WASHINGTON, April 13, 2026 — The staff of the U.S. Securities and Exchange Commission’s Division of Trading and Markets said certain providers of user interfaces used to prepare transactions in crypto asset securities could create, offer, or operate those interfaces without registering as broker-dealers, provided they satisfy a detailed set of conditions. The statement was issued on April 13 and was expressly framed as a staff view rather than a rule, regulation, or Commission-level statement.
The staff said the statement was intended to provide greater clarity on the application of federal securities laws to activities involving crypto asset securities while the Commission continues to consider broader regulatory questions in the sector. It also said that, absent intervening Commission action, the statement will be considered withdrawn effective five years from April 13, 2026.
Conditions for operating without broker-dealer registration
The statement applies to certain “Covered User Interfaces,” which the staff defined as interfaces provided through websites, browser extensions, or other software applications, including those embedded in or used alongside self-custodial wallets, that assist users in user-initiated crypto asset securities transactions on blockchain protocols or smart contracts.
According to the staff, such interfaces may convert user-selected transaction parameters into blockchain-readable commands for signature and transmission through a user’s self-custodial wallet, and may also display market data such as prices, potential execution routes, and estimated transaction costs.
Under the staff’s view, a Covered User Interface provider may operate without broker-dealer registration if, among other things, users can customize default transaction parameters, the provider does not solicit investors to engage in specific crypto asset securities transactions, and routing-related functions rely on pre-disclosed, objective, and independently verifiable parameters.
The staff also said compensation tied to the interface must be limited to fixed, consistently applied charges that are product-, venue-, route-, and counterparty-agnostic.
Disclosures, controls, and limits on the staff position
The staff further said providers relying on the statement should maintain policies, procedures, and controls to evaluate trading venues and distributed ledger trading systems using objective factors, and should prominently disclose material information to users.
Those disclosures include the provider’s role, fees, conflicts of interest, limitations on use, software parameters used for routing-related functions, cybersecurity controls, protections for trading information, integrations with venues or distributed ledger systems, and any default transaction parameters together with associated risks and conflicts.
At the same time, the statement drew clear limits around the activities it does not cover. The staff said the position does not extend to providers that negotiate transaction terms, solicit specific transactions, provide investment advice or recommendations, arrange financing, process trade documentation, conduct independent asset valuations, hold or access user funds or securities, execute or settle transactions, or take or route orders. It also said the statement does not address custodial wallets held on behalf of investors.
The document states that it has no legal force or effect and does not alter or amend applicable law or create new obligations. Instead, it represents how staff would view the broker-dealer registration requirements under Section 15 of the Securities Exchange Act of 1934 in the specific circumstances described.
Broader clarity is still needed
SEC Commissioner Hester Peirce, in a separate statement published the same day, said the statement was a positive step while indicating that a more durable regulatory approach would still be needed. Her statement underscored that the Division of Trading and Markets document addresses only a limited set of facts and only one aspect of the federal securities law framework.
