Global Crypto Regulation Diverges: U.S. Bill Stalls While Thailand and Netherlands Chart Different Paths

U.S. Crypto Framework Postponed Amid Industry Opposition

Comprehensive cryptocurrency legislation in the United States Senate has been postponed indefinitely after facing significant resistance from major industry players, marking a setback for efforts to establish clear regulatory guidelines for digital assets ^[1].

The Senate Banking Committee halted work on its anticipated market structure bill following Coinbase's public withdrawal of support. The decision by CEO Brian Armstrong came just before a scheduled markup hearing where lawmakers would have debated amendments and potentially moved the legislation toward a floor vote ^[1].

The delay could extend into late February or March as lawmakers attempt to rebuild bipartisan consensus in a divided Senate, according to Bloomberg reporting ^[1]. The committee has shifted immediate attention to other priorities, including housing affordability initiatives connected to President Donald Trump's agenda ^[1].

Industry Concerns Center on Stablecoin and DeFi Provisions

Coinbase's withdrawal reflects deeper rifts between cryptocurrency companies and bill drafters, primarily concerning stablecoin rewards. Industry leaders have raised concerns that current provisions could weaken the Commodity Futures Trading Commission's authority, restrict decentralized finance operations, and limit stablecoin rewards—features they consider essential for continued innovation ^[1].

Meanwhile, traditional banking institutions have lobbied for tighter restrictions on yield-bearing crypto products, warning such features could divert deposits from banks and destabilize lending markets. This lobbying appears to have influenced the bill's language and intensified opposition from the crypto sector ^[1].

Patrick Witt, executive director of the White House council on digital assets, has encouraged continued negotiation, calling regulatory clarity "a question of when, not if." However, he cautioned that without industry cooperation, future versions of the legislation could prove less favorable to crypto firms ^[1].

Thailand Advances Crypto ETF Framework for 2026

In contrast to the U.S. stalemate, Thailand is moving forward with regulations to establish itself as a leading Asian crypto hub. The country's Securities and Exchange Commission is finalizing comprehensive guidelines for bitcoin and cryptocurrency exchange-traded funds, futures trading, and tokenized investment products, with implementation planned for early 2026 ^[2].

SEC Deputy Secretary-General Jomkwan Kongsakul explained that the new framework aims to expand digital asset access while addressing security and custody concerns that have deterred institutional investors. "A key advantage of crypto ETFs is ease of access," Kongsakul stated. "They eliminate concerns over hacking and wallet security, which has been a major barrier for many investors" ^[2].

Thailand's SEC board has approved crypto ETFs in principle, with regulators finalizing operational rules covering custody, liquidity, and cooperation between asset managers and licensed exchanges ^[2]. After approving its first spot Bitcoin ETF in June 2024 for institutional investors, Thailand signaled plans by October 2025 to expand offerings to include ether and potentially diversified crypto basket products ^[2].

Under the proposed framework, investors would be permitted to allocate 4-5% of diversified portfolios to digital assets ^[2]. The SEC also plans to launch crypto futures trading on the Thailand Futures Exchange and introduce market-making mechanisms in 2026 ^[2].

Thailand eliminated capital gains tax on crypto trading from January 1, 2025, through December 31, 2029, further enhancing its appeal to digital asset investors ^[2].

Netherlands to Tax Unrealized Bitcoin Gains

The Netherlands is taking a distinctly different approach, preparing to tax unrealized gains on Bitcoin, stocks, bonds, and other assets. Following a parliamentary decision, the country will implement a reform called "Wet werkelijk rendement Box 3" starting in 2028 ^[3].

Under this system, investors must pay annual taxes based on the value change of their assets, even without selling. The tax calculation compares asset values at year-end versus year-beginning, including ongoing returns like interest or dividends ^[3].

Critics warn the system could create liquidity problems for investors required to pay taxes on paper gains without actual cash inflows. The model could impose substantial financial burdens, particularly for volatile assets like Bitcoin ^[3].

By comparison, Germany currently does not tax unrealized gains. For cryptocurrencies, taxes apply only upon sale, with profits becoming tax-free after a holding period exceeding one year. Germany is not currently pursuing taxation of paper gains similar to the Dutch plan ^[3].