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Check out some of our new resources
Use the new DLx Law Policy Tracker as a reference to stay engaged with some of the new, forthcoming, or potential policy changes we are tracking, both in the U.S. and abroad.
Mar 11, 2025
6th Circuit invalidates FCC’s recently reinstated net neutrality rules
United States (Regulatory)
Pointing to the U.S. Supreme Court’s Loper Bright decision from June 2024 overturning longstanding precedent on deferral to federal agencies in their promulgation of rules and regulations, on January 2, 2025, a three-judge panel on the 6th Circuit Court of Appeals ruled that the Federal Communications Commission (FCC) lacked the statutory authority to regulate broadband internet service providers (ISPs), invalidating the FCC’s net neutrality rule that was partially reinstated under President Joe Biden’s administration.
Without the FCC’s enforcement of net neutrality, the ability of private carriers to slow, block, or otherwise restrict access to internet content significantly undermines principles of openness and permissionless—principles that mirror the very ethos of decentralized blockchain networks. Ultimately, this change and the policy efforts of the Trump administration could jeopardize the frictionless flow of on-chain database transactions and access to various blockchain networks and dApps and could even threaten the innovation and adoption of AI technologies.
Last updated 05/21/2025.
History:
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Mar 11, 2025: The 6th Circuit Court of Appeals denies the petition for rehearing on an invalidation order, ruling that the issues raised in the rehearing petition were fully considered and noting that no judge had requested a vote on the rehearing. Ohio Telecom Assoc. v. Fed. Comms. Comm’n, Case 24-3449, Doc. 142 (Order).
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Jan 2, 2025: The 6th Circuit Court of Appeals rules that the FCC lacks the statutory authority to regulate broadband internet service providers (ISPs) under its mandate in the Communications Act of 1934, as amended by the Telecommunications Act of 1996, thereby invalidating the FCC’s 2024 net neutrality rule. Ohio Telecom Assoc. v. Fed. Comms. Comm’n, Case 24-3449, Doc. 139-2 (Opinion).
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May 22, 2024: The FCC under President Joe Biden reinstates certain major parts of the originally promulgated net neutrality regulations, adopting a declaratory ruling, report and order, order, and reconsideration order re-establishing the Commission’s authority over broadband internet access service. 83 Fed. Reg. 45,404.
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Feb 22, 2018: The FCC under President Donald Trump repeals the original net neutrality rule. 83 Fed. Reg. 7,852.
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Apr 13, 2015: The FCC under President Barack Obama promulgates the original net neutrality rule and issues its final rulemaking notice, requiring internet service providers (ISPs) not to unfairly restrict internet communications, consistent with the principle that all online traffic ought to be treated equally. 80 Fed. Reg. 19,738.
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Jul 1, 2014: The FCC publishes its initial proposed rule in July 2014 and accepts public comments. 79 Fed. Reg. 37,448.
Apr 10, 2025
Congress nullifies IRS crypto broker reporting rule for decentralized operators
United States (Regulatory)
On April 10, 2025, President Donald Trump signed a binding resolution passed by both chambers of the Congress under the Congressional Review Act (RCA) that nullified digital asset reporting obligations imposed on operators of decentralized exchanges and DeFi platforms pursuant to a December 2024 rule promulgated by the Treasury Department’s Internal Revenue Service (IRS) under the 2021 Infrastructure Investment and Jobs Act (IIJA). Under the CRA, a disclaimer of an agency rule prevents the agency from passing the same or a substantially similar rule in the future.
The IRS had promulgated its final rule under the IIJA with only weeks left in President Joe Biden’s administration, seeking to require operators of ‘front-end’ web interfaces providing access to DEXs or other DeFi services to, starting in 2027, perform due diligence on users and file related transaction reports with the Internal Revenue Service (IRS). The originally proposed rule was sought to be applied even against the developers of DeFi protocols and self-hosted digital asset wallets, but the new legislation would likely prevent the IRS from pursuing similar rulemaking efforts in the future.
Last updated 05/21/2025.
History:
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Apr 10, 2025: Exercising their power under the Congressional Review Act (CRA), the House and Senate passed—and President Donald Trump signed—H.J. Res. 25, effectively nullifying the IRS rule as applied to DeFi operators. When an agency rule is nullified under the CRA, it is forbidden from issuing the same or substantially similar rule. H.J. Res. 25.
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Dec 30, 2024: Treasury and the IRS issue a final rule covering remaining components of the proposed rule, removing the requirements that originally would have directly implicated protocol developers. See 89 Fed. Reg. 106,928.
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Jul 9, 2024: Treasury and the IRS issue a final rule covering only certain components of the proposed rule, including the calculation of basis for certain digital asset sales and exchanges. 89 Fed. Reg. 56,480.
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Nov 13, 2023: Treasury and the IRS hold a public hearing discussing the proposed rule.
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Aug 29, 2023: Treasury and the IRS publish proposed regulations that would have qualified many crypto service providers and protocol developers as information brokers under Section 6045 of the Internal Revenue Code, requiring them to make regular reports on customer transactions. 88 Fed. Reg. 59,576.
May 12, 2025
Congress nullifies CFPB rule on digital payment processors
United States (Regulatory)
Congress, exercising its power under the Congressional Review Act (CRA), officially disclaimed and effectively nullified the CFPB’s final rule establishing federal oversight over large digital payment service providers. Under the CRA, a disclaimer of an agency rule prevents the agency from passing the same or a substantially similar rule in the future.
The final rule, published December 10, 2024, required certain consumer-facing payment apps to comply with existing consumer protection laws and CFPB supervisory authority. Intended to safeguard personal data, reduce fraud, and prevent unfair account closures (sometimes referred to as “illegal debanking”), the rule defined “larger participants” in the digital payments market based on transaction volume and other objective criteria, thereby extending CFPB examination to those meeting the specified thresholds. The final rule became effective on January 9, 2025, and was officially disclaimed on May 12, 2025.
Last updated 05/21/2025.
History:
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May 12, 2025: Congress passes and President Donald Trump signs into law S.J.Res. 28, nullifying the CFPB’s final rule and preventing the agency from passing the same or a substantially similar rule in the future. S.J.Res. 28, 119th Cong. (2025).
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Dec 10, 2024: CFPB publishes its final rule in the Federal Register, formally extending its supervisory authority to large digital payment app providers and setting forth new compliance requirements. 89 Fed. Reg. 99582.
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Jan 8, 2024: Public comment period closes, with industry stakeholders, consumer advocacy groups, and financial institutions submitting feedback on the NPRM’s proposed definitions and oversight measures.
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Nov 17, 2023: CFPB officially issues a Notice of Proposed Rulemaking (NPRM), outlining criteria for defining “larger participants” in the digital payments market and detailing proposed supervisory requirements. 88 Fed. Reg. 99582.
Dec 11, 2025
White House launches new policy effort in bid to preempt any state laws or regulations on AI
United States (Regulatory)
On December 11, 2025, the President issued an executive order (the “EO”) launching a national artificial intelligence policy framework and directing federal agencies to challenge state laws that conflict with federal priorities. The EO tasks the Department of Justice to create an Artificial Intelligence Litigation Task Force and bring challenges in courts seeking to block state AI laws based on conflict preemption, obstacle preemption, or interstate commerce grounds. The EO also tasks the Secretary of Commerce to review existing state laws and identify provisions that conflict with the policy objectives set out in the EO. It also directs grant-making agencies to condition certain discretionary federal funds on state commitments not to enforce conflicting artificial intelligence statutes.
The EO additionally charges the Federal Communications Commission (FCC) to begin considering federal disclosure and reporting standards for AI models, and it requires the Federal Trade Commission (FTC) to ssue a policy statement applying Section 5 of the Federal Trade Commission Act to AI practices that implicate unfair or deceptive conduct. Under the EO, the President’s advisors must prepare legislative recommendations for a comprehensive federal framework that could preempt conflicting state laws while preserving state authority over child safety, permitting, and the procurement and use of AI systems. The EO expands on the Trump administration’s existing laissez-faire posture on AI policy and stands in stark tension with the Senate’s July action striking a 10-year moratorium on state AI laws in the 2025 budget reconciliation bill (formerly known as the “One Big Beautiful Bill”).
Last Updated 12/11/2025.
History:
- Dec 11, 2025: White House issues Executive Order 14179, launching a national artificial intelligence framework and directing federal agencies to challenge state laws that conflict with federal policy. Executive Order 14179.
- Jul 1, 2025: The Senate passes the Blackburn-Cantwell amendment stripping the state AI-regulation moratorium from H.R. 1. S.Amdt. 2814 to H.R. 1.
- May 22, 2025: The House of Representatives passes the “One Big Beautiful Bill,” a sweeping budget measure that includes a ten-year moratorium on states’ ability to regulate the AI sector. H.R. 1, § 43201.
- Jan 20, 2025: President Donald Trump signs an executive order titled “Initial Rescissions of Harmful Executive Orders and Actions,” which revokes, among other orders, Biden’s “Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence” order, effectively invalidating and repealing previous NIST guidance. E.O. No. 14148, 90 Fed. Reg. 8237 (Jan. 20, 2025).
- Jul 26, 2024: NIST publishes its three sets of final AI guidance, effective immediately. NIST AI 600-1; NIST SP 800-218A; NIST AI 100-5.
- Apr 29, 2024: NIST releases three initial public draft guidance documents related to AI risk management, secure software development for generative AI, and global AI standards. NIST AI 600-1; NIST SP 800-218A; NIST AI 100-5.
- Oct 30, 2023: President Joe Biden signs an executive order on the safe and responsible development of AI technologies. E.O. No. 14110, 88 Fed. Reg. 5191 (Oct. 30, 2023).
Jan 20, 2025
Trump rescinds Biden-era EOs, likely setting back the BIS’s proposed EDD rule for large cloud service providers
United States (Regulatory)
Immediately after assuming office, President Donald Trump signed an Executive Order that expressly repealed the former President Joe Biden’s October 2023 order on the safe and responsible development of AI (‘artificial intelligence‘). The repealed order had established several directives for the Department of Commerce’s Bureau of Industry and Security (BIS) on which parts of its January 2024 Proposed Rule was based that seeks to impose KYC (‘know-your-customer‘) and enhanced due diligence requirements on large cloud service providers and were based.
The BIS’s Proposed Rule would implement additional measures to address the ‘ongoing national emergency’ related to significant malicious cyber-enabled activities. It would expand on existing U.S. export control frameworks in an effort to deter malicious actors from exploiting U.S. technologies and services by imposing new restrictions and due diligence requirements, particularly for cloud infrastructure providers and other potentially vulnerable platforms. Organizations involved in providing or hosting software, data processing, or cloud services would be subject to heightened compliance obligations under the proposed regulations, having a potentially profound impact on the digital assets industry. The BIS has not indicated whether its publication of a final rule could still be expected or whether it would accord with a lesser scope than the Proposed Rule.
Last updated 05/21/2025.
History:
- Jan 20, 2025: President Donald Trump signs an Executive Order titled “Initial Rescissions of Harmful Executive Orders and Actions” that revokes—among other of former President Joe Biden’s Executive Orders—the order on responsible AI development, potentially affecting the BIS’s ultimate approach under a final rule (though the BIS has not indicated whether a final rule could still be anticipated). E.O. No. 14148 (90 Fed. Reg. 8237).
- Jan 29, 2024: BIS publishes a Notice of Proposed Rulemaking (NPRM) that incorporates considerations from public input on the 2021 ANPRM and the mandates included in the October 2023 Executive Order, outlining expanded export controls and compliance duties aimed at curbing significant malicious cyber-enabled activities. 89 Fed. Reg. 5698.
- Oct 30, 2023: President Joe Biden signs an Executive Order on the safe and responsible development of AI technologies. E.O. 14110 (86 Fed. Reg. 6837).
- Sep 24, 2021: BIS publishes an Advance Notice of Proposed Rulemaking (ANPRM) on the basis of the January Executive Order, seeking public input on how to shape forthcoming regulations. 86 Fed. Reg. 53018.
- Jan 19, 2021: President Donald Trump signs an Executive Order expanding on concerns addressed under former President Barack Obama’s 2015 Executive Order. E.O. 13984 (86 Fed. Reg. 6837).
- Apr 01, 2015: President Barack Obama signs an Executive Order declaring a national emergency in connection with significant malicious cyber-enabled activities and allowing for the blocking of property of persons involved under U.S. sanctions and export controls. E.O. 13694 (80 Fed. Reg. 18077).
