The global regulatory landscape for digital assets has seen significant evolution in September 2025, driven by U.S. agencies coordinated efforts to clarify oversight and international proposals enhancing stablecoin and tokenized asset regimes. These advancements underscore a push toward harmonized standards that balance innovation with investor protection, influencing cross-border compliance for market participants worldwide.
United States’ Coordinated Oversight: SEC and CFTC Initiatives
The U.S. Securities and Exchange Commission (SEC) unveiled its Spring 2025 Regulatory Agenda on September 4, establishing a roadmap for crypto asset regulation under key statutes like the Investment Advisers Act and Investment Company Act, with proposed rules covering offerings, sales, custody, and alternative trading systems. This agenda introduces potential exemptions and safe harbors to promote digital asset innovation while reinforcing investor safeguards against market risks. The phased approach addresses longstanding ambiguities, enabling issuers to structure compliant products without exhaustive prior approvals.
On September 17, the SEC approved generic listing standards for commodity-based trust shares, streamlining the process for exchanges such as Nasdaq and NYSE Arca to list spot digital asset products, including multi-asset vehicles like the Grayscale Digital Large Cap Fund. This development reduces filing burdens and accelerates market access for tokenized assets, aligning with broader efforts to integrate crypto into traditional securities infrastructure. Implementation varies by exchange, with some jurisdictions requiring enhanced disclosures to mitigate volatility.
Complementing the SEC’s agenda, the SEC and Commodity Futures Trading Commission (CFTC) released a joint statement on September 5, pledging synchronized regulation through unified definitions, reporting protocols, and margin requirements to eliminate overlaps in digital asset supervision. The statement explores DeFi safe harbors and extended trading hours, signaling regulatory support for decentralized protocols while imposing safeguards against systemic risks. A September 2 clarification further permits registered exchanges to offer leveraged spot crypto trading under existing investor protections, part of initiatives like the SEC’s Project Crypto and CFTC’s Crypto Sprint.
Acting CFTC Chair Caroline Pham announced a tokenized collateral initiative on September 23, soliciting feedback until October 20 on leveraging stablecoins for derivatives margins to improve efficiency and liquidity. This builds on the joint statement by addressing interoperability challenges, with proposals emphasizing reserve quality and redemption mechanisms. These U.S. measures interconnect with ancillary frameworks, such as the U.S. Treasury’s September 18 Advance Notice of Proposed Rulemaking under the GENIUS Act, which seeks input until October 20 on stablecoin reserves and cross-system compatibility, and the September 22 U.S.-UK Transatlantic Taskforce for collaborative digital asset standards.
International Stablecoin and Tokenized Asset Enhancements
Hong Kong’s Securities and Futures Commission proposed updates on September 9 to its fiat-referenced tokens (FRT) framework, expanding 2024 issuance rules with rigorous licensing for stablecoin activities, including fiat reserve backing and audit mandates to ensure stability. This positions Hong Kong as an Asian innovation leader, diverging from stricter global bans on yield generation while imposing AML/KYC protocols. Regional peers like the UAE’s Abu Dhabi Global Market Financial Services Regulatory Authority initiated a parallel consultation on September 9, closing October 7, to extend FRT regulations to custody, trading, and high-quality liquid asset requirements for tokenized instruments.
Australia’s Treasury published an exposure draft on September 24, reclassifying digital asset platforms and tokenized custody as financial products under the Corporations Act, with public comments due October 24 to incorporate licensing and disclosure obligations. This aims to harmonize oversight with traditional finance, addressing risks in custody and exchange operations. Singapore’s Monetary Authority issued guidelines on September 25 for ethical digital advertising and financial content, curbing crypto promotion misinformation through verification and risk disclosure duties on platforms.
In Europe, the European Central Bank’s September 26 advancement of digital euro pilots highlights stablecoin vulnerabilities and Markets in Crypto-Assets Regulation (MiCA) enforcement, promoting uniform application across member states to foster interoperability. A September 15 joint proposal from French, Austrian, and Italian authorities seeks MiCA supervisory alignment, resolving inconsistencies in stablecoin authorizations and cross-border trading. These efforts, akin to MiCA’s asset classifications for e-money and asset-referenced tokens, impose transitional periods: extending to July 2026 in some states, while integrating with regimes like the Digital Operational Resilience Act (DORA) for ICT risk management and the Transfer of Funds Regulation (TFR) for transaction traceability.
Implications for India’s VDA Ecosystem
The U.S. harmonization and international proposals from September 2025 carry profound implications for India’s virtual digital assets (VDA) market, where oversight relies on amendments to legacy frameworks like the Prevention of Money Laundering Act (PMLA), 2002, including FIU-IND registration for service providers and a 30% tax on gains with 1% TDS on transactions. Unlike the SEC-CFTC’s unified definitions or MiCA’s pan-EU standards, India’s approach remains decentralized, with SEBI and RBI diverging on securities classification and CBDC priorities, complicating cross-border VDA activities amid high domestic adoption.
From a compliance standpoint, U.S. safe harbors for DeFi and tokenized collateral could guide Indian AIFs in structuring compliant tokenized funds under SEBI regulations, while stablecoin reserve mandates under the GENIUS Act and FRT frameworks inform RBI’s digital rupee pilots, potentially reducing extraterritorial AML risks for Indian users on offshore platforms. Indian entities exposed to the EU or UAE must navigate MiCA’s prohibitions on stablecoin interest and DORA’s resilience requirements, alongside Australia’s financial product reclassification, necessitating robust due diligence to align with FATF Travel Rule equivalents already adopted in India.
These convergences highlight the need for Indian VDA businesses to monitor US-UK taskforce outcomes and Asian consultations for benchmarking against domestic gaps, such as absent standalone VDA legislation. Proactive adaptation can mitigate fragmentation, enabling seamless integration of global innovations like yield-bearing tokens permitted in Bahrain and Hong Kong but restricted under MiCA into Indian venture capital and blockchain strategies.
Disclaimer: The information published in the above newsletter is collected from various sources in electronic medium and analyzed by the firm. The reader is advised to consult the attorney qualified in their jurisdiction, before acting on any information contained in this newsletter. India Juris excepts no liability what so ever in this regard.
