TL;DR
The December 2025 SEC innovation exemption is still a concept, not a proposal. However, leadership aims to begin rulemaking by end-2025 or early-2026, after sec shutdown delays 2025. Expect details on guardrails and digital asset periodic reporting.
December 2025 SEC innovation exemption: where it stands
The December 2025 SEC innovation exemption is not yet formally proposed. According to a legal commentary, “Although the SEC has yet to propose the innovation exemption formally,” the Commission still views it as a priority. The same report notes a target to “begin rulemaking by the end of 2025 or early 2026,” after delays tied to the recent shutdown.
Even so, the direction appears clear. The concept continues to take shape inside the broader sec project crypto discussion, which frames a principles-based approach. Notably, observers still highlight sec shutdown delays 2025 as a factor in timing.
Atkins’ Dec. 2 remarks: authority and intent
On Dec. 2, Chair Paul Atkins reiterated confidence in existing authority. As reported, “We have enough authority to drive forward… I’m looking forward to having an innovation exemption.” Those paul atkins sec comments signal intent to use current tools rather than wait for new legislation.
Moreover, the remarks suggest rulemaking could advance once staff completes scoping. Consequently, market participants are watching for a notice or proposal that references the innovation exemption directly. Additional paul atkins sec comments may preview the shape of the guardrails.
Timeline: key dates and expected milestones
Updates on Dec. 1–2 set practical expectations. A Dec. 1 analysis said the SEC aims to begin rulemaking by late 2025 or early 2026. The next day, Atkins reinforced that intent with his on-the-record remarks. Together, these touchpoints help outline the innovation exemption rulemaking timeline, even without a published proposal.
From here, the innovation exemption rulemaking timeline likely includes a proposal, a public comment period, and potential adjustments before adoption. However, the schedule has already slipped due to sec shutdown delays 2025. As the December 2025 SEC innovation exemption moves from concept to proposal, timing will depend on bandwidth and comment volume.
December 2025 SEC innovation exemption: potential scope and safeguards
Under sec project crypto, the envisioned framework would allow limited, real-world testing of novel business models. The approach is principles-based and focused on defined guardrails. According to a summary, “Project Crypto envisions an ‘innovation exemption’, a framework that would allow companies to test novel business models under principles-based safeguards.”
Crucially, guardrails may include digital asset periodic reporting to the SEC. As one account puts it, “Participants may be required to report periodically to the SEC.” Such digital asset periodic reporting could surface key risk metrics and give supervisors visibility into pilot activities. Consequently, firms would gain measured flexibility while maintaining accountability.
Authority and process: how the SEC could create the exemption
Atkins has indicated the Commission has sufficient authority to craft exemptions that foster innovation. Therefore, it is plausible that the agency will proceed via traditional rulemaking. The rule text would define eligibility, scope, safeguards, and reporting.
In practice, the process would draw from staff expertise and public feedback. It would also reflect insights from sec project crypto and related risk analyses. Furthermore, if a proposal emerges, it will likely specify how digital asset periodic reporting works in a pilot context.
What’s Next: signals to watch on the innovation exemption
Several near-term signals will indicate momentum:
- A formal proposal or rulemaking notice referencing the December 2025 SEC innovation exemption.
- Concrete guardrails, including whether digital asset periodic reporting is mandated and at what cadence.
- Any revised schedule that addresses lingering sec shutdown delays 2025.
- Additional paul atkins sec comments that clarify scope, authority, or timing.
- References to sec project crypto in the preamble or economic analysis.
In short, scrutiny is shifting from whether to how. For the December 2025 SEC innovation exemption, the critical variables are timing, guardrails, and transparency. Stakeholders should prepare to engage quickly once a draft rule appears.

