Crypto After the Midterms: Regulation, Liquidity and the Institutional Era

The US midterm elections on 3 November 2026 is likely to determine the political setting for the next phase of US crypto regulation, not whether crypto is regulated or not. When the Senate failed to advance the Digital Asset Market Clarity Act on 15 September, the US did not lose its existing crypto framework; it lost an opportunity to put that framework into statute. The 49–50 vote was procedural, not a vote on the substance of the bill. The distinction matters because the next US Congress will inherit the question that CLARITY left unresolved: will crypto market rules continue to depend on agency decisions, or be set in law?

Although Congress stalled, the regulatory build-out continued. Within 48 hours, the SEC created a five-year conditional exemption for qualifying tokenised US equities, allowing permissioned Automated Market Maker (AMM) based trading where the token represents the same underlying security and preserves the relevant investor rights. Meanwhile, the CFTC gave conditional relief to passive software providers that connect users to regulated derivatives venues and moved a broader crypto-market rulemaking into federal review. These were not substitutes for CLARITY: they were narrower, agency-led routes that regulate the access layer around blockchain-based financial products rather than the blockchain itself.

This emerging US model increasingly focuses on regulating the businesses and services built around blockchain, rather than the blockchain technology itself. The midterms may impact how quickly Congress codifies that architecture, but the regulatory build-out is already underway.

Markets tell a parallel story. Crypto now trades increasingly like an investment class, not an isolated market. Q3 2026 showed how quickly treasury yields, monetary-policy expectations and portfolio flows can overwhelm crypto-specific catalysts. Bitcoin gained approximately 23% over eight days after the US Treasury expanded bond buybacks in August, triggering more than $1.6 billion in short liquidations. The rally weakened when expectations for Federal Reserve tightening returned.

Institutional access has strengthened this macro connection. US spot Bitcoin ETFs moved from approximately $4.7 billion net outflows in Q2 to $6.4 billion inflows in Q3. The same wrapper that brought institutional capital into Bitcoin also gives investors a simple way to reduce exposure when yields, volatility or portfolio preferences change. ETFs therefore increasingly connect crypto to the same asset-allocation decisions that govern equities, bonds and commodities.

The result was a broad but uneven recovery. Total crypto market capitalisation reached USD 2.96 trillion, increasing by 39% in Q3. Bitcoin gained around 43%, Ethereum 71% and Solana about 61%, while the Top 80 cryptocurrencies advanced approximately 57%. Yet spot exchange volume fell by 6%, even as perpetual futures open interest rose more than 40%. Prices recovered faster than underlying market participation, leaving Q4 with stronger valuations but more leverage and continued sensitivity to macro conditions.

At the same time, the crypto industry progressed on a different axis. Stablecoins expanded their role in settlement and collateral, tokenised securities generated increasing trading activity, and jurisdictions from the EU to Switzerland, the UAE, UK and Hong Kong moved from policy design toward licensing and live infrastructure.

Crypto enters Q4 as two things at once: an investment class increasingly exposed to global financial conditions, and a financial infrastructure industry whose development increasingly continues through market cycles and political changes. The election will influence the US legislative path. It will not determine the industry’s entire trajectory.

On 15 September, the Senate voted 49–50 against advancing the CLARITY Act, falling short of the 60 votes required and highlighting the challenge of securing broader support for US crypto market-structure legislation.

The upcoming midterm election now determines the political setting in which those negotiations continue. As of 16 October, the Silver Bulletin generic congressional ballot showed Democrats ahead by 8.9 percentage points nationally, or 9.6 points after its likely-voter adjustment. A national polling margin does not translate into House seats, but it indicates the political environment going into the final weeks.

The Senate is less straightforward.  With Republicans holding a 53–47 Senate majority, control hinges on competitive races across several states, including Maine, Texas, Ohio and Michigan.

For crypto, the relevant question is not whether one party is inherently “good” or “bad” for digital assets. The more useful question is which parts of policy become easier or harder to change under each configuration of Congress.

A Democratic House alongside a Republican Senate may increase the scope for House oversight while leaving legislation dependent on agreement between the two chambers. Democratic control of both chambers could shift committee leadership, oversight priorities and the terms on which market-structure legislation returns. Republican control of both chambers may provide greater alignment between Congress and the administration’s existing crypto policy agenda, although the September cloture vote shows that Senate procedure and cross-party support still matter. A Republican House and Democratic Senate may create another form of divided government, leaving agencies and already-enacted legislation with greater importance.

The distinction between legislation and implementation is becoming especially important here.  The GENIUS Act has established a statutory framework for payment stablecoins that will continue to be implemented regardless of congressional control. Market-structure legislation remains less settled, leaving questions around SEC and CFTC jurisdiction, platform registration and customer asset protection open to further legislation or agency interpretation.

Reuters reported a change in congressional control could also intensify oversight of crypto firms, increasing compliance costs without new laws. The impact will vary across digital assets: US-facing exchanges, brokers and stablecoin issuers are more directly exposed to policy shifts, while Bitcoin remains more sensitive to broader market forces.

Indeed, total crypto market capitalisation reached a quarterly high on 21 September, despite the CLARITY Act failing to advance days earlier, underscoring that regulation is only one of several forces shaping the market.

The midterms can change the path of US crypto regulation. They do not provide a standalone forecast for crypto prices.

Asset Performance

Sources: Coingecko, Trading Economics

Q3 reversed much of the weakness seen in the first half of the year. Crypto outperformed traditional risk assets, but the recovery looked different from a broad speculative cycle. Bitcoin remained the market’s anchor, while Ethereum, Solana and a wider set of altcoins generated stronger percentage returns as investors moved further down the risk curve.

The shift becomes clearer when compared with Q2. In the previous quarter, crypto fell while US equities rallied, producing one of the sharpest divergences between digital assets and technology stocks since the launch of spot Bitcoin ETFs. Q3 closed much of that gap. Crypto recovered even as equities delivered comparatively modest gains, gold remained positive and Treasury yields rose. The reversal suggests that the weakness in Q2 reflected crypto-specific deleveraging and capital withdrawal as much as a general rejection of risk assets.

Altcoin performance broadened substantially. Ethereum and Solana led among the largest Layer-1 networks, while several mid-cap assets delivered much stronger returns.

Together, these moves suggest that once the broader market recovered, capital increasingly differentiated between altcoins based on revenue capture, institutional distribution and measurable product usage rather than treating the sector as a single beta trade.

Market liquidity

Sources: CoinGecko, CryptoRank, CoinGlass, DeFiLlama.

Market liquidity did not recover as convincingly as prices. Spot participation remained subdued even as valuations rebounded, while derivatives positioning rebuilt aggressively. The result was a market with stronger prices but a larger share of activity concentrated in leveraged exposure rather than cash-market demand.

Higher futures open interest increased the market’s sensitivity to changes in funding conditions, yields and macro expectations. Q3 therefore ended with broader gains across digital assets, but also with a market structure more vulnerable to sharp repricing when positioning became crowded.

ETF flows linked these dynamics directly to institutional portfolio behaviour. In Q2, regulated Bitcoin products became a source of supply as investors withdrew capital. In Q3, they returned as a source of demand. The reversal shows that ETFs should no longer be treated as a permanent structural bid. They have become a two-way portfolio-allocation channel through which investors may increase or reduce crypto exposure as relative valuations, yields and risk appetite change.

Digital Asset Treasuries Show Strength

While the balance sheets of digital asset treasury companies expanded alongside the market recovery, Q3 also showed that the DAT model depends increasingly on financing conditions, equity valuations and capital-structure management. Bitcoin accumulation is only one part of the model; the cost and availability of funding have become equally important.

Strategy provides the clearest example of how DAT demand now depends on capital structure as much as on Bitcoin conviction. In our August article, Why Is Strategy Selling Bitcoin? The Digital Credit Pivot and the mNAV Redefinition, we argued that Strategy’s 6,948 BTC of sales in 2026 did not signal a change in its long-term Bitcoin thesis. The immediate pressure came from STRC trading below its $100 stated amount. That impaired one of Strategy’s key funding channels and made discounted STRC repurchases more attractive than issuing common equity while MSTR traded close to the value of its underlying Bitcoin holdings. Strategy formalised this approach through its June Digital Credit Capital Framework, using Bitcoin as a balance-sheet asset that could be monetised when capital-market conditions warranted it.

Q3 largely validated that framework. Strategy had been repurchasing STRC progressively closer to par, from an implied average price of $86.53 in late July to $95.20 by mid-August. As STRC recovered, the company stopped relying on Bitcoin sales and returned to accumulation. On 31 August, Strategy bought 4,603 BTC for $369.7 million at an average price of $80,318, taking total holdings to 845,050 BTC. It also repurchased $151.8 million of STRC that week, showing that Bitcoin accumulation and preferred capital repair may no longer be mutually exclusive.

Q3 therefore left the market in a materially different position from the end of Q2. Q2 cleared leverage and weakened the marginal bid. Q3 rebuilt prices, institutional demand and risk appetite faster than it rebuilt underlying spot liquidity. The recovery was broad, but the market entered Q4 with a greater dependence on sustained capital inflows and stable funding conditions.

Beyond Q3 Market Pricing: Digital Asset Infrastructure, Product Evolution and Emerging Risks

Stablecoins and yield-bearing instruments

Stablecoins started as a practical solution to a crypto-market problem: how to move dollar exposure between exchanges without repeatedly entering the banking system. Their role has since widened. They now sit inside payments, treasury management, collateral, trading and settlement workflows.

This may be relevant for how institutions may consider evaluating them.

As we argued in Institutional Stablecoins: Four Regulatory Regimes Compared, regulatory regimes increasingly agree on the broad principles – high-quality reserves, segregation, redemption and financial-crime controls, but differ on who can issue stablecoins, what reserves can contain and what rights holders have. For institutions, the important question is therefore no longer simply whether a token maintains a one-dollar price. It is who owes the holder the dollar, what assets stand behind that obligation and under what conditions the holder can redeem.

The market is also beginning to separate transactional cash from yield-bearing cash. Stablecoins are primarily designed for settlement and payments. Investors seeking return are increasingly looking toward tokenised money market funds and similar instruments instead.

That distinction formed the core of our analysis in Tokenised Money Market Funds: On-chain Yield, Off-chain Constraints. Tokenisation can make a fund share easier to transfer, use as collateral or hold inside a digital wallet, but it does not change the economics of the underlying fund. A token may move between approved wallets at any hour while subscriptions, redemptions and portfolio liquidity continue to operate according to traditional fund rules.

The emerging institutional structure therefore looks less like one universal digital dollar and more like a stack of different forms of money: bank deposits for final cash settlement, stablecoins for transactional liquidity, and tokenised funds for yield. Their usefulness will depend increasingly on how easily institutions can move between those layers.

Tokenised equities: Access is improving faster than simplified ownership

Investors can potentially trade equity exposure outside conventional market hours, move it between wallets, integrate it with onchain lending markets and settle transactions without relying on the same chain of intermediaries used in traditional brokerage.

The legal position is more complicated.

As we explored in Tokenised Equities: Who Can Buy Them and What You Actually Own, two products displaying the same stock ticker may give investors very different rights. One token may represent the underlying share. Another may represent a contractual claim against an intermediary holding that share. A third may simply track the price through a synthetic structure.

That distinction becomes more important as activity grows. Trading volume can expand much faster than the amount of underlying equity actually held onchain. High turnover may demonstrate demand for continuous equity exposure without necessarily demonstrating equivalent demand for blockchain-native ownership.

The next stage of tokenised equities therefore depends less on how many stocks can be represented onchain and more on whether those representations can reproduce the functions investors expect from conventional securities: dividends, voting rights, corporate actions, tax treatment, custody and enforceable ownership.

Liquidity presents a second constraint. A tokenised stock may trade continuously even when the underlying exchange is closed. Someone must still provide the security or cash required to settle that position. Twenty-four-hour trading does not automatically create twenty-four-hour primary-market liquidity.

Tokenised equities are starting to move beyond trading into collateral and financing. Recent integrations across

The tokenised asset is beginning to remain onchain after purchase and perform another financial function: it can secure a loan, provide collateral or support a leveraged position. The market is effectively starting to build a securities-financing layer around tokenised equities, albeit at a small scale relative to traditional prime brokerage and securities lending.

It also makes the ownership distinction we highlighted in Tokenised Equities: Who Can Buy Them and What You Actually Own more important, not less. Once a token becomes collateral, lenders need to know what sits behind it, how the underlying shares are held, whether they can be redeemed or liquidated when traditional markets are closed, and what claim survives if the issuer or intermediary fails. The next test for tokenised equities is therefore not how many tickers move onchain, but whether they can support liquid and legally robust collateral markets at scale.

Security: The cryptography is no longer the only perimeter

Recent security incidents show that attackers increasingly do not need to break the cryptography securing Bitcoin or Ethereum. They can attack the systems around it.

Weak key generation, software implementation errors, compromised third-party products and tampered hardware can all defeat an otherwise secure cryptographic system. The recent demonstrated the problem clearly: the cryptographic protection remained intact, while a malicious hardware implant captured the recovery phrase before the security architecture could protect it. The same pattern appeared elsewhere in the Coldcard incident involving wallet firmware, bridges and external security vendors.

This changes the institutional definition of custody risk. Holding the private key securely is necessary but no longer sufficient. Institutions also need to understand how that key was generated, which hardware touched it, which software can interact with it, which vendors sit in the operational chain and what happens if one of those components fails.

These incidents also challenge the assumption that self-custody or offline storage is inherently the safest end state. As we discussed in What is true cold custody? Why isn’t “offline” the same as “safe”?, taking a private key offline protects it from remote access, but says little about how the key was generated, whether the device or firmware was compromised, how backups are secured or what happens when one component fails. The Coldcard and Ledger incidents exposed precisely these upstream risks: users could follow standard self-custody practices and still inherit a vulnerability they had little ability to detect.

For larger holdings, offline is only the starting point. Institutional cold custody combines air-gapped key protection with distributed approvals, segregation of duties, auditability and disaster recovery so that no single person, device or location can become the point of failure. As we argued in Institutional Crypto Custody: How Cold Custody Secures Digital Assets, the shift from cold storage to cold custody is ultimately a shift from protecting a secret to engineering out concentrations of operational risk.

Quantum and mathematical superintelligence: Preparing for a different threat

Quantum computing presents the better-understood risk. A sufficiently capable quantum computer could theoretically use Shor’s algorithm to solve mathematical problems that protect widely used forms of public-key cryptography. The problem extends far beyond crypto: banks, governments and internet infrastructure depend on similar cryptographic assumptions.

More recently, advances in automated mathematical reasoning have raised a second possibility: that a sufficiently capable AI system could discover a classical mathematical shortcut that weakens an existing cryptographic primitive without requiring quantum hardware.

Recent discussion around mathematical superintelligence brought that possibility into crypto markets. The concern is that rapid progress in mathematical reasoning shortens the amount of time the industry may have to respond if a meaningful breakthrough occurs in breaking the cryptography protecting most blockchains today.

The distinction between the two threats matters. Quantum risk assumes new hardware capable of running known algorithms at sufficient scale. The AI scenario assumes discovery of a new algorithm that works on classical hardware. Both ultimately raise the same institutional question: how quickly could the industry migrate if today’s signature schemes became unsafe?

In our May report, The Quantum Clock Is Ticking — Is Crypto Ready?, we argued that the harder problem may not be inventing post-quantum cryptography, but coordinating its deployment across wallets, exchanges, custodians, validators and dormant assets. Developments since then have moved that question closer to implementation.

Ethereum now has a dedicated post-quantum security team and has set a target for the Layer 1 to become quantum-resistant across execution, consensus and data by December 2029. Its roadmap includes replacing quantum-vulnerable validator signatures, introducing post-quantum public-key infrastructure and using account abstraction to give users greater flexibility over signature schemes.

The broader financial sector is also moving in the same direction. The Bank of England said in October that it is assessing how prepared banks are for quantum computing to compromise existing encryption standards, while NIST has already standardised the first post-quantum algorithms. Quantum readiness is therefore becoming less of a crypto-specific tail risk and more of a common infrastructure problem across payments, banking and digital assets.

Q4 began with a less forgiving cross-asset backdrop. US Treasury yields have moved above 5%, gold remains above $4,000, and the Nasdaq 100 recorded its sharpest weekly decline in October 2026, since April 2025 as investors questioned the debt financing behind the AI infrastructure boom. Until recently, strong earnings and AI capital expenditure allowed equities to absorb higher yields. October provided the first clear sign that the cost of capital is beginning to matter even for the market’s strongest theme.

This creates a difficult test for crypto. Bitcoin’s relationship with traditional assets has shifted depending on what markets are reacting to. During September’s yield surge, BTC traded inversely to the dollar and alongside gold, with its 30-day correlation to gold reaching roughly 0.6. By October, its correlation with the Nasdaq had recovered above 0.5. The distinction is important: an inflation or sovereign-debt shock can make Bitcoin trade more like a scarce asset, while a broad reduction in risk or leverage pulls it back toward equities.

Gold provides the other side of that comparison. Higher real yields would normally weigh heavily on a non-yielding asset, yet gold has remained above $4,000 even as Treasury yields climbed. Central-bank buying and demand for reserves outside conventional sovereign debt have weakened its historical relationship with real yields.

Bitcoin has not yet established the same defensive demand base. In a risk-off move driven by credit stress, Treasuries and gold attract capital while crypto still suffers from deleveraging. The behavior of BTC relative to both Gold and the Nasdaq will therefore be more informative in Q4 than any fixed correlation assumption.

AI becomes a test of the broader risk cycle

The recent AI sell-off has everyone’s attention. Investors are finally paying attention to how the infrastructure required to meet AI demand will be financed.

The pressure has been most visible in datacentre and “neocloud” companies that financed rapid expansion through debt. CoreWeave’s bonds have come under pressure, planned datacentre transactions have been delayed, and investors have started differentiating between large technology companies that can fund AI investment from operating cash flow and newer infrastructure businesses reliant on external financing.

That distinction has relevance for crypto. The AI rally absorbed a substantial share of speculative and growth capital while crypto struggled during the first half of the year. A correction in AI does not imply that money automatically rotates into digital assets. If the correction reflects changing sector preferences, some capital may rotate. If it reflects tighter credit and lower tolerance for leverage, the same conditions may constrain crypto.

The October sell-off therefore creates a useful Q4 signal: whether weakness remains concentrated in highly leveraged AI infrastructure or spreads into credit markets and broader equity positioning. The latter may matter more for Bitcoin than the performance of any individual technology company.

The global liquidity picture is also changing

Japan could become more important to global capital flows. Higher domestic yields are beginning to draw Japanese banks and insurers back toward government bonds at home. They bought a net ¥5.4 trillion longer-dated JGBs in the five months through August while selling foreign bonds at an unusually fast pace.

A large-scale repatriation has not yet occurred, but the incentive structure has changed. Japanese investors spent years looking overseas because domestic yields offered little return. As that gap narrows, less capital needs to leave Japan. For crypto, the relevant transmission may come through global bond yields, currency funding and leveraged positions rather than direct Japanese crypto buying.

China presents almost the opposite picture. Q3 growth improved to 4.5%, but domestic demand remains weak, property investment continues to contract and much of the resilience comes from exports and industrial production. Beijing has released additional fiscal capacity for infrastructure, but the year-end question is whether that support produces stronger private-sector demand rather than simply more state-led investment.

Together, the US, Japan and China point to a Q4 environment in which liquidity is less abundant and more selective. US investors can potentially earn a higher yield in parts of the Treasury market, Japanese institutions have greater incentive to keep capital at home, and Chinese stimulus remains targeted rather than indiscriminate. Crypto therefore enters Q4 competing harder for the marginal dollar.

Crypto IPOs will test whether the recovery extends beyond tokens

The IPO market may provide one of the clearest tests of how much institutional appetite has actually returned.

BitGo reopened the US crypto IPO window in January, raising $212.8 million at $18 per share, above its marketed range, and opening 24.6% higher on its first day. But the window did not stay uniformly open. Kraken, which had confidentially filed in late 2025, subsequently paused its listing plans as market conditions deteriorated.

Two Q4 candidates now make the pipeline more interesting. Blockchain.com, which confidentially filed earlier this year, has reportedly considered raising around $500 million at a valuation of roughly $4–6 billion. Grayscale Investments has also progressed through the registration process for a potential public listing.

These offerings test something ETFs cannot. An ETF asks investors whether they want exposure to Bitcoin or another digital asset. A crypto-company IPO asks them to underwrite revenues, margins, regulatory costs and business-model durability at today’s cost of capital.

The distinction is especially relevant after the recent correction in AI infrastructure. Public markets are becoming less willing to finance growth simply because the addressable market is large. Crypto companies approaching the IPO market will face the same scrutiny: how much revenue depends on asset prices, what happens to margins during a lower-volume environment, and how much capital the business needs to keep growing.

Successful listings at credible valuations would show that Q3 reopened more than demand for tokens. They would suggest that institutional capital is again willing to finance the businesses built around the asset class. Delays or deep valuation discounts may indicate that the recovery in crypto prices has moved faster than the recovery in its equity-capital market.

Year-end flows could add volatility

December introduces portfolio mechanics that were less important in earlier crypto cycles. More digital-asset exposure now sits in ETFs, listed equities and conventional brokerage accounts, making tax-loss harvesting, benchmark rebalancing and year-end risk limits more relevant to crypto flows.

This could be particularly visible in assets that rallied sharply in Q3 but remain below their early-2026 levels. Investors can realise losses in one wrapper, reduce risk ahead of year-end or rebalance between direct crypto, ETFs and listed crypto companies much more easily than in previous cycles. Thin holiday liquidity could amplify those flows.

What Q4 will tell us

Q3 established that capital can return quickly to crypto. Q4 should provide better evidence of what kind of capital has returned.

A stronger market may combine sustained ETF demand with improving spot participation and continued differentiation among altcoins based on actual usage. A weaker one may rely increasingly on derivatives while ETF flows become unstable and tighter financial conditions constrain risk appetite.

Outside token prices, IPOs will test institutional willingness to finance crypto businesses, Ethereum Glamsterdam upgrade will test whether technical improvements translate into economic activity, and developments in stablecoins and tokenised securities will show whether blockchain infrastructure continues expanding even in a tougher investment environment.

The central Q4 question is therefore not whether Bitcoin can extend its Q3 return. It is whether digital assets and the businesses around them can continue attracting capital when investors have more alternatives, financing is more expensive and the strongest competing growth trade of the past several years is itself being tested.

Beyond the midterms, crypto enters the final quarter of 2026 as two things at once: an investment class increasingly tied to global financial conditions, and a financial infrastructure sector developing its own sources of demand. The distinction between the two will matter more than the election result alone.

The third quarter marked a recovery in crypto markets, but its mechanics matter more than the headline return.

A Treasury-market catalyst broke Bitcoin out of a narrow range. Derivatives turned the move into a short squeeze. ETF investors added capital as conditions improved. When expectations for monetary policy tightened again, Bitcoin responded alongside other macro-sensitive assets.

That sequence shows how far crypto has moved into mainstream portfolio construction. Institutionalisation has expanded access, but it has also increased the importance of rates, yields and cross-asset allocation.

At the same time, the underlying industry is developing through a separate channel. Stablecoins are becoming settlement assets. Tokenised securities are beginning to trade rather than merely exist. Central banks are connecting tokenised markets to central-bank money. Banks are adding custody and execution. Regulators are moving from consultations to licenses and authorisations.

The midterms will determine the congressional setting for the next stage of US policy. They will not determine all of these developments.

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