The UK Jurisdiction Taskforce (UKJT) published its Report on Control of Digital Assets on March 19, 2026. The Report was prepared by a Control Panel led by Lord Justice Sir Antony Zacaroli, with drafting support from David Quest KC and a panel of lawyers and technical experts. The Report provides non-binding practical guidance on how legal and technical control arises and operates in digital asset systems and how that analysis supports ownership and property rights questions under English law.
The Report operates alongside the Property (Digital Assets etc) Act 2026, which formally recognises a third category of personal property under English law encompassing certain digital assets that do not fit traditional categories of "things in possession" or "things in action." The Report sets out a typology of control mechanisms across digital asset architectures, including blockchain-based tokens, stablecoins, non-fungible tokens, and tokenised securities. It addresses how private keys, smart contracts, and custodial arrangements establish legal or equitable title and give rise to proprietary rights under English law.
Custodians holding digital assets on behalf of clients, exchanges registered as cryptoasset businesses under FCA rules, and issuers of tokenised securities must assess their control structures against the UKJT typology to confirm client asset protections and ownership claims will hold under English law. Financial institutions transacting in digital assets under English-law governed agreements benefit from the Report's analysis when structuring collateral arrangements, repo transactions, and insolvency scenarios. The Report is particularly relevant to cryptoasset service providers subject to the FCA's registration regime and to financial market infrastructure operators processing digital asset settlement.
The Report carries no statutory force and courts may treat it as persuasive non-binding guidance. Open questions remain on control analysis for multi-signature arrangements, multi-party computation custody structures, and smart-contract-governed assets where no single party holds a determinative private key. These questions may be addressed in further UKJT guidance or through case law development under the Property (Digital Assets etc) Act 2026.
Licentium advises digital asset businesses, custodians, and institutional investors on UK and EU digital asset regulatory requirements, and may assist with control structure analysis and FCA registration matters. Please contact us to discuss your situation. Work we undertake includes cryptoasset regulatory compliance, custody arrangement design, tokenised asset legal analysis, FCA registration support, and cross-border digital asset regulatory strategy.
Source: UK Jurisdiction Taskforce, Control Panel, Report on Control of Digital Assets, published 19 March 2026, https://lawtechuk.io/ukjt/
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