SEC Crypto 2.0: Roadmap of SEC Developments on Cryptocurrency and Digital Assets in 2025 

December 31, 2025

This past year marked a notable shift in the ongoing efforts to develop a regulatory framework for digital assets in the U.S. markets, driven by coordinated actions from the Securities and Exchange Commission (SEC) and the new presidential administration. Under the leadership of SEC Chairman Atkins and in alignment with the president’s digital-asset-friendly agenda, the SEC advanced certain guidance, and other initiatives in 2025 to provide clarity in the marketplace and develop a regulatory framework that promotes innovation and facilitates the trading and custody of digital assets.

What follows is a summary of these key statements and initiatives that we expect will shape the SEC’s regulatory landscape for digital assets in 2026 and beyond.

Launch of SEC Crypto Task Force

On January 21, 2025, SEC Acting Chairman Uyeda launched the Crypto Task Force “dedicated to developing a comprehensive and clear regulatory framework for crypto assets.”

Rescission of Accounting Guidance on Crypto

On January 23, 2025, the SEC issued Staff Accounting Bulletin No. 122 rescinding the interpretive guidance provided in Topic 5.FF, Accounting for Obligations to Safeguard Crypto-Assets an Entity Holds for its Platform Users, which required crypto assets to be recorded as liabilities on crypto holders’ balance sheets.

Crypto Task Force Priorities

On February 4, 2025, Commissioner Hester Peirce, leader of the Crypto Task Force, published a statement titled “The Journey Begins” that set forth certain priorities of the Crypto Task Force. These priorities include determining the status of digital assets under securities laws, identifying the scope of the SEC’s jurisdiction on regulation of digital assets and providing prospective and retroactive relief for offerings of certain digital assets.

Cyber and Emerging Technologies Unit for Retail Investor Protection

On February 20, 2025, the SEC announced the replacement of the Crypto Asset Cyber Unit with the Cyber and Emerging Technologies Unit (CETU), which is focused on retail investor protection, combating cyber-related misconduct, and judiciously deploying enforcement resources.

Staff Statement on Meme Coins

On February 27, 2025, the SEC’s Division of Corporation Finance issued a Staff Statement on meme coins, or digital assets inspired by internet memes, characters, current events, or trends. The statement stated that trading of the types of meme coins described does not constitute an offer or sale of securities under federal securities laws and does not require registration or exemption from registration under securities law.

Dismissal of Coinbase Enforcement Action

On February 27, 2025, the SEC announced the dismissal of a civil enforcement action against Coinbase, due to the Crypto Task Force’s efforts to rectify the SEC’s approach on digital assets by “developing crypto policy in a more transparent manner” rather than expressing the SEC’s views on crypto through enforcement actions.

Statement on Proof-of-Work Mining Activities

On March 20, 2025, the SEC’s Division of Corporation Finance issued a Staff Statement on certain proof-of-work mining activities, which clarifies that the mining of certain digital assets that are “intrinsically linked to the programmatic functioning of a public, permissionless network, and are used to participate in and/or earned for participating in such network’s consensus mechanism or otherwise used to maintain and/or earned for maintaining the technological operation and security of such network” (Covered Crypto Assets) does not constitute an offer or sale of securities under federal securities laws and does not require registration or exemption from registration under federal securities laws.

Crypto Task Force Roundtables

Beginning on March 21, 2025, the SEC Crypto Task Force held five roundtables that featured company and financial institution representatives, legal and regulatory experts, academics, researchers, and service providers who discussed a series of topics including the securities status of digital assets, public offerings of digital assets, exemptions and safe harbors from registration, trading and custody requirements, and more.

Staff Statement on Stablecoins

On April 4, 2025, the SEC’s Division of Corporation Finance issued a Staff Statement on stablecoins, or digital assets with their value tied to a reference assets such as the U.S. dollar or another fiat currency, which summarized the factor-based analysis necessary to determine whether transactions in stablecoins are subject to federal securities laws.

Staff Statement on Offerings and Registrations of Securities in Crypto Asset Markets

On April 10, 2025, the SEC’s Division of Corporation Finance issued a Staff Statement on offerings and registrations of securities in the crypto asset markets that addresses the SEC’s interpretation of certain disclosure requirements under Regulation S-K for offerings of digital assets registered under federal securities laws. Such disclosure requirements include the description of the business, description of securities, risk factors, identification and expertise of directors, officers, and significant employees, financial statements and exhibits.

Withdrawal of SEC and FINRA Joint Statement from 2019

On May 15, 2025, the Division of Trading and Markets of the SEC and Office of General Counsel of the Financial Industry Regulatory Authority withdrew a Joint Staff Statement regarding broker-dealer custody of digital assets previously issued on July 8, 2019.

Statement on Protocol Staking Activities

On May 29, 2025, the SEC’s Division of Corporation Finance issued a Statement on certain protocol staking activities. The statement noted that the following protocol staking activities do not involve the offer and sale of securities under the federal securities laws and do not require registration or exemption from registration under federal securities laws: (1) “staking” of Covered Crypto Assets on networks that use proof-of-stake (PoS networks) as a consensus mechanism (Protocol Staking); (2) activities taken by third-party service providers in connection with staking on PoS networks; and (3) ancillary services provided by third-party service providers such as slashing coverage, early unbonding, alternative reward payment schedules, and amounts or aggregation of Covered Crypto Assets.

FAQs relating to Crypto Asset Activities and Distributed Ledger Technology Launch of Project Crypto

On July 31, 2025, immediately after the publication of a report from the president’s working group on digital assets, the SEC launched “Project Crypto,” a series of initiatives aimed at developing regulatory proposals based on the group’s recommendations.

Statement on Liquid-Staking Activities

On August 5, 2025, the SEC’s Division of Corporation Finance issued a Statement on certain liquid staking activities. The statement noted that the following activities do not involve an offer and sale under federal securities laws and do not require registration or exemption from registration under federal securities laws: activities taken and ancillary services provided by protocol based or third-party service providers in connection with deposits by owners of Covered Crypto Assets in return for newly minted crypto assets that evidence such ownership of the Covered Crypto Assets and any related awards.

Spring 2025 Regulatory Agenda

On September 4, 2025, the SEC released its Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions that includes certain rule proposals related to the offer and sale of digital assets such as amendments to the definition of broker-dealers and custody rules.

Joint SEC and CFTC Statements

On September 5, 2025, SEC Chairman Paul Atkins and Acting Chairman Caroline D. Pham of the U.S. Commodity Futures Trading Commission (CFTC) issued a Joint Statement memorializing the SEC and CFTC’s efforts to harmonize regulations on digital assets to increase market choice, promote investor protection, and provide clear and predictable regulatory frameworks that promote innovation in the digital market. The SEC and CFTC previewed potential joint actions including the expansion of trading hours, coordination of margin requirements, and creation of safe harbors or innovation exemptions for peer-to-peer spot crypto trading.

No-Action Letter on Tokenized Security Entitlements

On December 11, 2025, the SEC’s Division of Trading and Markets issued a no-action letter to the Depository Trust Company (DTC) stating that the staff would not recommend enforcement action under various federal securities laws in order to allow the DTC to pilot a preliminary version of its voluntary securities tokenization program, which permits certain securities held through DTC to be represented as tokenized security entitlements.

Investor Advisory Committee Meeting

On December 4, 2025, the SEC’s Investor Advisory Committee met to discuss corporate governance and the tokenization of equities.

Crypto Asset Custody Basics

On December 12, 2025, the SEC issued the Crypto Asset Custody Basics for Retail Investors investor bulletin aimed at educating retail investors on the various types of digital asset custody strategies and related questions and tips.

 

The SEC’s statements and initiatives this year highlight its continued focus on developing a clear and concise regulatory framework for digital assets. With momentum continuing to build, we anticipate even greater SEC activity related to digital assets in 2026. Market participants and other stakeholders should remain proactive and carefully monitor developments to ensure compliance and adapt to the evolving regulatory landscape for digital assets.

 

 

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Authors

Katayun I. Jaffari

Chair, Corporate Governance
Co-Chair, Capital Markets & Securities
Chair, ESG

kjaffari@cozen.com

(215) 665-4622

Mehrnaz Jalali

Member

mjalali@cozen.com

(212) 453-3949

Rikisha Collins

Associate

rcollins@cozen.com

(215) 366-4464

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