Crypto market structure bill could be delayed to 2027, with implementation in 2029, TD Cowen says

U.S. legislation aimed at setting clear rules for crypto markets may take longer to pass, with approval potentially pushed to 2027 and implementation stretching into 2029, according to TD Cowen.

While there is a path for a crypto market structure bill to pass this year, political dynamics in Congress make delays more likely, TD Cowen’s Washington Research Group, led by managing director Jaret Seiberg, said in a Monday note. Democrats, the firm said, may have little incentive to move quickly, particularly if they believe they could regain control of the House in the 2026 midterm elections.

“Election outcomes are always uncertain, which is why Democrats may cut a deal,” Seiberg wrote. “That could happen quickly, as staff have been working on the technical language for months.”

Still, Seiberg said, “Time favors enactment as the problems disappear if the bill passes in 2027 and takes effect in 2029. Crypto would need to accept that the presidential election could impact the final rules, and Democrats would need to accept that the conflict provision will not apply to Trump.”

A major sticking point is expected to be conflict-of-interest language. Democrats are likely to push for provisions that would bar senior government officials and their families — including President Donald Trump — from owning or operating crypto businesses, Seiberg said. He added that such language would be a “nonstarter” for Trump unless its effective date were pushed several years into the future.

Bloomberg estimated last July that Trump has generated roughly $620 million from crypto-related ventures tied to his family, including World Liberty Financial, a DeFi and stablecoin project that lists Trump and his three sons as co-founders. The family also holds a stake in bitcoin mining firm American Bitcoin, while lawmakers have raised concerns about the TRUMP and MELANIA memecoins launched shortly before Trump took office.

“One potential way to overcome Trump’s objections is to make the conflict of interest provision effective three years after enactment,” Seiberg said. “This pushes it past the next inauguration, which means it would never apply to Trump. We do not believe Democrats would accept this deal unless it also pushed the rest of the bill out three years.”

Crypto market structure bill 

The crypto market structure legislation — widely viewed as the next major regulatory milestone after the passage of the GENIUS Act on stablecoins — would establish a clear framework for how digital assets are regulated in the U.S., including agency oversight and asset classification. The House passed its version of a market structure bill last year, but momentum has slowed in the Senate, where committees are expected to take up the issue later this year.

Overcoming a Senate filibuster requires 60 votes, meaning Republicans would need backing from at least seven Democrats even if all Republicans supported the bill, Seiberg said. In practice, he added, it could take eight or nine Democratic votes, as some Republicans are expected to oppose the legislation.

That dynamic gives Democrats leverage to delay passage until after the midterms. A later enactment date would also likely push implementation beyond the next presidential inauguration, allowing Democratic regulators to shape the final rules if a Democrat wins the White House. Seiberg noted that complex legislation often takes years to take effect, pointing to the GENIUS Act’s three-year implementation timeline.

This creates friction with the crypto industry, which would prefer the law to take effect under Trump and is agnostic to conflict-of-interest provisions. That mismatch, Seiberg said, is a central reason why the politics around the bill remain difficult.

Policy experts recently told The Block they see a 50%–60% chance that a crypto market structure bill becomes law in 2026.

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