Hogan Lovells Digital Assets and Blockchain

A strong episode from Hogan Lovells’ The Influencers: Digital Transformation podcast. Plenty of useful insight on how digital transformation is reshaping regulatory expectations, governance frameworks and business models, particularly relevant for financial institutions navigating fast‑moving change. 📢 Worth a listen.

🔴 Live from our London office (17 March, from 4:30pm GMT) We’re live this afternoon for a focused session with Mobius, exploring how UK pension schemes can engage safely and pragmatically with the rapid shift from tokenisation pilots to production. We opened the session with remarks from Guy Opperman, Strategic Advisor and Independent NED, before moving into deep‑dive briefings on the legal and regulatory frameworks and the practical operating model considerations — including custody, controls and data — that pension schemes must assess as they explore tokenised assets. We’re also discussing where the earliest return on effort genuinely lies for schemes beginning their tokenisation journeys. We then move into an educational session delivered jointly with EY, followed by a moderated panel featuring market practitioners shaping the next phase of tokenisation adoption in the UK. Stay tuned for insights following today’s discussion — and if you’d like to explore what tokenisation and the evolving UK framework mean for your organisation, we’d be pleased to connect. Sharon Lewis Bryony Widdup John Salmon Mobius

On International Women’s Day, we are proud to celebrate Sharon Lewis, Bryony Widdup and Liz Greaves, who have each been recognised in Innovate Finance’s Women in FinTech Powerlist 2025 for their outstanding leadership, influence, and contribution to the financial services sector. Sharon Lewis and Emily Reid have also been recognised in the 'Hall of Fame'– a new category this year, which recognises a decade of FinTech trailblazers.   Being featured in the powerlist is a significant achievement, reflecting their commitment to excellence, integrity, and the advancement of women across the industry. Their leadership continues to shape the future of financial services – driving progress, inspiring talent, and championing positive change. You can view the full powerlist here: https://lnkd.in/e3kc8VYz   We are delighted to celebrate this recognition on International Women’s Day, and proud to support and spotlight the trailblazers shaping the future.   Happy International Women’s Day!

The new UK Cryptoasset Regime is coming, and preparation matters.   As the UK moves towards full FCA authorisation for cryptoasset activities, firms should be planning now. Here’s a reminder of the key milestones and what to focus on: Key dates 👉 12 March 2026 – Deadline for responses to FCA CP26/4 (Application of the FCA Handbook) 👉 July 2026 – FCA Pre‑Application Support Service (PASS) opens 👉 30 Sept 2026 – 28 Feb 2027 – Authorisation application window (with saving provisions) 👉 25 October 2027 – Regime goes live   What firms should be doing now ✔ Assess whether your products and services are in scope ✔ Understand territorial reach, entity structure and UK presence ✔ Prepare for FCA engagement via PASS ✔ Develop a clear, FCA‑ready business model summary ✔ Build momentum early — demand for PASS is expected to be high   During 2026, the FCA will finalise rules and guidance. Firms that engage early and apply within the window will be best placed to minimise disruption and maintain continuity when the regime goes live.   Hogan Lovells supports firms of all sizes through the full cryptoasset authorisation lifecycle, combining legal and consulting expertise to deliver practical, regulator‑ready advice.   Keep up with the latest regulatory developments by signing up below 👇 to receive updates on upcoming events related to cryptoassets regulation.   👉 https://bit.ly/40etXRG John Salmon Sharon Lewis Michael Thomas Lavan Thasarathakumar Mark OrtonMark Aengenheister Nick Oxley Charlie Middleton James Sharp Dominic Hill

The UK’s new Cryptoasset Regime goes live on 25 October 2027 — and firms should start preparing now.   Once the regime is live, firms carrying out regulated cryptoasset activities will need to be authorised under FSMA by the FCA. The regime introduces new activities (custody, trading platforms, dealing, arranging, staking, stablecoin issuance) and a far wider territorial scope that will capture many overseas firms serving UK retail clients.   How Hogan Lovells can help firms get ahead: ✔ Assess whether activities are considered “in the UK” ✔ Advise on group structuring, including branch and subsidiary models ✔ Advise on UK presence and substance requirements including assessing suitability under the SMCR ✔ Analyse activities, advise on permissions and conduct token analysis ✔ Support with documentation including drafting or obtaining QCDDs   Why start early: • Identify required permissions • Test whether your structure is fit for purpose • Build UK operations and governance well before authorisation   Early engagement will be key to securing FCA approval in 2027. If you’d like to understand how the regime affects your business, our team is ready to support. John Salmon Sharon Lewis Michael Thomas Bryony Widdup Mark Aengenheister Nick Oxley Lavan Thasarathakumar Mark Orton James Sharp Charlie Middleton

UK Cryptoasset Regime: FCA PASS Opens July 2026   From July 2026, cryptoasset firms can engage early with the FCA through its Pre‑Application Support Service (PASS) — an opportunity to discuss proposed business models, permissions and expectations directly with a dedicated case officer ahead of submitting an application.   PASS gives firms early clarity, helps identify challenges and supports stronger, more complete applications under the new UK cryptoasset regime.   Why it matters: ⭐ Build early dialogue with regulators ⭐Receive feedback on permissions, models and business plans ⭐Prepare for a smooth transition into the new regime   👉 Firms planning to continue operating or launch new products should engage early. If you’d like guidance on preparing for PASS or navigating the UK cryptoasset framework, get in touch with our team — we’re here to help. John Salmon Sharon Lewis Michael Thomas Bryony Widdup Mark Aengenheister Nick Oxley Lavan Thasarathakumar Mark Orton James Sharp Charlie Middleton

Hogan Lovells is delighted to contribute once again to the Global Digital Finance Annual Report, a flagship publication shaping global dialogue on digital assets, regulatory evolution, and the future of financial market infrastructure. We are especially proud of the thought leadership delivered by John Salmon, Partner and Co‑Chair of our Digital Assets and Blockchain practice, who contributed across several high‑impact chapters:   🔹 EU Policy & Regulatory Working Group Co‑authored with Nathan Catania, Partner at XReg Consulting, this chapter provides deep insight into the realities of MiCA implementation across EU Member States and the operational challenges firms face as supervisory expectations evolve. 🔹 A Positive Outlook for UK Cryptoassets Co‑authored with Lavan Thasarathakumar, Senior Advisor at Hogan Lovells, this piece analyses the UK’s ambition to become a global hub for digital assets and explores how the forthcoming regime can balance innovation, proportionality, and institutional readiness. 🔹 Digital Payments Forum As Co‑Chair of the Forum, John — together with Will Paul, Global Public Policy Lead for Payments, Hardware, and Small Business at Block — examines the rapid evolution of digital money, developments in stablecoin regulation, and the increasing convergence between tokenised payments and financial market infrastructure. These contributions underscore Hogan Lovells’ commitment to advancing responsible innovation and supporting our clients across the digital assets ecosystem as policies, markets, and technologies rapidly mature.   We congratulate GDF on another outstanding year of industry leadership and collaboration, and we look forward to continuing to shape the future of digital finance together. 👇 Explore the full report to dive deeper into the insights driving 2026 and beyond. 

The FCA’s new Cryptoasset Regime is accelerating, and after the FCA Payments & Digital Assets Authorisations webinar (29 Jan), the path ahead for firms is clearer and more urgent.   To help teams navigate what’s coming, we’ve pulled together an at‑a‑glance timeline of every major milestone, including consultation deadlines, the opening of PASS, the application window, and the final go‑live date.   If you’re operating or planning to operate in the UK crypto sector, these are the dates you cannot afford to miss. 👇   🔹 12 Feb 2026 – Feedback due on CP25/40, CP25/41, CP25/42 🔹12 Mar 2026 – Feedback due on CP26/4 🔹 July 2026 – FCA’s PASS pre‑application service opens 🔹 30 Sep 2026 – 27 Feb 2027 – Application window for cryptoasset permissions 🔹 25 Oct 2027 – The new regime goes live   Across the slides we break down: ✔ What’s changing ✔ Why each milestone matters ✔ What firms should be doing now to stay ahead   The message is simple: early engagement will be critical, whether that’s shaping consultation responses, preparing a robust application pack, or ensuring operational readiness for 2027. If you’d like to discuss the implications or how to prepare your organisation, feel free to reach out to our teams or visit our website, which are tagged in the comment section.

Re-sharing this excellent upcoming session from GDF and Hogan Lovells → a timely deep dive into the fast‑evolving digital money ecosystem. 🔗 Register here: https://luma.com/m95z6sja

Save the Date: Tokenisation Moves From Pilot to Production   Tokenisation is no longer theoretical — it’s happening now. Join Mobius and Hogan Lovells for a focused afternoon on how UK pension schemes can engage safely and pragmatically with this shift. We’ll cover the real guardrails that matter, from legal and regulatory considerations to custody, controls, operating models, and where the early return on effort truly lies.   What to Expect 👉 An educational deep‑dive with experts from Hogan Lovells and EY 👉Opening remarks from Guy Opperman, Pensions & Financial Inclusion Minister (2017–2022) 👉A moderated panel featuring leading market practitioners 👉Plenty of time to connect over networking sessions   🗓️ 17 March | 4:00–7:00 pm GMT Registration will open soon. Please keep your eyes peeled! Sharon Lewis Bryony Widdup James F. Nasreen Anderson Rowena Scarbrough Guy Opperman Amarjit Singh 💙 Theo Golden, CFA James Lawrence, CFA Beccy Milchem Matt Ong Mobius