From Foundations to Frameworks: A Look Back at 2025 and the 2026 Crypto Roadmap

The legal perspective on cryptocurrency in the United States has undergone a significant transformation over the last 12 months. While the state of crypto under the Biden Administration was defined by “regulation by enforcement” and uncertainty, 2025 will be remembered as the year the United States aimed to become the “crypto capital of the world.”

As we begin 2026, the crypto industry is no longer fighting for the right to exist; instead, it is racing against the legislative clock to finalize the rules of the game before the political tides could shift once again.

2025: The Year of the "New Normal"

The momentum of 2025 was driven by a decisive shift in the executive branch’s posture. Under the Trump Administration, the federal government pivoted from a "regulation by enforcement" model to one that viewed digital assets as a pillar of American financial competitiveness. This transition was marked by three primary pillars: landmark legislation, a focus on jurisdictional clarity, and a complete overhaul of agency leadership.

The GENIUS Act: A Historic Milestone

In July 2025, President Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. This was the first significant piece of crypto-specific legislation to become federal law. For years, the lack of rules for stablecoins created a "gray market" that kept many traditional banks on the sidelines. The GENIUS Act changed this by:

• Mandating 1:1 Reserves: Requiring all payment stablecoin issuers to back their tokens with high-quality liquid assets like US dollars or short-term Treasuries.
• Introducing Monthly Reserve Audits: Establishing a standard for transparent, third-party attestations of these reserves.
• Clarifying Jurisdiction: Formally declaring that payment stablecoins are neither securities nor commodities, placing them instead under the supervision of federal banking regulators like the OCC and the Federal Reserve.

The Search for "Clarity"

While the GENIUS Act addressed stablecoins, the broader market still struggled with the question of which tokens were securities and which were commodities. The House of Representatives took a significant step toward solving this with the CLARITY Act (Digital Asset Market Clarity Act). Though it faces a longer road in the Senate, the CLARITY Act provided a blueprint for how a token could transition from a security (during its fundraising phase) to a commodity (once the underlying network became sufficiently decentralized). Meanwhile, the relevant Senate Committees (Banking and Agriculture) have been working on their own market-structure bills, with guidance from the Committees, to finalize them at the beginning of 2026.

Personnel is Policy: Atkins and Selig

The shift in tone was most visible at the SEC and CFTC. At the Securities and Exchange Commission, Paul Atkins took the helm and immediately launched "Project Crypto." His goal was to move away from the "securities-law minefield" of the past. Atkins famously argued that many tokens traded today are not themselves securities, but rather the result of investment contracts that have long since expired.

At the end of December 2025, Michael Selig was confirmed as the Chairman of the CFTC. Selig brings a "principles-based" approach, focusing on market integrity and fraud prevention rather than technical "gotcha" enforcement. Even before Mike Selig's appointment, Acting Chairwoman Caroline Pham launched a “Crypto Sprint” to modernize rules for spot trading and allow the use of tokenized collateral in traditional derivatives markets.

2026: The Implementation Phase and the Election Clock

If 2025 was about setting the foundation, 2026 is about the finished structure. However, the industry faces a new set of pressures this year, primarily driven by the upcoming mid-term elections and the grueling process of federal rulemaking.

The Market Structure Bill: The Final Piece

The most critical item on the 2026 legislative agenda is the Market Structure Bill in the Senate. This bill is intended to bridge the gap between the SEC and the CFTC once and for all. It seeks to create a formal registration process for crypto exchanges, similar to how national securities exchanges operate, but tailored for digital assets.

The challenge is the "Senate logjam." While there is bipartisan support for the bill, reconciling the versions from the Banking and Agriculture committees is a complex task. Leadership in both committees has expressed a desire to move quickly, but the window for substantive policy work is closing fast.

GENIUS Act Rulemaking

While the GENIUS Act is law, it is not yet fully operational. The statute gave federal regulators a strict timeline to write the "fine print." These rules will determine the exact capital requirements for stablecoin issuers and the process for banks to enter the space.

• The July 18, 2026, Deadline: This is the date by which regulators are expected to release final rules for the GENIUS Act. The Act will then become law 120 days after the rules have been published.

The Midterm Election Pressure

Perhaps the most significant factor in 2026 is the November midterm elections. Historically, the U.S. Congress loses its appetite for complex, bipartisan legislation as the summer approaches and members head home to campaign.

Industry advocates are pushing for a "speed-to-market" strategy. The goal is to get the Market Structure Bill to the President’s desk well before the August recess. If the bill is not passed by then, it risks being pushed into a "lame duck" session at the end of the year—or worse, being delayed until a new Congress takes over in 2027. The current political makeup of the Senate is favorable to crypto, but there is no guarantee that it will remain true after the November election.

A Pivotal H1 2026

The first half of 2026 will likely determine the trajectory of the American crypto industry for the next decade. We have moved past the era of "will they or won't they" regarding regulation. The questions now are more practical: How fast can the rules be written? What will firms need to do to meet the new standards? And can Washington find the focus to finish the job before the election cycle takes over?

The momentum from 2025 provided a rare window of opportunity. Whether 2026 is remembered as a success will depend on whether that window remains open long enough for the Market Structure Bill to cross the finish line.