In 2025, we saw significant regulatory developments for digital assets. The GENIUS Act was signed into law, while the CLARITY Act passed the House and is currently moving through the Senate. Each act aimed to provide a comprehensive statutory framework designed to provide certainty while fostering innovation in the digital asset ecosystem. As a follow-up to our September 2025 article on US Digital Asset Regulation, we’re sharing developments that have taken place since the CLARITY Act and GENIUS Act were introduced or signed into law.
CLARITY ACT
The CLARITY Act was introduced with the intention of the SEC overseeing digital assets that behave like securities and the CFTC overseeing commodities that live on decentralized networks. By splitting responsibilities, the CLARITY Act aims to develop rules for exchanges, brokers, and trading, as well as address specific issues. In July 2025, the House passed the CLARITY Act by a bipartisan vote of 294 to 134 during what legislators dubbed “Crypto Week.” The bill then moved to the Senate, where it must clear two separate committees (the Senate Banking Committee and the Senate Agriculture Committee) before proceeding to a full Senate floor vote, where it would likely need 60 votes to overcome a potential filibuster. The Senate Agriculture Committee advanced its version of the legislation in January 2026, passing the Digital Commodity Intermediaries Act by a narrow 12-to-11 vote along party lines. The Senate Banking Committee, however, still has yet to complete its markup, and to date, several markups were cancelled without a new date, and there is no confirmed upcoming markup or vote date.
Since its introduction, several banks have pushed back, and Coinbase CEO Brian Armstrong has gone as far as to publicly withdraw Coinbase’s support due to several objections to the draft. The main pushback comes from a conflict between the banking and crypto industries over a provision that would prohibit crypto platforms from offering rewards on stablecoin holdings. Banks argue the provision is necessary to prevent platforms from creating unregulated, bank-like deposits that could trigger mass deposit flight. The crypto industry contends that stablecoin rewards programs are not deposits and that the prohibition would eliminate a key revenue stream. Ripple CEO Brad Garlinghouse and others in the industry have urged the crypto sector to accept the bill despite its shortcomings and bring some regulatory certainty to the market.
This all comes during a time when the crypto market has experienced significant volatility, which is illustrated by Bitcoin dropping from its peak of $125,000 to lows of $60,000. As midterms approach, it’s questionable whether Congress will be able to resolve the remaining disputes and if the CLARITY Act will be able to pass at all. However, some industry leaders remain optimistic that we are near the end of negotiations and that the CLARITY Act will soon pass.
GENIUS ACT
The GENIUS Act for stablecoins was the first major federal legislation passed by Congress to define and regulate the issuance of payment stablecoins. In July 2025, President Trump signed it into law, establishing a licensing and supervision regime for payment stablecoin issuers that officially takes effect on the earlier of January 18, 2027, or 120 days after the primary federal payment stablecoin regulators issue final implementing regulations. The GENIUS Act is now entering the implementation phase with several major rulemakings underway or forthcoming. This summer, it is expected that new rules covering everything from audits to supervision of stablecoin issuers will be covered, with the FDIC, Federal Reserve, NCUA, OCC, Treasury, and state regulators expected to implement regulations by no later than July 18, 2026.
On September 19, 2025, the U.S. Department of the Treasury (the “Treasury”) published proposed rulemaking soliciting public input for stablecoin issuers and service providers, illicit finance, foreign payment stablecoin issuers, taxation, insurance, and economic data. By its November comment deadline, the Treasury received over 400 comment letters.
In December 2025, the Federal Deposit Insurance Corporation (“FDIC”) became the first regulatory body to publish proposed rules for stablecoin issuers and established the application process for FDIC-supervised state-chartered banks seeking to issue payment stablecoins through a subsidiary. In February 2026, the National Credit Union Administration (“NCUA”) published its own proposed rules and is accepting comments through April 13th. The Office of the Comptroller of the Currency (“OCC”) has separately previewed rulemaking that will address liquidity and other restrictions applicable to stablecoin issuers under OCC supervision. The Federal Reserve is also developing its own rules as one of the primary federal payment stablecoin regulators under the Act.
MOVING FORWARD
Where things go from here depends on two very different timelines running in parallel. The GENIUS Act is now in its implementation phase where regulators are working towards a July 18, 2026 deadline to finalize the rules that will govern stablecoin issuers, banks, credit unions, and other financial institutions in this space. The compliance clock is already ticking, and businesses operating in or entering the stablecoin market should be tracking these rulemakings closely and engaging in the comment process where their interests are at stake.
The CLARITY Act is a different story. Despite years of industry lobbying and a strong House vote, the bill’s fate now hinges on whether senators and industry stakeholders can resolve a relatively narrow set of disputes before the midterms make passing anything controversial nearly impossible. We will continue to monitor these developments and publish updates as the regulatory picture becomes clearer.