Department of Financial Services Superintendent Benjamin Lawsky reportedly stated in a speech that the DFS is considering creating a special transitional BitLicense that would allow virtual currency startups meeting certain criteria to operate within a more flexible regulatory framework while their full BitLicense application is under examination. Lawsky indicated that a revised BitLicense proposal will soon be made available for public comment and that a final version will be released next January.

Lawsky reportedly also stated at separate events that the proposed BitLicense regulations are not intended to cover “blockchain 2.0” platforms, even though small amounts of digital currency may be transmitted along with non-currency information or value in connection with blockchain 2.0 transactions. However, he indicated that the DFS is still “working out how to address” the issue.