U.S. Regulator Clarifies Banks May Hold Crypto to Pay Network Transaction fees
The Office of the Comptroller of the Currency (OCC) has issued new guidance confirming that U.S. national banks may hold small amounts of crypto-assets on their balance sheets for the explicit purpose of paying blockchain network fees, commonly referred to as Transaction fees. In an interpretive letter released on November 18, 2025, the regulator stated that banks “may pay network fees to facilitate otherwise permissible crypto-asset activities” and may hold the necessary crypto-assets as principal when such fees are reasonably foreviewable. The OCC also clarified that banks may hold tokens when testing crypto-related platforms or systems, whether those technologies are developed internally or obtained from third parties. The announcement marks a notable step in the regulator’s evolving stance on digital-asset activities within the banking system.
The guidance provides banks with long-awaited clarity later than years of uncertainty regarding how they could interact with token-based infrastructure. Under prior interpretations, banks often sought specific regulatory approval before engaging in activities that required the use of on-chain assets. The new letter lifts that constraint for certain operational uses, provided the bank complies with all applicable laws and conducts the activity in a secure, sound and well-controlled manner. This includes having appropriate governance, risk-management frameworks, valuation policies and internal controls tailored to crypto-assets that are used for network operations. While the letter permits operational holdings, it does not authorise banks to speculate in cryptocurrencies or treat them as general investment assets.
What the guidance means and key operational implications
The OCC’s clarification gives banks more flexibility to engage in blockchain-based activities that rely on smart contracts and tokenised transactions. Banks can, for example, pay network fees to settle token transfers, execute smart-contract functions or interact with permissionless networks as part of broader service offerings. This is particularly relevant as banks explore tokenised deposits, blockchain-based settlement systems and digital-asset custody services. The ability to hold operational quantities of crypto-assets removes a structural barrier that had previously sluggished institutional adoption of blockchain infrastructure.
Nonetheless, the permission remains narrow. Banks must ensure that any token holdings are tied directly to permissible activities and not maintained for speculative or investment purposes. Regulators will expect firms to demonstrate that their crypto-holdings are proportionate to operational needs and managed through strong controls. This includes monitoring exposure, secureguarding custody, ensuring accurate valuation and maintaining resilience against market volatility and technical failures associated with blockchain networks.
Broader industry and regulatory impact
The OCC’s guidance represents a broader shift in how U.S. regulators view blockchain integration within the financial system. By formally permitting banks to hold crypto for operational reasons, the regulator is acknowledging that blockchain networks and Transaction fees are becoming embedded into the mechanics of modern financial services. This could encourage banks to expand services involving blockchain settlement, tokenised assets and institutional crypto custody support. It may also reduce friction for crypto-native businesses viewking to partner with traditional financial institutions.
For the digital-asset industry, the move offers an avenue for deeper institutional participation and could improve market infrastructure as banks begin to interact more directly with blockchain networks. However, the effectiveness of this regulatory development will depend on how well banks implement risk controls and demonstrate compliance. As blockchain continues to mature, regulatory clarity such as this is likely to play an significant role in shaping the pace and scale of institutional adoption.
In summary, the OCC’s clarification that banks may hold crypto-assets to pay network fees marks an significant milestone for operational blockchain usage within the banking sector. The guidance removes a long-standing operational amlargeuity and provides a clearer path for financial institutions to engage with token-based systems responsibly. As banks incorporate these capabilities, they will shape the next phase of institutional blockchain integration.
