Summary:
- Vault structures are rapidly emerging as core onchain financial infrastructure. Total deposits have grown from $24 billion in April 2023 to $131 billion as of April 2026, with broader real-world asset applications expected to become the dominant use case.
- CCI’s Vault Coalition unites leading digital asset firms to produce rigorous legal and policy analysis and develop consensus-driven regulatory principles for the industry.
- Modeled on CCI’s historical work, including advancing staking clarity through POSA, the Coalition will provide grounded, substantive legal and policy analysis to help move regulators toward frameworks rooted in economic substance.
Today, the Crypto Council for Innovation launched its Vault Coalition, a focused industry effort to advance policy clarity and workable regulatory frameworks for emerging vault models. The Coalition is anchored by Galaxy and Morpho with participation from a16z, Avalanche Policy Coalition, BitGo, and Sharplink.
As background, a vault is a smart contract that pools deposited digital assets, puts them to work through a defined strategy and issues each depositor a vault receipt token representing their share of the pool.
The market is growing rapidly. Total deposits in vaults reached $131 billion as of April 2026, up from $24 billion in April 2023. Regulatory clarity is widely understood to be a critical catalyst for the next phase of that growth. As S&P Global Ratings noted in a recent primer on vault structures, experience with stablecoin regulation in the US shows that uncertainty restricts institutional participation, while clearer frameworks unlock capital. Today, regulatory ambiguity remains a barrier for vault strategies that resemble traditional financial intermediation and many institutional investors are avoiding direct participation in vault structures precisely because they cannot be certain which regulatory regime applies.
As institutional participation in digital assets continues to scale, firms face growing uncertainty around how vault structures are treated under existing rules, particularly involving questions of custody and control. SEC Chairman Paul Atkins stated at the Special Competitive Studies Project AI+ Expo that the US “should consider ways to provide clarity surrounding what are commonly referred to as ‘crypto vaults,’ particularly regarding Securities Act and Advisers Act touch-points.” The current uncertainty sits ahead of the legal and operational clarity firms need to participate and innovate responsibly. Resolving it is a precondition for the next phase of institutional adoption, especially as onchain vault services could give institutions an onramp to crypto markets.
The questions, while answerable, require careful, substantively rigorous, and technically informed analysis developed with direct input from the firms actually building and operating these structures. That is the work the Vault Coalition is built to do and will do.
CCI’s Vault Coalition brings together a select group of industry leaders to do the substantive work that closes that gap. The Coalition will produce legal analysis, develop policy principles drawn from how these structures actually operate, and engage directly with regulators on the basis of that work.
The Vault Coalition is organized around three core propositions:
- Regulatory treatment of vault structures should be grounded in how they actually function, not in analogies to incumbent financial products that do not map onto the underlying technology.
- The legal and regulatory questions surrounding vaults are answerable, but they require careful, technically informed analysis developed with direct input from the firms building and operating these structures.
- A shared, well-reasoned industry position is more useful to policymakers and to the market than firms making the case individually and produces better regulatory outcomes.
“Regulators benefit from precise, technically grounded input from industry when working through novel structures. The Vault Coalition exists to provide exactly that: rigorous legal and policy analysis developed by the firms with the deepest operational knowledge of how these structures actually work. That is the right foundation for regulatory clarity, and it is why CCI convened this effort.” – Ji Hun Kim, Chief Executive Officer, Crypto Council for Innovation.
“CCI has a track record of producing the kind of careful, substantive work that moves regulatory understanding forward. We did it for staking through POSA, and the Vault Coalition will apply that same discipline to a new set of questions. The goal is to give regulators a well-reasoned framework they can work from one grounded in how these structures actually operate, not how they superficially resemble existing products.” – Alison Mangiero, Chief Strategy Officer and Head of U.S. Policy, Crypto Council for Innovation.
“Galaxy sits at the intersection of traditional finance and digital assets, and we see firsthand where the friction is. For institutions, regulatory uncertainty around vault structures is not a theoretical concern, it is a threshold question that determines whether they can participate at all. Getting that answer right matters, and Galaxy is committed to doing the work to get there.” – Natalia Li, Head of Policy, Galaxy.
“We are at an inflection point. Institutional participants are prepared to deploy, but they require a clear legal roadmap to move forward. The Vault Coalition exists to transform industry expertise into the foundational standards the market demands. Morpho is committed to this work because we recognize that the path to maturity is built on legal clarity, not just code.” – Christopher Robins, General Counsel, Morpho.
Firms interested in participating in the Vault Coalition can contact CCI to learn more.
