DeFi Debrief
Week of December 1: DEF Comment Letter to CFTC; 10 Things to Know About DeFi; International Updates
DEF Submits Comment Letter to CFTC
On November 28, 2025, DEF submitted a comment letter to the Commodity Futures Trading Commission (CFTC) in response to its Request for Input on the recommendations for the CFTC in the President’s Working Group on Digital Asset Markets report.
In the letter, we urge the CFTC to continue pursuing a principles-based, technology-neutral approach that protects customers and creates space for DeFi and digital market infrastructure to grow in the United States.
A major focus of our letter is the need for clear, appropriately tailored guidance for DeFi. Effective regulation must recognize the differences between intermediated and intermediary-less DeFi systems to ensure rules are workable in practice. We also highlight that blockchain-based derivatives can operate within a transparent, compliant framework, but only if regulators provide clarity that supports responsible innovation rather than stifling it.
DEF is grateful to the CFTC and the Acting Chairman Caroline Pham for her leadership. Read our full letter here.
DEF Publishes “10 Things to Know About Decentralized Finance” Explainer
On December 2, 2025, DEF published an explainer, entitled: “10 Things to Know About Decentralized Finance.” Designed for those interested in learning about DeFi but unclear on where to start, DEF gives some quick hits on what DeFi is, why it matters, and how it works.
Click here to give it a read.
New UAE Law Captures DeFi Technology
On September 15, 2025, the United Arab Emirates (UAE) issued Federal-Decree Law No. 6 of 2025 Regarding the Central Bank Regulation of Financial Institutions and Activities and Insurance Business (the “New CBUAE Law”). The New CBUAE Law became legally effective as of September 16th, 2025, and represents a significant overhaul of the financial regulatory framework of the UAE; notably, it brings DeFi activities under the authority of the Central Bank of the UAE.
The New CBUAE Law introduces provisions that expand the scope of the Central Bank’s authority. Article 61 of the New CBUAE Law explicitly includes providing open finance services and providing payment services using virtual assets as “Licensed Financial Activities,” and Article 62 further extends the licensing framework to capture activities conducted through emerging technologies, including DeFi. Article 62 also introduces new licensing requirements for emerging-technology providers by stating that any person who carries on, offers, issues, or facilitates a licensed financial activity—“regardless of the medium, technology, or form employed”—is subject to the licensing, regulatory, and supervisory authority of the Central Bank of the UAE.
The new law makes it clear that decentralized projects that facilitate or enable financial services may fall within the Central Bank’s regulatory oversight, even if they merely provide technological infrastructure and not the underlying financial product. Under the rule, projects will have to evaluate whether their business model and technology could be deemed to enable activities such as payments, exchange, lending, custody or investment services, and therefore trigger a licensing requirement.
DEF is actively monitoring for developments.
UK Finalizes Tax Guidelines for DeFi Lending and Staking
On November 26, 2025, the United Kingdom’s tax authority, His Majesty’s Revenue and Customs (HMRC), published its consultation outcome for the taxation of DeFi involving the lending and staking of cryptoassets, in response to the HMRC’s 2022 guidance on the tax treatment of cryptoasset loans and liquidity pool arrangements and subsequent Call for Evidence to address potential administrative burdens.
Under the proposed approach, the HMRC would create separate rules for cryptoasset loans and liquidity pools, with any potential new rules applying to both centralized finance (CeFi) and DeFi arrangements. Officials say the goal is to align tax with how DeFi actually works and reduce reporting burdens when nothing has been “sold.”
Notably, HMRC confirms it is developing a “no gain, no loss” approach to DeFi loans and liquidity pools, which will defer capital gains tax until there is a true “economic disposal” (e.g., a real sale or swap, not just when tokens move in and out of a DeFi protocol—and may extend this approach to automated market makers as well).
DeFi Dictionary
Regardless of market conditions, builders keep building and tokens keep launching. There comes our DeFi Dictionary word of the week: “Network Token.”
Notable and Quotable
“[T]hese are only the first steps in a broader effort to realign our markets with their most fundamental purpose, which is to place the full measure of American might where it belongs: in the hands of our citizens instead of the regulatory state.”
– SEC Chair Paul Atkins, “Revitalizing America’s Markets at 250”, Speech at the NYSE on December 2, 2025.
 | A guest post by
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The CFTC comment letter's push for principles-based regulation is smart, but distinguishing between intermediated and intermediary-less systems is where it gets tricky in practice. A lot of protocols sit somewhere in between, with governance tokens or dev teams that could arguably be seen as having some control. I'm curious how regulators will actually draw those lines without accidentally killing projects that are genuinely trying to be decentralized.