Key Takeaways:
- The SEC’s Division of Trading and Markets issued guidance on April 13, 2026, allowing crypto UI providers to skip broker-dealer registration if 12 conditions are met.
- The statement, set to expire April 13, 2031, signals SEC intent to clarify federal securities law for decentralized exchange front-ends and self-custodial wallets.
- Covered User Interface Providers must disclose fees, MEV risks, and conflicts of interest or risk falling outside the SEC’s no-action scope.
SEC Lets Crypto Interface Operators Skip Broker-Dealer Registration Under 12 Conditions
The statement targets what the SEC calls “Covered User Interface Providers,” a category that includes websites, browser extensions, and mobile apps designed to help users prepare and submit crypto asset securities transactions through self-custodial wallets.
These interfaces typically convert user-set transaction parameters, such as buy or sell direction, volume, asset type, and price range, into blockchain-readable commands. They may also display market data, estimated gas fees, and available execution routes. Providers generally charge a fixed percentage per transaction.
Under Section 15(a) of the Securities Exchange Act of 1934, any person in the business of effecting securities transactions for others is generally required to register as a broker. The SEC staff said in the statement that it will not object to a Covered User Interface Provider operating without that registration, provided the provider meets 12 specific conditions.
Those conditions cover how interfaces handle user customization, fee structures, execution routing, affiliated trading venues, and disclosure obligations. The provider must allow users to adjust default transaction settings and provide educational materials to support those decisions. The provider cannot solicit users into specific crypto securities transactions or offer investment advice.
On routing, if an interface displays only one execution path, users must be able to view alternatives. If multiple routes appear, the interface must offer objective sorting tools, such as by price or speed, without labeling any route as the “best” option.
Compensation must be limited to a fixed charge applied consistently across products, routes, venues, and counterparties. The fee cannot vary based on which trading venue is selected or which asset is involved.
Disclosure requirements are extensive. Providers must inform users that the operator is not registered with or regulated by the SEC in connection with the interface’s operation. They must also disclose all fees and their calculation methods, conflicts of interest, cybersecurity policies, data protection practices related to maximal extractable value strategies, and details about every connected trading venue or liquidity pool.
Any affiliated trading venues must be clearly identified, and the interface must connect to those venues on the same terms as any unaffiliated platform.
The statement also lists activities that remove a provider from its scope entirely. Operators who negotiate transaction terms, hold user funds, execute or settle trades, process trade documentation, or take and route orders are not covered by the staff’s no-action position.
The SEC said maintaining policies, procedures, and internal records, including the use of onchain transaction data alongside private books, could help providers demonstrate they are operating within the statement’s limits.
The staff said it welcomes public comments. Submissions can be filed electronically at rule-comments@sec.gov with “File Number 4-894” in the subject line. Absent any intervening action by the Commission, the statement will be considered withdrawn on April 13, 2031.
