Crypto Disclosure Rules Are Evolving – but the infrastructure still lags

Over the past few years, few regulatory themes have sparked more debate – or more divergence – than disclosure requirements for cryptoassets. As the digitisation of finance accelerates, and traditional and decentralised markets converge, one question sits at the centre: what should disclosure look like for digital assets, and how should it be delivered?

To answer that, it’s worth stepping back.

Modern securities law, starting with the US Securities Acts - shaped in the aftermath of the Great Depression - was built on the concept of disclosure. The logic was twofold: reduce information asymmetries to support efficient markets, and protect investors by ensuring they have the right information to make informed decisions. For nearly a century, this principle has underpinned financial regulation worldwide.

But crypto didn’t emerge from the traditional financial system – and it certainly didn’t inherit its disclosure practices. The ICO boom, which marked crypto’s arrival into the mainstream investor consciousness, was largely unregulated. Projects were launched with no standardised disclosures, few safeguards, and little clarity about rights, risks or obligations. It was an experiment in, and some say, the birth of, decentralised capital formation – and while it accelerated innovation, it also exposed serious structural gaps.

The nature of cryptoassets has only complicated things further. Unlike equities or bonds, digital assets trade 24/7 across jurisdictions and their legal status is often ambiguous. They’re volatile, technical, and marketed to retail investors  through many different, centralised and decentralised platforms. All of this has made it challenging to apply existing securities disclosure rules wholesale – and has led to years of regulatory debate over what should change, and what should stay the same.

Now, after years of uncertainty, we’re beginning to see regulatory models emerge – and diverge.

A global split on disclosure design

In the EU, the Markets in Crypto-Assets Regulation (MiCA) has created the first comprehensive disclosure regime for cryptoassets. It borrows heavily from traditional securities frameworks: issuers must publish a white paper to issue assets to retail investors (subject to certain exemptions), and are subject to prospectus-style liability for misstatements. While MiCA doesn’t cover everything – NFTs and DeFi are excluded for now – it marks a clear step toward harmonisation and predictability.

The UK, meanwhile, is still shaping its approach. It has leaned into the white paper model, taking cues from MiCA, but with a more flexible lens. The FCA is exploring the idea of a centralised “white paper utility” – a digital repository where disclosures could be published, tracked and validated. It’s a recognition that the form and function of disclosures may need to evolve for a digital-first asset class.

In the US, the picture is more fragmented – but potentially more transformative. The Market Structure Bill and other emerging proposals suggest a technology-led disclosure regime that could leapfrog EU-style reforms entirely. With lessons learned from other jurisdictions, and input from industry and legislative bodies, US regulators may prioritise modular, real-time disclosure models designed specifically for the on-chain environment.

Why the delivery model matters

What all these approaches have in common is a growing recognition that form matters as much as content. Disclosure is no longer just about producing a PDF or a static document. In a tokenised market, where information moves as fast as assets do, disclosures need to be machine-readable, real-time, and accessible on-chain. That’s not just a crypto issue – it’s a systemic shift that will eventually touch tokenised securities, digital bonds, and tokenised real world assets.

The challenge is that the infrastructure to support that shift barely exists. Today, disclosures are still largely drafted in Word documents, circulated in PDFs, and published on websites. There’s no shared taxonomy, no standard validation process, and no unified framework for how disclosure data should be structured, versioned or surfaced across markets in different jurisdictions. That gap introduces risk – and holds back innovation.

A critical moment for global finance

What’s emerging now is a broad consensus that disclosure for digital assets cannot simply mirror what came before. Cryptoassets – and the infrastructure supporting them – demand new formats, faster dissemination and context-aware transparency. This will likely push regulators and market participants toward solutions that are more dynamic, more tech-driven, and globally interoperable.

Whether through centralised repositories, open data models or new cross-border protocols, the direction of travel is clear: disclosure needs to evolve with the assets it governs. That means embracing formats that go beyond static reports – toward real-time, structured, and digitally native communication with the market.

This is a pivotal moment. The frameworks now being shaped will influence how digital markets grow, how retail and institutional investors are protected, and how trust is built in a rapidly shifting ecosystem. The decisions made by regulators today will either future-proof disclosure – or leave it struggling to catch up. Either way, change is no longer theoretical. It’s already underway.