing Bitcoin payment ecosystems. 🧠 The Bottom Line This paper frames the issue as bigger than tax simplification. According to BPUK, the UK now faces a strategic choice:  Preserve outdated treatment built around speculative assumptions, or  Recognise the emergence of digital payment infrastructure and position Britain as a global leader in crypto payments policy The future of payments may be digital. The question is whether the UK intends to lead or follow. 📄 Read the full written paper here: 👉  Response to HMRC Call for Evidence: Taxation of Stablecoins To find out more about Bitcoin Policy UK's work and how you can get involved, visit: https://bitcoinpolicy.uk/

    Response to HM Revenue and Customs Call for Evidence: Taxation of Stablecoins

  8. Feb 20

    Response to FCA Consultation Paper - Regulating Cryptoasset Activities

    In this episode, we present an audio version of Bitcoin Policy UK’s response to FCA Consultation Paper CP25/40 on the regulation of cryptoasset activities, originally published on 29 January 2026. This submission sets out BPUK’s position on how the UK should regulate cryptoassets and, crucially, how it should avoid category errors that treat Bitcoin as interchangeable with issuer-driven tokens. 🔍 Core Argument: Avoid the Category Error A central theme of the submission is that Bitcoin is not interchangeable with the wider “cryptoasset” sector. Bitcoin: Has no issuer, foundation or controlling entityCannot alter its monetary policy by committeeEnables peer-to-peer settlement without intermediariesFunctions as a form of digital commodity moneyMany other cryptoassets, by contrast, are issuer-driven products with insider allocation, governance discretion and venture-style backing. Regulatory design must reflect this distinction. 🧭 The Perimeter Boundary That Matters BPUK urges the FCA to draw a hard line between: Custodial/intermediary activity (where regulation is effective and appropriate), andNon-custodial infrastructure such as wallet software, node operators, miners and open-source developers (where firm-style obligations are infeasible or nonsensical).The framework will succeed or fail based on whether it respects this boundary. 🏛️ Key Policy Themes The response covers a targeted set of consultation questions, focusing on areas where regulatory design has the greatest impact: 1️⃣ Retail Protection BPUK supports strong retail protections where harm concentrates: Custody failuresLeverage and lending risksConflicts of interestIssuer-driven token promotion cyclesHowever, it cautions against treating Bitcoin as equivalent to centrally issued tokens when applying restrictions. 2️⃣ Best Execution & Price Source Rules The paper warns against overly rigid UK-only pricing or execution requirements that could: Reduce access to global liquidityWorsen spreads for UK consumersFragment marketsPrinciples-based standards focused on outcomes are preferred. 3️⃣ Conflicts of Interest & PFOF BPUK strongly supports tighter controls on: Internalised tradingToken listing conflictsPayment for order flow (PFOF)Retail users must not become monetised inventory. 4️⃣ Staking & DeFi Where a clear controlling person exists, regulation is appropriate. But “protocol regulation” by default risks: Capturing open-source infrastructureImposing unenforceable obligationsChilling domestic innovationDefinitions of “control” must focus on custody, discretion, and unilateral power, not vague influence. 5️⃣ Tax & Lending Neutrality The response also references ongoing tax issues around DeFi lending and staking, arguing that: Current tax treatment does not reflect economic substanceCryptoasset lending is treated less favourably than traditional securitiesThe UK risks falling behind without reform📄 Read the full written paper here: 👉  Response to FCA Consultation Paper CP25/40 To find out more about Bitcoin Policy UK's work and how you can get involved, visit: https://bitcoinpolicy.uk/

    Response to FCA Consultation Paper - Regulating Cryptoasset Activities
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About

The UK's Bitcoin policy conversation On the Record by Bitcoin Policy UK brings the organisation’s latest work and thinking to audio.  Listen to policy papers, consultation responses, research briefings, commentary, and interviews with members of the BPUK team.Covering Bitcoin regulation, CBDCs, financial freedom, digital finance trends, and more, the podcast helps policymakers, professionals, and those exploring Bitcoin stay informed on the issues shaping its future in the UK and beyond. Learn more at https://bitcoinpolicy.uk/

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