With only a handful of working days left in 2025, it might be useful to look back on the year of crypto policy that passed, to inform us as we look forward.
What were the main industry’s key policy expectations of this year?
1. US policy momentum unlocks the industry for major global impact
2025 saw steady support from the Trump Administration for removing barriers that previously hampered the banking sector’s engagement with crypto. This cascaded to the Federal Agency level – from the Federal Reserve Board (FRB) and the Federal Deposit Insurance Corporation (FDIC) withdrawing post-FTX statements on the permissibility of engaging in crypto-related activities; to the Department of Justice (DOJ) ending “regulation by prosecution”; to the Office of the Comptroller of the Currency (OCC) confirming banks can engage in crypto-related activities incidental to banking.
The ripple effect was more than felt internationally. While many rulebooks were already in train, they were, firstly, expedited and, secondly, written with elected politicians much more closely observing their regulatory agencies. The tone of rulemaking began to shift from risk-aversion to competitiveness. This is true for stablecoins and payments, for tokenization of financial instruments, and for on-shoring crypto intermediation.
Will this trend hold in 2026? While we are keenly monitoring the lead-up to the U.S. midterm elections in November 2026, we are inclined to think that with the appointments made at regulatory agencies and with the rotation of institutional capital into digital assets, the trend is unlikely to be reversed.
Outside the U.S., 2026 will see a tug of war between permissive Ministries of Finance and cautious regulators. Likely, national champions will be best positioned to benefit from this tension.
2. Comprehensive market structure laws put in place for digital assets
Across jurisdictions, a core expectation was that 2025 would finally deliver comprehensive “who regulates what” market‑structure frameworks for spot and derivatives trading, custody, and broker‑dealer / exchange functions for crypto.
In the U.S., this legislative effort is centered on the Market Structure Bill, which was clearly delayed with the government shutdown, and at risk altogether if its passing cuts too close to the midterm elections.
Outside of the U.S., there were meaningful advances in foundational crypto-intermediation regulation in Canada, Brazil, Argentina, the U.K., major markets in Sub-Saharan Africa, UAE, Hong Kong, Australia, Japan, Indonesia, and Vietnam.
Critically, 2026 will be the year when most of the meat is put on the bones of most of these frameworks. For example, we know that in Japan, digital assets will be re-classified as investment instruments, which is helpful for their tax treatment, but we are yet to find out what this means for licensing and risk management.
One non-U.S. market we are closely watching is the U.K., which is very much subject to the tension between elected officials and appointed regulators, with the Chancellor taking an ever keener interest in the figure of digital assets, while the Governor of the Bank of England maintains a skeptical stance.
If we can learn a lesson from geographies where rules and licenses were being implemented this year, like the EU, we can expect acquisitions and market consolidation.
3. Stablecoin and payments regulation advances
Advancement of stablecoin legislation and policy was a prominent policy expectation for 2025. The U.S. GENIUS Act was passed in June. The Treasury Department has since issued an Advance Notice of Proposed Rulemaking (ANPRM) on its implementation, with federal agencies now focusing on their own implementation priorities.
Elsewhere in the world, Hong Kong passed its Stablecoin Bill in May, with the new regime coming into effect in August. Canada released a draft stablecoin law in November that mirrors the structure of the GENIUS Act, requiring 1:1 reserve backing and qualified custody. The U.K.’s Bank of England (BoE) consulted on rules that would suggest temporary holding caps on stablecoins (£20,000 for individuals and £10M for businesses) to prevent deposit outflows. Brazil’s Central Bank (BCB) issued its first comprehensive regulatory framework for cryptoassets in November, classifying certain crypto transactions as foreign-exchange operations. South Korea is at the precipice of issuing won-stablecoin legislation.
In 2026, we’d be looking for the triple point in stablecoin rollout:
- the nexus between commercial drivers for faster payment flows along major remittance and trade corridors in multiple currencies;
- clear and permissive rules on domestic AND foreign stablecoins;
- and risk management choices from banks, payment institutions, and corporations.
I expect a few new policy teams to gain prominence. Firstly, alignment of stablecoin rules. While equivalence is a politically difficult idea, global stablecoins issued in multiple countries (ie USDC) are compelling U.S., U.K. and EU regulators in particular to consider alignment. Secondly, permissibility for use of stablecoins in settlement of capital markets transactions. This remains a big issue in the U.K. and EU. Thirdly, wholesale CBDCs. The EU is fast approaching issuing one – potentially the missing link for interbank settlement of tokenized deposits.
4. Working out how “decentralized” is “decentralized enough”
For years, we have been speculating if and when decentralized finance (DeFi) will be subjected to some sort of regulatory requirements, imposed on somehow identifiable points of centralization. Yet, while there are a number of policy publications and regulatory working groups on this issue, no major jurisdiction has made a decisive move. Arguably, the Central Bank of the UAE took a first step with their most-recent framework, although a lot of details on the practicalities are still to be determined.
While 2025 was, yet again, not the year in which DeFi was regulated, there are a few drivers of more regulatory focus in 2026.
Firstly, the SEC’s “innovation exemption” – this will be a time-and-purpose-bound waiver of certain regulatory obligations. It may give U.S. institutions certainty that partnering with a DeFi project will not be dismantled through new rules or new enforcement.
Secondly, the Market Structure Bill. One of the biggest unresolved questions stalling Senate progress is how DeFi, its developers, and non‑custodial software should be treated under federal securities and commodities laws. The expectation here is for clear protections for software developers (especially open source), validators, and self‑custody set ups.
Thirdly, increased TradFi connectivity. The rotation of more institutional capital to DeFi can attract regulatory attention but it also gives space for the industry to work out risk management best practices ahead of a regulatory mandate.
5. Unlocking tokenization of financial instruments
Industry reports anticipated that 2025 would advance tokenization frameworks for securities, funds, bonds and other real-world assets (RWAs), including via wholesale markets pilots and clearer custody/segregation rules for tokenized instruments.
In 2025, political support for RWA tokenization seemed to run ahead of both regulatory clarity and as industry interest. Leaders from SEC Chairman Atkins, to the UK Chancellor, to Hong Kong’s Chief Executive, and MAS Managing Director in Singapore, all took stage to declare their capital as the aspiring hub for tokenization. Regulatory activity in support of these claims is lagging, but trickling through.
As the grey areas are still substantial, we expect 2026 to see more RWA tokenization in geographies where the political narrative extends a permissive umbrella. We expect reliance on “sandboxes” or “pilot regimes” to be an industry deterrent, contrary to how these structures are intended to be. We also expect TradFi commercial interests to dictate advocacy in this space much more obviously.
What the rearview mirror tells us about the road ahead
As we approach 2026, the policy imperatives are to shift from navigating the “unknown unknowns” of digital assets to operating within a more defined landscape, still filled with key “known unknowns.”
Together with market and interest rate developments, this environment will benefit institutions seeking to gain commercial territory ahead of their competitors, and ahead of innovation bets becoming commonsense logic.
Contact us to learn more about how Fireblocks can help you navigate policy and compliance requirements.
