On June 22, 2026, the Bank of England threw out an unexpectedly "loosened" version: the latest policy statement and draft "Code of Conduct" for systemic stablecoin issuers no longer insists on the previously controversial "individual and corporate holding limits" red line, but instead shifts the regulatory focus to setting a total issuance cap of "initial issuance not exceeding £40 billion" for each systemic stablecoin. On the asset side, the draft also softens its stance — the proportion limit of interest-bearing assets, such as short-term UK government bonds, that can be configured in qualified reserves has been raised from 60% to 70%, while still requiring at least 30% of reserves to remain in central bank deposit accounts to ensure liquidity at any time. The media quickly interpreted this: this is a policy adjustment that emerged in response to strong feedback from the industry, meaning that the central bank is willing to make a more pragmatic trade-off between financial stability and payment innovation, while market prices and trading volumes temporarily remain static, choosing to wait to see the details implemented before making decisions. Before the final rules are finalized by the end of the year, a straightforward question lies before all issuers and platforms: when regulation shifts from "controlling every user" to "focusing on the entire pool," who is the boundary redrawn for, and who will be forced to rewrite their business model?

From Holding Limit Control to Total Quantity Cap

In the early proposal, the Bank of England directly targeted end-user wallets: whether individuals or businesses, anyone holding payment tokens pegged to the pound would face a hard balance red line. The regulator's logic was straightforward — by limiting the amount an individual entity can hold, potential systemic risks could be "squeezed into the wallet." However, the industry quickly pushed back: for retail users, this limit means that once the quota is used up, to use tokens to pay salaries, make cross-border settlements, or manage liquidity, they must return to the traditional account system; for businesses, financial and settlement processes become complex splits around regulatory red lines, amplifying implementation costs and compliance uncertainties. Thus, this seemingly technical "holding limit" has been viewed by many participants as a key barrier hindering the genuine adoption of payment tokens in mainstream business scenarios.

The latest draft simply turns the page: the central bank clearly abandons the setting of holding limits on wallets for individuals and businesses, instead establishing a "total initial issuance not exceeding £40 billion" ceiling for each identified systemic payment token. The regulatory perspective shifts from "monitoring how much money is in each wallet" to "controlling how large the entire token pool is," so ordinary users and businesses no longer need to monitor their token balances daily for regulatory red flags and can embed such tools more naturally within existing business processes. Meanwhile, the overall size remains locked under the total quantity framework and systemic safeguards set by the central bank, and as soon as it approaches the £40 billion threshold, pressure will shift from end users to issuers and cooperative platforms: what truly needs recalculating is the pace of expansion for the issuers, rather than how many pounds ordinary users can still spend on a daily basis in on-chain payments.

Relaxation of Reserve Assets: The Trade-off Between Returns and Safety

When holding limits are no longer imposed on end users, the structure of reserve assets becomes the subject of negotiation. In this version of the draft, the Bank of England administers a "profit booster" shot to issuers: the upper limit on the proportion of interest-bearing assets like short-term UK government bonds in collateral assets has been raised from 60% to 70%, meaning more funds can be allocated to return-generating assets. However, at the same time, the regulator has not relinquished control over the "cash gate" — at least 30% of reserves must be held in the form of central bank deposits, and the Bank of England has deliberately emphasized in the statement that systemic safeguarding measures like central bank deposit accounts will be retained, ensuring that the safety bottom line does not take a step back.

For issuers, this represents a newly delineated boundary between profit and risk control: the additional 10 percentage points are allowed to shift from "pure safety" to "yield-bearing," directly expanding the projects’ profit pool and leaving them greater maneuvering space in terms of rates, subsidies, and revenue sharing, no longer relying solely on convenience and technology storytelling to compete with traditional currency products. But the regulation locks at least 30% of reserves firmly in central bank accounts, ensuring that in concentrated redemptions and payment peak scenarios, issuers must always produce "the toughest liquidity," and cannot place their entire safety net on market-traded assets. The boundaries are drawn more finely: those who want to earn more must prove within this 70% yield-bearing asset and 30% central bank deposit framework that they can outpace traditional products while avoiding transferring systemic risks to the entire payment system.

Who Benefits Most Directly: Issuers, Financial Technology, and Trading Platforms

The first to recognize the "ceiling" are the institutions planning to issue pound-denominated systemic payment tokens within the UK framework. In the past, they were unclear about what regulators considered "too large;" now the maximum issuance for each product in the initial stage can reach £40 billion, turning the formerly vague threat into a clear measurement. Furthermore, with the upper limit on the proportion of interest-bearing assets such as short-term UK government bonds raised to 70%, as long as they secure the bottom line of at least 30% required to sink into central bank deposit accounts, issuers are allowed to design a more commercially viable model balancing returns and stability. This set of rules effectively hands potential issuers a compliance manual on "how to make money and how not to expand the balance sheet," with the primary beneficiaries undoubtedly being players ready to launch pound-denominated systemic tokens in the UK market.

Following the issuance end, payment institutions, cryptocurrency trading platforms, and custodial and settlement service providers see that the business landscape may be redrawn: once compliant pound token products are truly launched, payment companies can embed them into online acquiring and cross-platform clearing, trading platforms can use them as a basis for pound-denominated pricing and margins, and custodial and settlement institutions have the opportunity to design custody and clearing services more closely aligned with traditional finance around the combination of central bank deposits and government bonds. For banks and traditional financial institutions, this arrangement opens up possibilities for custody reserves, token settlement accounts, and even co-issuing and co-operating with tech companies, but how far these paths can go still depends on how the final rules, set to be finalized by the end of the year, will shape up. Currently, market prices and trading volumes show little reaction, which indicates that most players are still waiting for that final text before daring to truly place their bets.

Pragmatic Shift: How the Central Bank Responds to Industry Pressure

If we look at this year’s regulatory process with a broader lens, the Bank of England’s stance change is very clear: from the initial proposal that intended to impose hard upper limits on how much payment tokens individuals and businesses could hold to the latest draft on June 22, which completely abandons this notion in favor of establishing a "total initial issuance not exceeding £40 billion" cap for each systemic token. Formally, this is just a shift from "user-side limits" to "asset-side caps," but essentially it is a direct response to the industry's concerns about "usability" and "scalability": it no longer directly severs the business scenarios of large merchants and payment institutions, but instead brings risk management forward to overall scale control and reserve quality. In this regard, the draft increases the upper limit of short-term UK government bonds and other interest-bearing assets from 60% to 70%, providing issuers with a clearer profit model, while also mandating that at least 30% of reserves must be held in the form of central bank deposits and emphasizing the continued retention of such systemic safeguards in the statement, effectively telling the market — the room for innovation can be expanded, but the safety net will not be withdrawn.

This "first presenting a somewhat conservative draft, then adjusting it in response to industry feedback" rhythm itself is a signal. For project parties and license applicants assessing the UK compliance path, it signals two things: first, the regulatory goal will not shift from "financial stability" to "unconditionally encouraging innovation," but specific tools are not set in stone and can be negotiated and fine-tuned through formal consultation and feedback; second, as long as they can clearly articulate their roles within the framework of the central bank’s designated total quantity limit and reserve structure — whether they are creating pound-pegged payment tools or serving as a broader settlement layer — regulatory expectations are likely to shift from "whether to allow" to "how to implement." Given that the final rules are still slated for finalization by the end of the year, this pragmatic turn is enough to alter the timelines of many teams: rather than simply waiting, they might as well design business scale paths and asset-liability structures early around the £40 billion total cap and 30% central bank deposit bottom line, because the truly non-negotiable element will be that risk bottom line, not the regulator's attitude towards the prospects of domestic crypto payments and pound tokenization.

Finalizing Rules Before the End of the Year: Several Unresolved Challenges

Currently, what the Bank of England has presented is just a policy statement and a draft "Code of Conduct," rather than a definitive version that can be executed verbatim; the official timeline states that the truly binding details will not be finalized until the end of the year. Before that, specific clauses concerning "systemic safeguarding measures" have been intentionally left blank, making it impossible for outsiders to accurately calculate the real costs of capital occupation, liquidity preparedness, and operational transformation. For issuers and platforms, several key challenges remain unsolved: what scale and business structure will be deemed "systemic," triggering more intense prudential regulation; how the boundaries for the use of central bank deposit accounts will be defined, and whether wallet service providers and payment institutions can obtain stable access to the banking system, and in what form; whether regulators will tighten the applicability of the £40 billion initial issuance limit on a case-by-case basis. Until these answers are out, this draft resembles a directional regulatory boundary rather than an operational manual that can be directly translated into product rhythms and risk control processes. Thus, despite the framework having taken shape, current market prices and trading volumes remain calm, with most participants choosing to adjust their plans while waiting rather than rashly advancing large-scale layouts; the true points of contention will not be revealed until the final text version is implemented at year-end.

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