Crypto Exits Surge in 2025: Momentum Builds for an Even Bigger 2026

After more than a decade of speculation about when digital‑asset companies would finally break into the public markets at scale, 2025 delivered the long‑awaited breakthrough. Crypto‑related businesses didn’t merely test market appetite—they validated it. Investor demand strengthened, regulatory clarity improved markedly, and institutional capital aligned with the sector’s most mature operators (none of which even existed 15 years ago). As 2026 begins, the indicators point toward an even more active year for exits, capital formation, and business expansion.

In many ways, this moment reflects themes explored in earlier Foley analyses, including the stability‑focused roadmap in Crypto Asset Strategy for Corporate Legal Leaders. Those frameworks predicted that once regulatory guardrails were established and institutional‑grade compliance took root, a pathway toward IPOs and strategic M&A would emerge. In 2025, that prediction materialized.

A Breakthrough Year for Crypto IPOs

For years, crypto founders and investors envisioned a maturation arc similar to other technology sectors: from experimentation to scale to public‑company viability. But until recently, the IPO window remained nearly shut. That changed decisively in 2025.

PitchBook reported an unprecedented surge in crypto‑related IPOs, a clear sign that the market now views digital‑asset companies as structurally ready—not merely cyclically appealing.¹ The watershed moment came with Circle’s debut, the first major IPO by a stablecoin issuer. Its shares surged 167% on opening day, raising nearly $1.1 billion and signaling institutional appetite for governance‑strong, disclosure‑driven digital‑asset issuers.²      

Circle didn’t stand alone. Bullish, eToro, and Gemini also entered the public markets, while Grayscale and Kraken prepared filings. These businesses benefited from maturing compliance programs, improved market infrastructure, and enhanced regulatory predictability—hallmarks of the kind of issues we anticipated in our earlier work.

As outlined in Crypto Asset Strategy for Corporate Legal Leaders, sustainable crypto IPOs depend on disciplined governance, sound risk management, and a public‑company‑aligned compliance posture. Beginning with Circle (which models all these features), a critical mass of issuers achieved that threshold in 2025.

Venture Capital Re‑Engages—More Selectively

Even as deal count fell, venture capital investment in digital‑asset companies rose to $19.7 billion in 2025, indicating that investors are concentrating capital in later‑stage companies preparing for liquidity events.¹ These companies exhibited meaningful revenue, strong compliance fundamentals, and the infrastructure necessary for institutional participation.

This pattern mirrors the enterprise‑adoption trend outlined in our 2026 legal‑leadership framework, where corporate legal teams are no longer observers but architects of digital‑asset strategy.³ As CLOs and GCs formalize governance frameworks for stablecoin use, cross‑border payments, and liquidity management, investor confidence grows—and late‑stage capital follows.

Regulatory Clarity: The Catalyst Markets Needed

Executive Order on Digital Financial Technology

The year began with a Presidential Executive Order directing federal agencies to coordinate policy, enhance regulatory consistency, and promote responsible innovation across digital financial infrastructure.⁴ This signaled a shift from reactive enforcement to proactive oversight. The federal financial regulatory agencies all followed suit.

The GENIUS Act: A Turning Point for Stablecoins

Passed in mid‑2025, the GENIUS Act created the first federal framework for “permitted stablecoins,” requiring 100% liquid‑asset reserve backing, standardized monthly disclosures, and federal supervision.⁵ For the first time, enterprises could safely buy, hold, and use stablecoins with legal certainty—a key theme underscored in our corporate‑legal strategy guidance.³

The CLARITY Act and Market‑Structure Reform

Further momentum came from House passage of the CLARITY Act, which aims to establish a unified market‑structure framework for digital assets and draw clearer boundaries between SEC and CFTC jurisdiction.⁶ Senate committees are now refining provisions relating to commodity classification, stablecoin incentives, “DeFi” technology, and secondary‑market oversight.

Regulatory predictability—long the missing ingredient—is becoming reality at last.

Stablecoins Become Enterprise Infrastructure

Enterprise adoption of stablecoins might be the most important development in digital assets this year. Stablecoins increasingly function as the financial plumbing for global businesses—powering cross‑border payments, real‑time settlement, and T+0 clearing.

Industry analysts project stablecoin circulation to exceed $1 trillion by 2026.⁷ This shift is not driven by retail speculation; it reflects corporate‑treasury modernization.

Legal departments now play a central role in assessing:

• Issuer compliance under the GENIUS Act
• IRS tax treatment (stablecoins treated as “property,” not “cash”)⁸
• KYC/AML and sanctions‑screening obligations
• Custody, wallet governance, and service‑level agreements
• Multi‑jurisdictional regulatory obligations

As noted in our digital‑asset strategy guidance, enterprise adoption is now constrained more by legal strategy than by technical readiness.³

Bitcoin Matures Into a Strategic Asset

The SEC’s approval of Bitcoin ETFs in 2024 and continued institutional inflows in 2025 solidified bitcoin’s role as a macro‑oriented asset increasingly treated as a form of digital gold.⁹ Liquidity deepened, volatility moderated relative to earlier cycles, and custody infrastructure matured.

Companies exploring balance‑sheet allocations now apply risk‑management frameworks similar to those used for other speculative assets, adjusting for market‑structure differences. As our legal‑leadership memo observed, treasury teams can adapt equity‑volatility frameworks to responsibly manage bitcoin exposure—provided controls, accounting treatment, and custody safeguards are in place.³

Legal Leaders Step Into the Driver’s Seat

One of the defining shifts of 2025–2026 is the evolving role of legal leadership. CLOs and GCs are now initiating digital‑asset strategy rather than responding to it. They are:

• Designing digital‑asset policies
• Leading cross‑functional working groups
• Briefing boards on fiduciary considerations
• Coordinating stablecoin payment pilots
• Managing cross‑border regulatory compliance

Legal must lead, not follow.³

2026: The Strongest Exit Environment Yet?

Several forces—regulatory progress, enterprise adoption, institutional demand, and investor discipline—are converging to produce what may be the strongest exit environment in the history of digital assets:

• A deep backlog of IPO‑ready companies
• Clearer federal frameworks for market structure
• Strategic acquirers seeking differentiation through M&A
• Growing demand for compliant, enterprise‑grade digital‑asset infrastructure
• Higher board‑level literacy in digital‑asset strategy

If 2025 proved that crypto exits are possible, then 2026 may prove that they are durable. The sector has moved from experimentation to infrastructure. For founders, investors, and enterprise leaders, this is a moment to lead with clarity, confidence, and a commitment to compliance.

Notes

1. PitchBook Data, Crypto VC Trends Report (2025).
2. CNBC, Stablecoin Issuer Circle Soars in NYSE Debut (June 5, 2025).
3. Louis Lehot & Patrick Daugherty, Crypto Asset Strategy for Corporate Legal Leaders (Foley & Lardner LLP 2026).
4. White House, Executive Order on Digital Financial Technology (Jan. 2025).
5. GENIUS Act, S. 1582, 119th Cong. (2025) (signed into law July 18, 2025).
6. CLARITY Act, H.R. 3633, 119th Cong. (2025).
7. AMB Crypto, $1 Trillion Stablecoin Market by 2026? Here’s What Needs to Happen (Sept. 11, 2025).
8. IRS, Digital Asset Tax Guidance (2025).
9. SEC, Approval Order for Bitcoin Exchange‑Traded Products (2024).