#ETF关注 #美SEC加密圆桌会议 #美SEC澄清PoW挖矿监管立场
On March 20, 2025, the U.S. Securities and Exchange Commission (SEC) issued a statement clarifying that cryptocurrency mining activities using the proof of work (PoW) mechanism do not involve U.S. securities laws. This statement provides a legal basis for future ETF approvals of PoW tokens (such as Litecoin), reducing compliance barriers. The SEC's analysis was based on the Howey Test, which determined that PoW miners' earnings come from their own computational power contributions rather than third-party business activities, thus not fitting the definition of an investment contract. This decision may bolster confidence in the mining industry and delineate a clear survival space for the PoW ecosystem. Furthermore, the SEC's regulatory shift also marks a new paradigm in U.S. crypto governance, transitioning from law enforcement deterrence to co-creation of rules.
Regulatory breakthrough: SEC's historic ruling reshapes the industry landscape
On March 20, 2025, the U.S. Securities and Exchange Commission (SEC) issued a statement clarifying that cryptocurrency mining activities using the proof of work (PoW) mechanism do not involve U.S. securities laws.
This statement may provide a legal basis for future ETF approvals of PoW tokens (such as Litecoin), reducing compliance barriers. It reveals a significant shift in regulatory logic:
The SEC's Financial Department indicated that PoW mining, including independent and pool mining, does not meet the definition of 'securities' under the (1933 Securities Act) and (1934 Securities Exchange Act), and therefore does not need to be registered. The SEC emphasized that the rewards miners receive come entirely from their own computational resource contributions, rather than 'relying on the management or operation of others'.
The SEC's analysis was based on the Howey Test, which determined that PoW miners' earnings come from their own computational power contributions rather than third-party business activities, thus not fitting the definition of an 'investment contract'. Even if miners join a mining pool, the SEC believes that miners still compete for rewards through their own computational resources rather than relying on pool operators' management.
The SEC holds that the role of pool operators is primarily 'administrative management' rather than investment management. Even if operators coordinate miners' computational power, manage hardware, and distribute rewards, these actions do not satisfy the core element of 'efforts of others' in the Howey Test. The SEC determined that PoW mining is unrelated to the regulatory requirements of securities law.
If mining activities are considered securities, miners may be required to register with the SEC and comply with securities regulations, increasing operational costs and potentially driving smaller miners out of the market. Exchanges may not be able to freely list PoW tokens, and participation of institutional investors may be restricted.
The SEC's clear distinction between PoW and PoS regulatory logic may indicate its special positioning of PoW networks and could pave the way for future PoW cryptocurrency ETFs (like Dogecoin ETFs). This 'technologically neutral' statement delineates a clear survival space for the PoW ecosystem.
Regulatory shift and Ethereum's paradigm revolution: the regulatory shock from PoW to PoS
Historically, Ethereum's consensus mechanism transition is considered the most radical 'self-disruption' in crypto history. As the second-largest blockchain network by market capitalization, Ethereum initially operated on a proof of work (PoW) mechanism, where miners competed for ETH rewards through computational power. However, due to the energy consumption controversies and efficiency bottlenecks arising from ecosystem expansion, its development team began planning a transition to proof of stake (PoS) in 2018. This concept finally became a reality on September 15, 2022—through the 'Merge' technological upgrade, Ethereum's mainnet and beacon chain completed their integration, completely abandoning the PoW mechanism and becoming a PoS chain that relies entirely on validators staking tokens.
However, after the transition, although Ethereum's energy consumption plummeted by 99.95%, the annual inflation rate has not been effectively reduced. With the exhaustion of the ecosystem and the gradual increase in inflation, Ethereum's price has also been consistently suppressed.
In the two years following Ethereum's PoS upgrade, this coincided with the tough policy cycle of former SEC Chairman Gary Gensler, during which staking services became a primary target for enforcement.
The SEC believes that staking services offered by exchanges like Coinbase and Kraken essentially constitute 'unregistered securities issuance', as their earnings depend on platform operations rather than user-initiated validation. In 2023, the SEC initiated 46 enforcement actions against cryptocurrencies, imposing a total of $2.89 billion in fines, with Coinbase being fined $50 million for its staking operations, and Kraken paying a $30 million settlement. Gary even characterized the crypto industry as 'a wild west rife with fraud', advocating for comprehensive regulation of staking, lending, and other activities under the securities law framework.
Regulatory pressure saw a dramatic reversal after Trump's victory in 2024. New SEC Chairman Paul Atkins quickly adjusted strategies: during his first week in office in January 2025, he established a special crypto task force, withdrew lawsuits against companies like Coinbase and Kraken, and ended investigations into OpenSea and Uniswap. In March, he even abolished the controversial accounting policy SAB 121, allowing banks to custody crypto assets.
This means that regulatory logic has shifted from 'law enforcement deterrence' to 'co-creation of rules', marking a new paradigm in U.S. crypto governance entering the 'Trump cycle'.
PoW Revival: The undervalued value network is undergoing revaluation
Stimulated by favorable SEC policies, the underlying value logic of PoW tokens is being re-evaluated by the market:
1. The ultimate bastion against regulation
The PoW mechanism builds trust through physical computational power competition, with a level of decentralization far exceeding that of PoS chains reliant on staked tokens. For instance, although Dogecoin employs a hybrid mining mechanism bound to Litecoin, its global miner distribution spans 68 countries, with the top ten mining pools accounting for less than 35% of total computational power, creating a natural censorship-resistant network. This characteristic highlights its value during geopolitical turmoil: during the 2024 Russia-Ukraine conflict, the cross-border payment volume completed via Dogecoin surged by 420%.
2. Litecoin's 'payment layer' breakthrough
With faster block times and low transaction fees, LTC is expected to replace some stablecoin functions in cross-border payments. Litecoin's halving cycle (reducing output by 50% every four years) effectively creates a differentiated scarcity model. LTC welcomed its third halving in August 2023, and historical data shows that its price increased by over 150% in the 18 months following the halving.
3. Dogecoin's 'cultural symbol'
The mild inflation characteristic of DOGE (annual increase of 5 billion coins) makes it more suitable as 'crypto change' for small payments. In 2024, its on-chain daily transaction count reached 3.2 times that of Bitcoin, and the cultural value of DOGE's community far exceeds its technical value. After the SEC alleviated compliance risks, along with the increase in celebrity effects and retail sentiment, coupled with ETF expectations, it may be favored by long-term institutional funds.
Perhaps as the Coinbase report states: Dogecoin's best destiny is to become the 'Disney token' of the blockchain world—used for tipping, charity, and fan economy.
Please note that Disney's current market capitalization is $180 billion, while Dogecoin's market capitalization is $25 billion.
4. The unexpected beneficiaries of energy transition
Although PoW has long been criticized for high energy consumption, recent data shows that the global renewable energy usage rate in Bitcoin mining has reached 58%. In North America, the 'stranded energy mining' model formed due to excess shale gas has instead become a regulator of grid balance. SpaceX, under Elon Musk, even announced in early 2025 that it would use Starlink satellites to deliver solar energy to remote mining sites, which may signal that PoW will be deeply tied to clean energy.
Reflecting on the past four years in crypto: Why did new projects collectively abandon PoW?
Among the top 100 crypto projects born between 2021 and 2025, the proportion using pure PoW mechanisms is less than 5%, far below the 62% in 2017. The decline of this 'classical mechanism' is essentially the result of a triple interplay of technological evolution, capital preferences, and user demands:
1. Efficiency dilemmas and the modular wave
The throughput ceiling of PoW chains (Bitcoin 7 TPS, Dogecoin 33 TPS) struggles to meet the demands of modern Web3 applications. In contrast, new generation Layer 1s like Sui and Aptos achieve tens of thousands of TPS through technologies like parallel processing, and the transaction density of DeFi and GameFi applications in their ecosystems is a thousand times that of PoW chains. More importantly, modular blockchains (like Celestia) decouple the execution layer from the consensus layer, allowing developers to quickly build application chains based on standardized components. This 'Lego-like' trend stands in stark contrast to the rigid structure of PoW.
2. The capital game: VCs need control
In PoS mechanisms, project teams control governance rights through token presales, team reserves, and other designs, which aligns perfectly with the interests of risk capital. Data shows that among projects raising over $10 million in 2024, 87% adopted PoS or hybrid consensus, with venture capital firms averaging a 15% token share and board seats. In contrast, PoW projects have a dispersed miner community with strong anti-fork capacity, making it difficult for capital to exert influence—this is the fundamental reason why Wall Street abandoned 'classical mining'.
3. The 'rebellion' of retail investors and the shift to speculation
The explosion of Memecoins reveals profound changes in market structure: a new generation of investors focuses more on community revelry and short-term arbitrage rather than underlying technological faith. Although DOGE is a PoW coin, 90% of its market cap growth comes from Elon Musk's tweets and retail FOMO, having little to do with the mining mechanism. As 'Shiba Inu Coin' can create a hundredfold myth through presales and exchange listings, the time and energy-consuming PoW mining naturally loses its allure.
Conclusion: The 'fractal evolution' of the crypto world
The regulatory unblocking of PoW is akin to the classical revival in the digital age. While the industry revels in the euphoria of 'Bitcoin ETF approval' and 'mining stocks soaring', it should remain sober in recognizing that the revolutionary nature of cryptocurrency lies not in replicating gold, but in creating an entirely new paradigm of value interaction.
The future winners may be those hybrid protocols that can inherit the censorship-resistant genes of PoW while integrating new paradigms like modularity and AI agents. Just as Satoshi Nakamoto inscribed in the genesis block, 'The Times 03/Jan/2009 Chancellor on brink of second bailout for banks', true disruption always comes from deconstructing the old system and imagining a new order.
PoW will not disappear, but it must learn to seek new life in a 'limited ecological niche'—this may be the most brutal yet fascinating survival rule in the crypto world.