On 14 Sept the FCA and Bank of England published FS26/1 on tokenisation in UK wholesale markets. 123 responses, including BlackRock, BNY, Euroclear, Nasdaq, Coinbase, Ripple, Chainlink, Tether.
Everyone will cover the collateral finding. The paragraph worth keeping isn't about tokenisation.
One of the regulatory principles: all regulated activities must have an accountable, regulated person responsible for regulatory compliance.
Respondents pushed back, arguing it would be hard for DeFi firms to meet and so wasn't really tech neutral. The answer was no. Regulated activities require an identifiable person responsible for that activity, and the FCA sees no case to change the perimeter.
Its reason is one line: it cannot accept solutions where customers have no recourse when assets are lost or stolen. Recourse needs somebody to have recourse against.
Now the IMF, April, Note 2026/004, on a completely unrelated market:
"Most payment regimes require that a payment order be traceable to an authorized instruction from an account holder or its legally recognized agent. Agent-initiated payments challenge this model, as individual transactions may not correspond to explicit, transaction-level instructions."
Authorization becomes structural and mandate based. Two authorities, two unrelated markets, five months apart, same requirement, and neither has a mechanism for it.
Why that matters: you told your bank to pay a supplier, one instruction, one payment, one name. You told an agent what you wanted, four hundred payments, every one authorised, none of them instructed. The legal question has an answer at the mandate and no answer at the transaction.
The IMF's risk table has three columns. Source, who bears the cost, and whether there's a market failure justifying policy intervention. Eleven risks, eleven yeses. For the instruction gap the cost lands on account holders, on payment providers through disputes, and on payment systems through operational strain. Two of those three never made a decision about the agent. That's an externality, which is why the third column says yes.
Separate two things that keep getting merged. Attribution asks who is responsible for this payment. Performance asks whether the thing paid for happened. The IMF's authorization layer: AP2 mandates, OAuth, ERC-1812 claims, ERC-780 registries, ERC-6900 spend limits, and ERC-8004 for agent identity and reputation, named in an IMF table under "know your agent". All of it attribution and permission. Nothing in that layer holds funds against a condition.
One layer down the principle is already settled, and it took three years.
@circle applied to the OCC in June 2025 and got final approval on 10 July 2026, USDC reserves in cash and short-dated Treasuries attested monthly, EURC authorised under MiCA, listed on the NYSE.
A supervisor asking who is accountable for the instrument has an address. Asking who is accountable for the agent's payment, it doesn't.
#AgenticAI #Payments #Stablecoins