The CLARITY Act Has 4 Days Left: Digital Chamber Presses Senate, Lummis Sets April 25 Deadline
The Digital Chamber sent a formal letter to the Senate Banking Committee on April 20 demanding a markup. Senator Lummis says April 25 is the deadline — after that, the bill dies until 2030.
The most consequential piece of crypto legislation in US history is running out of time. On April 20, 2026, the Digital Chamber — the industry's most prominent trade association — sent a formal letter to Senate Banking Committee Chairman Tim Scott and Ranking Member Elizabeth Warren, demanding that the committee schedule a markup of the Digital Asset Market Clarity Act. The letter was copied to Digital Assets Subcommittee Chair Cynthia Lummis and Ranking Member Ruben Gallego.
The letter noted that 270 days have passed since the House approved the CLARITY Act in a 294-134 bipartisan vote — the largest congressional margin ever recorded on crypto legislation — and that the 119th Congress is past its midpoint. The Digital Chamber wrote that advancing the bill to markup is 'critical to delivering the clarity that the more than 70 million Americans who have embraced digital assets deserve.'
Senator Lummis has been more direct. She has warned publicly that if the Senate Banking Committee does not schedule a markup by April 25, the bill risks being shelved until 2030 — when the legislative calendar reopens after the November midterm elections reset Congressional priorities. Senator Moreno has said the same. Galaxy Research's Alex Thorn has issued the same warning. Polymarket odds for 2026 signing sit at 72%, up from 60% the prior week, but the prediction market is pricing in the possibility that 'close' still means 'not done.'
Why April 25 Is the Real Deadline
The procedural math is unforgiving. If the Banking Committee marks up the bill in late April, it still faces five sequential steps before becoming law: committee vote, full Senate floor vote requiring 60 votes (meaning meaningful Democratic support), reconciliation with the Agriculture Committee's version of the bill, reconciliation with the House-passed version from July 2025, and presidential signature.
Each step requires time. A floor vote alone requires floor time that Senate leadership must allocate. Reconciliation with two other versions of the bill requires a conference committee or informal negotiations. And the midterm campaign calendar begins consuming legislative bandwidth by June.
If the markup does not happen by April 25, the remaining calendar compresses to the point where completion before the midterms becomes mathematically implausible. The bill does not die formally — it remains pending — but practically, it enters a legislative limbo from which crypto market participants have been told repeatedly it will not emerge until 2030.
The State of Negotiations
What Is Resolved
The substantive disputes that defined the first quarter of 2026 are largely resolved. White House crypto adviser Patrick Witt confirmed on April 14 that the Tillis-Alsobrooks stablecoin yield compromise is holding. The deal prohibits passive yield on stablecoins while permitting activity-based rewards tied to genuine payments, transfers, and platform usage.
Coinbase CEO Brian Armstrong reversed his commercial objections to the bill on April 10, endorsing it publicly after Treasury Secretary Bessent's Wall Street Journal op-ed calling passage a national security priority. SEC Chair Atkins confirmed the agency is already preparing to implement the Act. The coalition backing the bill — spanning the White House, Treasury, SEC, CFTC, and the largest crypto companies — is broader now than at any prior point in the legislative process.
What Remains Open
Chairman Scott told Fox Business on April 14 that three issues remain: the stablecoin yield language (despite the Tillis-Alsobrooks compromise, the final text has not been published), DeFi provisions (new concerns from law enforcement agencies over DeFi-related provisions have added to delays), and securing all Republican votes on the committee.
The revised Tillis yield text has still not been formally released. Without the text, Scott has no document to base a markup date on. The procedural sequence is fixed: Tillis releases text → 48 hours pass → Scott sets a date. Each day the text is delayed is a day the markup cannot be scheduled.
What the Bill Does — A Compliance Officer's Summary
For compliance teams that have not yet studied the CLARITY Act's provisions, the core changes are as follows.
Token classification. The bill creates a three-category system: digital commodities (CFTC jurisdiction), digital securities (SEC jurisdiction), and payment stablecoins (GENIUS Act framework). The SEC-CFTC joint interpretation of March 17, 2026, which classified 16 tokens as digital commodities, would be codified into permanent law.
Registration categories. New registration categories for digital commodity exchanges, brokers, dealers, and custodians. Each carries specific capital requirements, AML program obligations, and operational standards.
Custody requirements. Title IV establishes institutional-grade custody standards: asset segregation, cold/hot wallet separation, MPC or multisig controls, SOC 2 audits, and BSA compliance.
AML program requirements. All registered entities must maintain AML/CFT programs meeting BSA standards — including customer identification, transaction monitoring, sanctions screening, SAR filing, and record retention.
Developer protections. Treasury Secretary Bessent and White House adviser Witt have both named developer protections as a core pillar. The bill shields non-controlling blockchain developers from prosecution under money transmission laws — the Promoting Innovation in Blockchain Development Act provisions are incorporated.
DeFi treatment. The bill distinguishes between non-custodial protocols (which may be exempt from certain registration requirements) and custodial intermediaries (which face full regulatory obligations).
What Compliance Teams Must Do Right Now
Do not wait for passage to prepare. The bill's requirements are well-defined in the House-passed text. If it passes, compliance teams will have months — not years — to implement.
If it does not pass, the SEC and CFTC's existing authority — the MOU, the joint interpretation, Regulation Crypto, and the GENIUS Act implementing rules — will establish substantially similar requirements through rulemaking. The destination is the same; only the vehicle changes.
Begin building your compliance infrastructure to the CLARITY Act standard: registration-grade KYC covering all customers, AML program with transaction monitoring and SAR filing capability, sanctions screening against OFAC, EU, UN, and relevant national lists, custody infrastructure meeting Title IV standards, and record retention for a minimum of five years.
CLARITY Act Deadline FAQ
- What is the CLARITY Act?
- The Digital Asset Market Clarity Act (H.R. 3633), which passed the House 294-134 in July 2025. It creates a comprehensive regulatory framework for digital assets, dividing jurisdiction between the SEC and CFTC based on token classification.
- Why is April 25 the deadline?
- Senator Lummis has warned that if the Banking Committee does not schedule a markup by April 25, the remaining legislative calendar is insufficient to complete the five procedural steps required for enactment before the November midterm elections consume Congressional bandwidth.
- What happens if the bill does not pass in 2026?
- Multiple senators and analysts have warned that failure in 2026 means the legislative process restarts in 2029-2030 at the earliest. In the interim, the SEC and CFTC's existing authority would be used to establish similar requirements through rulemaking.
- What are the remaining obstacles?
- Three issues: final stablecoin yield text (not yet published), DeFi provisions (law enforcement concerns), and Republican vote count on the Banking Committee.
- Should compliance teams wait for passage to begin preparing?
- No. The requirements are defined. Build to the CLARITY Act standard now. If it passes, you are ready. If it does not, the SEC and CFTC will establish substantially similar requirements through their existing authority.
Relevant Articles
CLARITY Act Enters Final Sprint
The compromise that enabled markup readiness.
Apr 14, 2026
Treasury Secretary Bessent on Digital Asset Rules
Executive branch pressure for passage.
Apr 15, 2026
Senate Returns From Recess: CLARITY Act Markup Window Open
The opening of the final legislative window.
Apr 13, 2026
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