Kavita Maharaj-Alexander:
 
Dec 31, 2025

2025 in Focus: A review of Five Key Regulatory Shifts Shaping Crypto and Web3

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As the crypto asset ecosystem continues its evolution from cutting-edge innovation to a regulated component of the global financial system, 2025 stood out as a pivotal year marked by significant regulatory progress. Across jurisdictions, policymakers pivoted towards the implementation of clearer and robust frameworks, placing greater focus on mitigating systemic risks and elevating compliance standards. These developments collectively signal a new phase in the maturing crypto landscape, highlighting the ways regulators and industry leaders are collaboratively shaping the future of Web3.

This review highlights the key developments that defined the year and set the stage for what comes next.


Stablecoins

Stablecoins continued to be a prominent focus within regulatory agendas throughout the year. Policymakers globally advanced legislative and supervisory initiatives in response to the growing role of stablecoins in payments and innovation[i], signalling a shift toward treating stablecoins as integral components of modern financial systems rather than experimental instruments.

In the United States, a significant milestone was reached in July with the enactment of the GENIUS Act[ii], a federal law establishing a comprehensive regulatory framework for fiat-backed payment stablecoins. This legislation mandates one-to-one reserve backing with permitted liquid assets[iii] and imposes stringent requirements for disclosures and independent audits, reflecting a clear policy intent to enhance institutional trust and mitigate systemic risks. By setting out clear rules for stablecoin issuance, reserve management, redemption rights and ongoing transparency, the Act seeks to balance responsible innovation with robust consumer protection through prudential, risk management, and compliance requirements[iv]. The Act is intended to take effect on the earlier of 18 months after enactment (i.e. January 2027) or 120 days after the primary federal payment stablecoin regulators issue their final regulations[v].

In Hong Kong, 2025 saw the full implementation of its stablecoin regime[vi], introducing licensing and operational requirements for issuers and mandating regular disclosures to bolster market integrity and user confidence[vii]. Requirements include that issuers must maintain full reserve backing with high-quality liquid assets at all times, minimum capital thresholds of HKD 25 million, and provide redemption at par value within one business day. The regime also embeds retail investor protections and mandates compliance with AML/CFT standards[viii], regular audits[ix], and transparent disclosures[x].

In South Korea, work continued on developing a stablecoin framework, as part of the broader Digital Asset Basic Act (DABA)[xi], with policymakers progressing prudential components intended to address issuance standards, reserve management, audit and user protections. Although the finalised proposal was not submitted within the anticipated timeline[xii], authorities continue to engage on the appropriate regulatory and supervisory approach. In parallel, industry‑led pilots progressed, including BC Card’s two‑month trial enabling foreign users to make domestic purchases using stablecoins converted into digital prepaid cards[xiii], and BDACS, in partnership with Woori Bank, completed a proof‑of‑concept for KRW1[xiv], validating issuance, collateral management, and on‑chain verification processes[xv]. With legislative work ongoing and a consolidated bill expected in early 2026, South Korea’s approach to stablecoin regulation remains in active development, shaped by efforts to ensure clarity, resilience, and coherence across the financial system.’

Japan’s established regulatory framework for stablecoins, shaped by recent reforms to the Payment Services Act, provided a clear foundation for continued experimentation in 2025, with banks and technology partners advancing pilots focused on settlement efficiency and cross‑border payments[xvi]. Authorities supported a joint stablecoin framework[xvii] in collaboration with major banks focusing on, inter alia, settlement efficiency and the safe integration of stablecoins within the existing banking system. JPYC Inc. became the first licensed FTSP[xviii] issuer (authorised to issue yen denominated stablecoin), and SBI VC Trade was authorised to distribute of USDC[xix].

The United Kingdom continued its phased implementation of a regulatory framework for fiat‑backed stablecoins in 2025, building on the powers introduced under the Financial Services and Markets Act 2023. HM Treasury published draft statutory instruments[xx] to bring stablecoin issuance and related activities formally within the FSMA perimeter, setting out the structure for authorisation, supervision, and the treatment of stablecoins used in payments. In parallel, the Financial Conduct Authority consulted on detailed rules for issuance and custody through CP25/14[xxi], focusing on redemption rights, reserve composition, operational resilience, and custodial oversight. The Bank of England also progressed its proposed regime for systemic payment systems using stablecoins, outlining prudential expectations for firms that could pose broader financial‑stability risks[xxii].

Canada’s crypto regulatory framework remained steady in 2025 but tightened around stablecoins as the CSA’s Staff Notice 21‑333 took full effect following the transition period ending 31 December 2024[xxiii], enforcing rules on the types of stablecoins permitted for trading and reinforcing the government’s plans to introduce a dedicated regime. The federal government used its November budget to table draft legislation establishing Canada’s first national framework for fiat‑referenced stablecoins, including fully backed, bankruptcy‑remote reserves, strict redemption and governance obligations, and Bank of Canada oversight[xxiv].

In Singapore, authorities progressed towards a dedicated legislative framework for stablecoins, focusing on licensing, operational resilience, and adequate reserve backing[xxv]. Singapore maintained its measured approach to stablecoin regulation in 2025 as the Monetary Authority of Singapore’s framework for single‑currency stablecoins continued to take effect.

Bahrain strengthened its regulatory approach to stablecoins in 2025 as the Central Bank of Bahrain introduced a dedicated framework for stablecoin issuance[xxvi]. The regime sets licensing and financial‑resource requirements for issuers, mandates high‑quality reserve assets with strict custody, reconciliation, and redemption‑rights provisions, and imposes governance, technology‑risk, cyber‑security, and disclosure standards. Ongoing reporting, restrictions on issuance, and recovery and redemption form part of the supervisory expectations, reinforcing Bahrain’s focus on responsible innovation within a prudentially supervised environment.

The UAE continued to develop its regulatory approach to stablecoins in 2025 as authorities refined their treatment of fiat‑referenced tokens within existing virtual‑asset frameworks. In September 2025, the Financial Services Regulatory Authority of ADGM advanced its work on fiat‑referenced tokens through Consultation Paper No. 9 of 2025[xxvii]. The Virtual Assets Regulatory Authority in Dubai advanced work on regulatory expectations for stablecoin issuers through its rulebook[xxviii]. Supervisory engagement remained active across the UAE as firms sought clarity on the treatment of stablecoins used in payments and settlement within a structured and risk‑sensitive regulatory perimeter.

Across these jurisdictions, the regulatory momentum reflected a shared recognition of stablecoins’ potential and associated risks. The frameworks adopted or proposed in 2025 collectively aimed to balance innovation with consumer protection and financial stability, among other things. As the sector evolves, these foundational steps are expected to shape the next phase of stablecoin adoption and oversight, supporting more institutional participation and the emergence of unified applications that blend traditional finance and decentralised technologies. With clearer standards around issuance, reserves, and redemption, crypto regulation entered a period of accelerating implementation and growing maturity.‍


Crypto Markets and Service Providers

In 2025, a growing number of jurisdictions advanced regulatory clarity for crypto markets and service providers, refining licensing regimes, strengthening operational standards and offering more explicit guidance on activities such as custody, trading and token issuance. Several authorities also clarified which activities and business models fall within their regulatory perimeter. While approaches continued to differ across regions, the year reflected a broader convergence around common regulatory themes, signalling incremental progress toward greater coherence across the global landscape.

In the European Union, the Markets in Crypto‑Assets became fully operational in late 2024, but 2025 reflected differing transitional approaches across member states[xxix], resulting in varied compliance timelines for crypto‑asset service providers[xxx]. This divergence persisted despite ESMA’s 2024 recommendation for national competent authorities to engage in early and continuous cross‑border dialogue to mitigate disruptions[xxxi], underscoring the practical challenges of implementing a complex, EU‑wide framework in its first year.

In the United Kingdom, progress continued on the development of the cryptoasset regulatory regime. The Financial Conduct Authority launched several consultations during the year[xxxii], engaging with the sector on regulating key activities. Its December consultation suite covered the regulation of cryptoasset activities[xxxiii], admissions, disclosures and market abuse[xxxiv], as well as a proposed prudential structure for cryptoasset firms[xxxv]. The HM Treasury also published the final draft Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 (Regulations) in December[xxxvi], together with an accompanying draft explanatory memorandum[xxxvii]. Collectively, these initiatives represent significant strides towards a clearer and more structured regulatory framework, reinforcing the country’s commitment to responsible innovation in the sector.

Across the Asia‑Pacific region, regulators continued to tighten oversight and clarify operational expectations for cryptoasset service providers. In Australia, the Government released draft legislation for consultation to bring digital asset platforms and tokenised‑custody providers within the Australian financial services regulatory framework[xxxviii]. ASIC updated its crypto guidance to clarify how existing financial services laws apply to digital assets, including when a token or related arrangement is a considered to be financial product; and to support industry transition through proposed relief for certain stablecoin and wrapped‑token distributors[xxxix]. Hong Kong published consultation conclusions on legislative proposals to establish licensing regimes for virtual‑asset dealing and custodian service providers and launched a separate one‑month consultation on new regimes for virtual‑asset advisory and management service providers[xl]. Vanuatu introduced new crypto legislation in 2025, establishing licensing, AML/CFT compliance and operational requirements for virtual‑asset service providers, and setting out requirements relating to consumer protection, operational standards, and the regulation of exchange and custodial services.[xli].

In Japan, the Financial Services Agency advanced work on a proposed dual‑classification framework for cryptoassets, first outlined in its April 2025 discussion paper[xlii] and further developed in the September 2025 working group report[xliii]. The model distinguishes Type 1 assets, issued for fundraising or business activities, from Type 2 assets, such as Bitcoin and Ethereum. Under the proposal, Type 1 assets would fall under a Financial Instruments and Exchange Act (FIEA) based regime with issuer‑level disclosure and operational requirements, while Type 2 assets would place information provision obligations on exchange operators. These discussions form part of broader efforts to refine exchange oversight, custody practices, and token‑listing processes, reflecting Japan’s continued emphasis on investor protection and alignment with established financial‑market frameworks. By December, the working‑group report[xliv] signalled a clearer move toward consolidating cryptoasset regulation under the Financial Instruments and Exchange Act and outlined a more developed information‑provision regime alongside enhanced expectations for market‑abuse controls, cybersecurity, and oversight of unregistered or overseas operators.

Across Africa, regulatory approaches to cryptoassets continued to evolve, with several jurisdictions progressing dedicated legal frameworks for virtual‑asset activities. In Kenya, Parliament enacted the Virtual Asset Service Providers Act, 2025, establishing a licensing and supervisory framework for virtual‑asset service providers, including fit‑and‑proper standards, business conduct, capital, cybersecurity, customer asset protection and AML/CFT/CPF obligations, as well as provisions for initial virtual asset offerings and enforcement powers[xlv]. In Ghana, Parliament passed the Virtual Asset Service Providers Bill, creating a framework for regulating virtual assets and virtual‑asset service providers under the joint oversight of the Securities and Exchange Commission and the Bank of Ghana, with licensing requirements to apply to all persons and entities conducting virtual‑asset activities[xlvi].

Across the Middle East, regulators continued to refine virtual‑asset frameworks and supervisory expectations. In Dubai, the Dubai Financial Services Authority issued updated rules on the regulation of crypto tokens in the Dubai International Financial Centre[xlvii], with the changes scheduled to take effect on 12 January 2026, including the removal of the centralised list of recognised crypto tokens and enhanced requirements for firms to assess token suitability. Separately, the Dubai Virtual Asset Regulatory Authority issued updated versions of all twelve of its Rulebooks in 2025, including changes to the Virtual Asset Issuance Rulebook[xlviii], to align with global regulatory practices and clarify licensing, disclosure, issuance and compliance obligations for virtual‑asset service providers[xlix]. In Abu Dhabi, the Financial Services Regulatory Authority published Consultation Paper No. 9 of 2025[l], proposing an expanded regulatory framework for Regulated Activities involving fiat‑referenced tokens, extending oversight beyond issuance to custody, intermediation and the holding or control of FRTs, and setting out criteria for the acceptance of domestic and foreign fiat‑referenced tokens within ADGM[li].

Across Latin America, regulators advanced comprehensive frameworks for virtual‑asset service providers and crypto asset markets. In Brazil, the Central Bank (Banco Central do Brasil) issued Resolutions BCB Nos. 519, 520 and 521 in November 2025[lii], establishing the authorisation regime for virtual asset service providers, defining the categories of intermediaries, custodians and brokers, and extending existing requirements on governance, AML/CFT, transparency, internal controls and client protection to all virtual‑asset service providers, with the rules entering into force on 2 February 2026[liii].

Argentina continued its regulatory consolidation in 2025, building on amendments to its AML Law (Law 25,246, as amended by Law 27,739) by operationalising a comprehensive framework for Virtual Asset Service Providers (PSAVs). Following the initial establishment of the PSAV Registry under CNV Resolution 994/2024[liv], CNV Resolution 1058/2025[lv] transformed the regime from a registration‑only model into a full supervisory perimeter, introducing PSAV categories, minimum capital requirements, custody and segregation standards, cybersecurity and systems‑audit obligations, and detailed conduct‑of‑business rules, with existing providers required to re‑register under the enhanced regime from mid‑2025[lvi].

In Panama, lawmakers introduced Bill No. 247 in 2025[lvii], proposing a regulatory framework for the use, commercialization and supervision of cryptoassets, including licensing and AML/CFT obligations for VASPs and regulating token offerings and custody, among other things[lviii].

Across the Caribbean, crypto asset regulation continued to develop, with notable activity in in the Cayman Islands and Trinidad and Tobago. In the Cayman Islands, the implementation of Phase 2 of the Virtual Asset (Service Providers) Act in April 2025 introduced formal licensing for trading platform operators and custodians under the supervision of the Cayman Islands Monetary Authority (CIMA), expanding supervisory tools and strengthening prudential, governance, and client‑protection requirements[lix]. Cayman also advanced its commitment to international tax transparency, publishing regulations in November 2025 to implement the OECD’s Crypto‑Asset Reporting Framework (CARF) and amendments to the Common Reporting Standard (CRS), with both frameworks scheduled for implementation in 2026 and first reporting due in 2027[lx].

In Trinidad and Tobago, the government enacted the Virtual Assets and Virtual Asset Service Providers Act, 2025[lxi], prohibiting the conduct of virtual‑asset activities without authorisation from the Trinidad and Tobago Securities and Exchange Commission (TTSEC) and defining such activities to include exchange, transfer, safekeeping, administration of virtual assets and related financial services. The Act also provides for a regulatory sandbox framework, sets out conditions for participation and oversight, and establishes offences and sanctions for breaches of its requirements. It establishes a transitional framework for existing providers and maintains a prohibition on granting full authorisations before 31 December 2026.

Taken together, these developments reflect a year in which crypto asset regulation became more structured, supervisory expectations more explicit, and regulatory approaches more clearly defined. While approaches continued to differ across jurisdictions, the direction of travel was broadly consistent with clearer licensing regimes, stronger prudential and conduct standards, and a more deliberate integration of crypto asset activities into established financial regulatory frameworks. The result is a global landscape that remains diverse but increasingly coherent, with regulators moving toward more predictable oversight and firmer expectations for market integrity, consumer protection and financial‑crime compliance.

 

Decentralized Finance

In 2025, regulators continued to deepen their understanding of decentralised finance, focusing on the practical risks posed by DeFi arrangements and the extent to which existing regulatory frameworks apply to activities. This included efforts to clarify when DeFi activities fall within regulatory perimeters, how supervisory expectations should apply and what degree of decentralisation is required for an arrangement to sit outside traditional regulatory scope.

In Bermuda, the Bermuda Monetary Authority (BMA) advanced one of the most innovative regulatory initiatives globally by launching a call for proposals to test embedded supervision within the context of DeFi. Announced in early 2025, the initiative invited voluntary participants, voluntary participants to pilot mechanisms that integrate regulatory requirements directly into blockchain‑based systems, enabling automated, real‑time compliance monitoring[lxii].

The pilot seeks to deepen supervisory understanding of DeFi models, assess the technical feasibility of embedding regulatory rules into smart contract based systems, and evaluate the operational, data management, security and scalability considerations associated with automated oversight. It also focuses on monitoring DeFi risk parameters and developing best practices for implementing embedded supervision across varying degrees of decentralisation[lxiii]. By late 2025, the BMA had selected its first cohort of participants to begin testing embedded supervision mechanisms in live DeFi environments[lxiv].

In the United Kingdom, the Financial Conduct Authority advanced its work on regulating decentralised finance through Consultation Paper CP25/40[lxv], which seeks industry feedback on how DeFi activities should be treated within the broader cryptoasset regulatory regime. Consistent with HM Treasury’s April 2025 Policy Note[lxvi], the FCA proposes that where DeFi activities are carried out by a controlling person or entity, those activities should fall within scope of the wider regulatory framework. The consultation emphasises the principle of “same risk, same regulatory outcome,” signalling the FCA’s intention to apply equivalent consumer protection, market integrity and prudential expectations to DeFi arrangements as to centralised firms, thereby reducing opportunities for regulatory arbitrage. CP25/40 also highlights the need for further engagement to determine how decentralisation, governance structures and protocol control should be assessed when determining regulatory obligations and seeks views on whether traditional rules should apply to activities such as staking, borrowing, lending and other DeFi based financial services.

While regulatory frameworks concerning DeFi remain at an early stage, the initiatives in 2025 from Bermuda and the United Kingdom are shifting the conversation beyond conceptual exploration and into operational testing and regulatory design. Their work reflects a willingness to adopt practicable, functional approaches to DeFi, embedding regulatory expectations directly into the technological architecture of DeFi arrangements and to clarify how existing rules should apply where decentralisation is partial or evolving, rather than forcing DeFi into frameworks that are not suited to its structure. As other jurisdictions continue to assess the implications of DeFi within their broader digital asset strategies, these early efforts offer useful insights while underscoring the practical challenges that remain in supervising decentralised systems.


Progress by International Standard Setters

International standard setters advanced several key workstreams in 2025 aimed at strengthening global consistency in the regulation and oversight of crypto asset markets. The Basel Committee, FATF, IOSCO and the Financial Stability Board each published updates that collectively signal a maturing global policy baseline, even as implementation remains uneven across jurisdictions.

The Basel Committee’s prudential standard on banks’ cryptoasset exposures entered into force in January 2025, establishing a globally consistent capital treatment for tokenised assets, stablecoins and unbacked cryptoassets. The framework introduces strict capital requirements for high risk cryptoassets and more favourable treatment for tokenised traditional assets that meet legal certainty and redemption risk criteria. Although certain implementation timelines extend into 2026, the 2025 milestone marked the first year of global application.

In June 2025, the FATF agreed revisions to Recommendation 16 to strengthen payment transparency across traditional and virtual asset transfers[lxvii]. The updated Standard clarifies responsibilities within the payment chain and introduces standardised information requirements for peer‑to‑peer cross‑border payments above USD/EUR 1,000. FATF also issued Best Practices on Travel Rule Supervision[lxviii], highlighting persistent implementation gaps, interoperability challenges and the need for more consistent, risk‑based supervision and cross‑border cooperation. The revised Recommendation 16 will take effect by 2030, supported by ongoing FATF guidance.

In October 2025, IOSCO published a thematic review assessing how twenty jurisdictions have implemented its 2023 Policy Recommendations for Crypto and Digital Asset Markets[lxix]. The review found that although many jurisdictions have taken steps to implement the recommendations, progress varies across governance, conflicts of interest, custody, market abuse controls and cross‑border cooperation. Material gaps persist in enforcement, continuous disclosure and the supervision of vertically integrated platforms.

In parallel, the Financial Stability Board published its first thematic review of the implementation of its 2023 global regulatory framework for crypto‑asset activities, covering thirty‑seven jurisdictions[lxx]. The review found that although many authorities have introduced or updated regulatory regimes, implementation remains at an early stage and differs significantly across jurisdictions, particularly in relation to stablecoin regulation, reporting requirements and cross‑border supervisory cooperation. The FSB highlighted that these inconsistencies create opportunities for regulatory arbitrage and complicate oversight of inherently global markets, underscoring the need for more robust data collection, clearer governance expectations and deeper coordination among international bodies.

These findings closely align with IOSCO’s thematic review published the same month, and the two bodies issued a joint note[lxxi] underscoring the need for more consistent implementation, stronger cross‑border cooperation and continued supervisory attention to emerging risks.

In November 2025, IOSCO published its Final Report on the Tokenisation of Financial Assets, drawing on a monitoring exercise by its Fintech Task Force[lxxii]. The report finds that tokenisation remains at an early stage, with activity concentrated in fixed‑income products, repos, collateral management and money‑market funds. Most initiatives continue to rely on traditional intermediaries rather than fully on‑chain models, and while some efficiency gains are emerging, many anticipated benefits, particularly secondary‑market liquidity, have yet to materialise. IOSCO notes that scaling remains constrained by limited interoperability and the absence of widely available high‑quality settlement assets.

International bodies made meaningful progress in 2025 by sharpening global standards and assessing how they are being applied in practice. Updated prudential rules, revised payments transparency requirements and the first wave of implementation reviews all contributed to a clearer and more operational global baseline. The task ahead is ensuring these expectations are implemented consistently and effectively as markets and technologies continue to evolve.


Innovation in Tokenization

Regulators across several jurisdictions advanced targeted reforms in 2025 to support the responsible growth of tokenized financial instruments.

In the Cayman Islands, the Virtual Asset (Service Providers) (Amendment) Act, 2025[lxxiii] introduced a targeted exemption for tokenized investment funds, streamlining registration obligations for entities already regulated under the Mutual Funds Act or Private Funds Act. This strategic carve-out will reduce regulatory friction for core market participants and deliver explicit legal certainty around the tokenization of traditional financial products.

Building on this, the government is considering further amendments to key Acts to address tokenization, with a focus on: (a) clear definitions for tokenized funds and their issued tokens; (b) operational requirements; (c) investor protections; and (d) the enhancement of the CIMA’s supervisory powers[lxxiv].

In Bermuda, the Bermuda Monetary Authority published a Discussion Paper on Asset Tokenisation in November 2025[lxxv], seeking stakeholder feedback on the opportunities, challenges and regulatory considerations associated with tokenising real world assets. The paper noted that Bermuda’s existing digital asset framework already provides a legal basis for tokenisation but acknowledged that the rapid evolution of the market may warrant more tailored guidance to address emerging complexities. It outlined the potential benefits of tokenisation, including fractional ownership, enhanced liquidity, improved settlement efficiency and programmable compliance, while also highlighting operational, regulatory and market integrity risks that require careful management. The BMA invited industry input to help determine whether enhancements to the current principles-based regime are needed and to inform its future regulatory approach.

In the United Kingdom, the Financial Conduct Authority published Consultation Paper CP25/28[lxxvi] to accelerate the adoption of tokenisation within authorised funds. The FCA proposed guidance to help firms operate tokenised fund registers using DLT, whether on private permissioned or public networks, and introduced a streamlined dealing mechanism for conventional and tokenised authorised funds, alongside a roadmap to address barriers to wider adoption, including future use of on‑chain cash instruments and atomic settlement. The consultation emphasised the FCA’s technology neutral, outcomes based approach, noting that tokenisation does not alter core requirements around register accuracy, portability or access for depositaries and regulators, while highlighting the potential for tokenised funds and portfolio management to engage new generations of investors.

In the United Arab Emirates, the Securities and Commodities Authority issued Resolution No. (15/Chairman) of 2025[lxxvii] introducing a technology neutral framework that clarifies how Security Tokens and Commodity Contract Tokens are treated within the UAE’s existing securities and commodities regulatory perimeter. The measure defines these instruments as rights recorded and transferred through distributed‑ledger technology and confirms that they are subject to the same regulatory, supervisory and investor‑protection requirements as traditional securities. While not a tokenisation regime, the Resolution provides important legal certainty for DLT‑based instruments by clarifying scope, excluding virtual assets and most real‑world‑asset tokens, and ensuring that tokenised securities benefit from established capital‑markets protections.

 

Conclusion

2025 marked a decisive shift in the global regulation of cryptoassets and Web3 technologies. Across stablecoins, crypto asset markets, decentralised finance, tokenisation and international standard‑setting, regulators moved from conceptual frameworks to concrete implementation. Jurisdictions refined licensing regimes, strengthened prudential and conduct standards, and clarified how emerging technologies fit within established regulatory perimeters. At the same time, global bodies sharpened expectations around transparency, governance and cross‑border cooperation, laying the groundwork for a more coherent international baseline.

While approaches remain diverse, the direction of travel is increasingly aligned: clearer rules, more predictable oversight and a stronger focus on market integrity, consumer protection and financial crime compliance. As tokenisation, DeFi and digital asset markets continue to evolve, the challenge ahead lies in ensuring consistent, effective implementation while supporting responsible innovation. The progress made in 2025 suggests that the foundations for this next phase are firmly in place.

In the year ahead, we can expect stablecoins to remain a central focus of regulatory agendas, tokenisation initiatives to expand across markets, and questions of data protection and privacy on blockchains to move further into view. As these developments unfold, it will be important not to lose sight of the need for harmonised and sensible frameworks that support the long‑term sustainability of the Web3 ecosystem. Achieving this, will require all stakeholders to remain flexible, informed and collaborative.


References
[i] As of December 2025, stablecoins have solidified their position as a cornerstone of the digital economy, with a global market capitalization exceeding $300 billion. https://coinmarketcap.com/view/stablecoin/. Stablecoins are increasingly used for B2B settlements, cross-border payments, and DeFi integration.
[ii] Guiding and Establishing National Innovation for U.S. Stablecoins Act
[iii] See Latham and Watkins summary of the Act here
[iv] For further details, see also EY July 2025 document on the Genius Act.
[v] The GENIUS Act: A Framework for U.S. Stablecoin Issuance.
[vi] Implementation of regulatory regime for stablecoin issuers.
[vii] Regulatory Regime for Stablecoin Issuers
[viii] Guideline on AML and CFT (For Licensed Stablecoin Issuers).
[ix] See Ordinance Guidance, August 2025.
[x] Ibid.
[xi] See Comprehensive Reform in South Korea of the Digital Assets Regulation and South Korea’s Digital Asset Act.
[xii] See article here
[xiii] See articles here, here and here.
[xiv] a won‑denominated stablecoin
[xv] KRW1 was first issued on the Avalanche blockchain network
[xvi] Stablecoin Regulatory Reform
[xvii] See article and FSA website
[xviii] funds transfer service provider.
[xix] See here
[xx] Regulatory regime for cryptoassets (regulated activities) – Draft SI and Policy Note
[xxi] Consultation Paper CP25/14 (May 2025) Stablecoin Issuance and Cryptoasset Custody
[xxii] Bank of England launches consultation on regulating systemic stablecoins.
[xxiii] See here
[xxiv] See Division 45 Stablecoin Act
[xxv] See articles here and here.
[xxvi] SIO Stablecoin Issuance and Offering. See also article.
[xxvii] FSRA of ADGM Publishes Proposed Regulatory Framework for Regulated Activities involving Fiat-Referenced Tokens
[xxviii] Virtual Asset Issuance Rulebook. See also helpful articles here and here.
[xxix] See useful discussion here
[xxx] See Harneys article on this.
[xxxi] ESMA Statement on MiCA Transitional period- 17 December 2024
[xxxii] See Discussion Paper DP25/1 Regulating Cryptoasset Activities, CP25/14 – Stablecoin Issuance and Crypto Custody and CP25/15 – Prudential Framework for Crypto Asset Firms published in May 2025. See also CP25/25: Application of FCA Handbook for Regulated Cryptoasset Activities (September 2025), along with three recent December 2025 consultations.
[xxxiii] CP25/40 Regulating Cryptoasset Activities (December 2025). CP25/40 sets out proposed rules for cryptoasset trading platforms, intermediaries, cryptoasset lending and borrowing, staking and decentralised finance.
[xxxiv] CP25/41 Regulating Cryptoassets: Admissions & Disclosures and Market Abuse Regime for Cryptoassets (Dec 2025). CP25/41 proposes an admissions and disclosures regime requiring cryptoasset trading platforms to establish risk-based admission criteria, conduct due diligence before admitting qualifying cryptoassets to trading. See Katten article.
[xxxv] CP25/42 A Prudential Regime for Cryptoasset firms (December 2025). CP 25/42 builds on the proposals of CP25/15 and focuses on the remaining cryptoasset activities, namely operating a qualifying cryptoasset trading platform, staking, arranging deals, dealing as agent and dealing as principal in qualifying cryptoassets (which includes firms that offer lending and borrowing products):see Skadden article.
[xxxvi] The Cryptoasset Regulations establish seven new regulated activities under FSMA: issuing a qualifying stablecoin; safeguarding qualifying cryptoassets; operating a qualifying cryptoasset trading platform (CATP); dealing in qualifying cryptoassets as principal; dealing in qualifying cryptoassets as agent; arranging deals in qualifying cryptoassets; and arranging qualifying cryptoasset staking.
[xxxvii] See legislation.gov.uk. A draft Statutory Instrument was published by HM Treasury in April 2025. The updated Statutory Instrument (published on 15 December 2025) now brings additional cryptoasset activities within the FCA’s regulatory remit and expands the regulatory perimeter initially proposed earlier in April 2025.
[xxxviii] https://consult.treasury.gov.au/c2025-701519
[xxxix] Digital assets: Financial products and services
[xl] See SFC Press Release here.
[xli] See Virtual Asset Service Provider - Vanuatu Financial Services Commission (VFSC)
[xlii] https://www.fsa.go.jp/en/news/2025/20250410_2/02.pdf
[xliii] See FSA September report
[xliv] See FSA December report
[xlv] https://new.kenyalaw.org/akn/ke/act/2025/20/eng@2025-11-04
[xlvi] See the Securities and Exchange Commission Ghana, Press Release.
[xlvii] https://www.dfsa.ae/news/dfsa-issues-updated-rules-regulation-crypto-tokens-difc
[xlviii] https://rulebooks.vara.ae/rulebook/virtual-asset-issuance-rulebook
[xlix] See Linklaters helpful brief.
[l] See here.
[li] See here.
[lii] https://www.bcb.gov.br/detalhenoticia/20918/nota
[liii] https://www.felsberg.com.br/en/brazil-virtual-asset-framework-519-520-521/
[liv] See General Resolution 994/2024
[lv] See General Resolution 1058/2025
[lvi] See helpful article here.
[lvii] https://panamabankingnews.com/wp-content/uploads/2025/03/Anteproyecto-de-Ley.pdf
[lviii] See article here
[lix] See CIMA circular
[lx] https://gov.ky/w/regulations-now-published-on-carf-and-crs
[lxi] See here.
[lxii] See BMA call for proposal.
[lxiii] See Harneys article
[lxiv] See Press Release.
[lxv] https://www.fca.org.uk/publication/consultation/cp25-40.pdf
[lxvi] See 2.10 of the Note.
[lxvii] Changes to FATF Standards
[lxviii] Access here
[lxix] IOSCO: Thematic Review of Crypto‑Asset Recommendations (October 2025)
[lxx] FSB: Thematic Review of the Global Regulatory Framework for Crypto‑Asset Activities (October 2025)
[lxxi] See here
[lxxii] IOSCO: Tokenisation of Financial Assets (2025)
[lxxiii] See Act here
[lxxiv] See discussion here.
[lxxv] BMA Asset Tokenisation November 2025
[lxxvi] CP25/28 Progressing Fund Tokenisation
[lxxvii] SCA Regulations | Regulations | Securities and Commodities.
Kavita Maharaj-Alexander
Kavita Maharaj-Alexander

“It is our choices, that show what we truly are, far more than our abilities.” – J.K. Rowling

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