Crypto Regulations 2025: From Legal Theory to Practical Infrastructure

By 2025, regulations around crypto will no longer be “legal battles in court” but will begin to focus on real infrastructure.

Debates about whether and how to regulate crypto are becoming less philosophical and more operational. Over the past year, regulators have concentrated on answering questions that once seemed “boring” but are crucial for market expansion: who is allowed to issue “digital dollars,” how to reserve assets, how investors can access quickly approved ETF products, and what constitutes proper custody when assets are private keys instead of paper certificates.

For this reason, 2025 becomes a pivotal year, even if you don’t read a single law. Most new regulations will not focus on punishing “bad actors,” but on questions like: can banks connect to stablecoins without losing their licenses, can exchanges serve customers without exploiting legal loopholes, and can new products launch on predictable schedules instead of piecemeal.

At year’s end, it’s clear that no major country shares a unified stance on regulation, but all are working toward the same goal: transforming crypto from a “legal nightmare” into a surveillable, operable, and predictable financial infrastructure.

Coinphoton has compiled a reference map of key changes in 2025, organized chronologically and by region.

United States

The US regulates crypto through multiple agencies, each controlling a specific part.

• Congress writes laws, but daily rules and enforcement fall under the SEC (securities, investor protection), CFTC (derivatives, commodities), IRS (taxes), and banking agencies like FDIC (bank insurance).
• This model leads to a token being subject to multiple sets of rules simultaneously: trading, marketing, custody, and profit handling all fall under different authorities.

In 2025, segments of the market directly related to traditional finance—payment stablecoins, exchange-traded products (ETP), and regulated custody—are clearer.

The major ongoing debate about authority between the SEC and CFTC remains unresolved.

Key points in 2025 in the US

1. Stablecoins: Turning “promise of $1” into mandatory redemption and reserve rules.
2. Products: Standardizing ETF listings, reducing individual approval processes.
3. Tax: Removing staking barriers in trust-style vehicles.
4. Custody: Clarifying how broker-dealers custody crypto-asset securities.

Major milestones:

• CLARITY Act (January 2025): Not yet law, but an effort to clearly delineate SEC and CFTC roles. DeFi remains unregulated, risking investor protection if negotiations fail.
• GENIUS Act (July 2025): Federal framework for payment stablecoins, clarifying issuance, reserves, and oversight.
• SEC approves listing standards for commodity ETPs (September 2025): Creating a standard listing pathway, reducing individual approvals.
• IRS safe harbor for staking in trusts (November 2025): Allowing staking without breaking tax classification.
• FDIC proposes stablecoin issuance procedures for banks (December 2025): Turning laws into operational procedures.
• SEC guidance on custody of crypto-asset securities (December 2025): Clarifying how to demonstrate control and protect customers.

European Union (MiCA)

The EU is simpler than the US: building a unified legal framework and promoting consistent adoption.

• MiCA: The main legal framework, regulating licensing and conduct for crypto service providers and stablecoin issuers.
• In 2025, MiCA begins to operate as a “gatekeeper” rather than just a document.

Key points in 2025 in the EU:

1. Transitioning MiCA from paper to actual licensing.
2. Clarifying liquidity reserves and redemption rights for stablecoins.
3. Reducing reliance on “grandfathering” and promoting passport-ready mechanisms.
4. Developing more unified AML supervision.

Major milestones:

• Multi-issuance stablecoin regulation (January 2025)
• EBA liquidity reserve guidance (October 2025)
• AMLA begins operation (mid-2025)
• ESMA completes MiCA transition phase (December 2025)

United Kingdom

The UK combines elements of the US and EU: principles-based but also drawing clear boundaries when it comes to infrastructure.

• Systemic stablecoins are regulated as payment infrastructure (FSMA 2023).
• In 2025, the UK focuses on planning laws to make compliance predictable for businesses.

Major milestones:

• Bank of England consults on GBP systemic stablecoin (November 2025)
• FCA publishes regulatory timetable (December 2025)
• Updates to benchmark rules (December 2025)

Hong Kong

Hong Kong emphasizes strict licensing, clear rules, and deep access to capital markets.

• Stablecoins are brought into licensing mechanisms, with exchanges permitted to connect to international liquidity within a regulated framework.

Major milestones:

• Stablecoin legislation passed (May 2025)
• Stablecoin Ordinance comes into effect (August 2025)
• SFC guidance for VATPs (November 2025)

Singapore

Singapore focuses on regulating financial activities: strict licensing, clear behavioral expectations, and tokenization within monetary frameworks.

• In 2025, tightening the “Singapore-based, overseas-only” model and moving toward legislation for stablecoins linked to institutional payments.

Major milestones:

• DTSP effective (June 2025)
• MAS publishes draft stablecoin legislation (November 2025)

Conclusion

• US: Building a clear framework for payment stablecoins, ETFs, staking, and custody, but token classification remains an open question.
• EU: Turning MiCA into an operational system, clarifying liquidity and redemption rights for stablecoins.
• UK: Viewing systemic stablecoins as payment infrastructure, with transparent regulatory roadmaps.
• Hong Kong & Singapore: Establishing clear “perimeters”: licensing stablecoins and exchanges, managing liquidity and international clients.

Overall, 2025 won’t simplify crypto, but it will make regulations more understandable where large-scale market operations are decided.