Haciyev Reşit 
In the U.S., while regulations aiming to oversee cryptocurrency markets are expected to take effect in 2026, analysts at investment bank TD Cowen have noted that the midterm elections could delay this process. According to the analysts, the law intended to provide clear rules for the crypto market may not pass until 2027, and the implementation of some provisions could be postponed until 2029.
CLARITY Act: A Critical Step in Crypto Regulation
TD Cowen stated that the approval of the CLARITY Act—considered the most important crypto legislation in the U.S.—could be delayed until 2027. The year 2025 marked significant regulatory progress in the U.S., with the GENIUS Act being passed for stablecoins and notable developments achieved in the CLARITY Act as well.
The CLARITY Act is considered the next major regulatory milestone following the GENIUS Act, aiming to set clear rules for the crypto market. However, Jaret Seiberg, Managing Director at TD Cowen, noted that while some progress could occur this year, full approval is more likely after 2027. According to The Block, although passing this year is possible, political uncertainties make a delay until 2027 more probable.
Main Obstacle: Conflict-of-Interest Clause
Seiberg highlighted that the biggest obstacle for the CLARITY Act is the clause aimed at preventing conflicts of interest. The Democratic Party insists on restricting access to crypto businesses for top U.S. officials and their families. In particular, President Donald Trump and his family’s involvement in crypto projects has intensified political debates around the law. TD Cowen suggests, as a possible compromise, delaying the enforcement of the conflict-of-interest provision by about three years. This approach could reduce political pressure on the current administration while speeding up the law’s passage.
CLARITY Act Hearing and Content
A hearing for the CLARITY Act is scheduled for January 15. The law is designed to provide a clear framework for regulating digital assets in the U.S. This framework will define the authority sharing between the SEC and CFTC and classify different asset types. It also includes provisions exempting certain cryptocurrencies that meet specific conditions from the registration requirements under the 1933 Securities Act.
Investors and companies in the crypto market need to prepare for the possibility of delays in U.S. regulations. TD Cowen notes that extending this process to 2027 or 2029 could create uncertainty and volatility in the market. This may affect investor risk appetite and require companies to reassess their strategic planning. Analysts emphasize that investors should closely monitor the regulatory timeline and adjust their portfolios and trading strategies accordingly.
“Due to the risk that Democrats could lose control of the House in the 2026 midterm elections, they are unlikely to rush the passage of the CLARITY Act. This could delay both the enactment and implementation of the law.”
Evaluation
Potential delays in U.S. crypto regulations represent a significant uncertainty for both investors and companies. A prolonged implementation of the CLARITY Act could impact the market in both the short and medium term. TD Cowen’s warnings highlight the importance of planning strategies in line with the regulatory timeline.
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