9 December 2025
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Financial Regulation - In the know: Payments – December 2025

To The Point
(5 min read)

The UK is progressing digital money regulation through several workstreams led by the Government, industry, and regulators. HM Treasury and the Bank of England are considering a digital pound to complement cash and deposits, aiming to boost the digital economy. Industry collaboration is also underway, notably the Regulated Liability Network initiative, which experiments with programmable money for wholesale payments and settlement. Regulation of cryptoassets and stablecoins has accelerated, with the Financial Conduct Authority establishing a new regime for stablecoin issuers and custodians in May, and the Bank of England publishing a consultation paper in November outlining the proposed regulatory framework for systemic stablecoins. This issue examines these developments, key milestones, and future directions as the UK continues to adapt to the challenges and opportunities presented by digital money.



The digital pound: Progress, hurdles, and the road ahead

The Bank of England (BoE) and HM Treasury are actively considering a digital pound to sit alongside cash and bank deposits, aiming to boost the UK’s digital economy. This forward-looking initiative is now in its design phase, with a final decision on rollout anticipated after 2026, subject to new legislation. In the article below, we delve into the latest updates and strategic direction for the BoE’s digital currency plans. We also spotlight the key challenges and opportunities this development could present for businesses and financial institutions. 

Read our insights here.

UK regulated liability network (RLN)- the opportunity, but what’s left to do?

The Regulated Liability Network (RLN) initiative is an ongoing industry collaboration experimenting with programmable money for wholesale payments and settlement. It proposes an infrastructure for managing a variety of regulated digital money on an interoperable network. The infrastructure aims to facilitate programmable payments and tokenised commercial bank deposits to improve security, reduce fraud, and increase efficiency in several financial activities including property transactions. 

Read more on the RLN project and the risks and opportunities that it presents here

Proposed regulatory regime for sterling-denominated systemic stablecoins

On 10 November 2025, the Bank of England (BoE) published a consultation paper setting out its proposed regulatory framework for systemic stablecoins. Stablecoins are digital assets designed to maintain a stable value and can be used for both retail payments and wholesale settlement. Key proposals include requirements for the composition of backing assets held by systemic stablecoin issuers. Issuers will be permitted to hold up to 60% of their backing assets in short-term UK government debt, with the remaining 40% held as deposits at the BoE.

Read more on the proposed regime and commercial implications for relevant firms here.

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Next steps

If you want to find out what these updates mean for your business, or discuss training opportunities or systems and controls changes, please feel free to get in touch with our Payments team who would be delighted to speak to you.

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Key contacts

Partner, Co-head of Digital Assets, Payments and FinTech, Financial Regulation
London, UK

Partner, Financial Regulation
London

Partner, Financial Regulation
London

Legal Director, Financial Regulation
London, UK

Managing Associate, Financial Regulation
London, UK