Regulation · Regime · United States · Guidance · Commodity Futures Trading Commission
CFTC tokenised collateral and digital-asset margin framework (staff guidance and pilot programme)Updated 14 Oct 2026
CFTC staff guidance and no-action relief that let derivatives firms use tokenised real-world assets such as Treasuries and money market fund shares, and certain digital assets including payment stablecoins, as collateral. The rules are treated as technology neutral, with each tokenised asset assessed case by case. A pilot lets futures commission merchants accept bitcoin, ether and USDC as customer margin, and an older advisory restricting this was withdrawn.
In force · effective 8 Dec 2025
Key points
- Tokenised real-world assets such as US Treasuries and money market funds can be used as collateral if firms assess eligibility, legal enforceability, segregation, custody and control, haircuts, valuation and operational risk case by case.[1]
- FCMs may accept non-securities digital assets, including payment stablecoins, as customer margin under no-action relief; for the first three months only BTC, ETH and USDC, with weekly reporting.[1]
- Staff FAQs (March 2026, updated September 2026) explain how registrants may invest customer funds in tokenised forms of permitted investments and use blockchain records to meet recordkeeping rules.[2]
What it covers
Debt securityFund interestStablecoinCCP marginCollateral mobility
Timeline
- 8 Dec 2025 · In forceStaff Letters 25-39 (guidance) and 25-40 (no-action) issued; Staff Advisory 20-34 withdrawn.[1]
- 6 Feb 2026 · AmendedLetter 25-40 reissued (as Letter 26-05) so a national trust bank can be a permitted payment stablecoin issuer for the relief.[3]
- 20 Mar 2026 · AmendedStaff publish FAQs on the tokenised collateral guidance and the digital asset margin no-action position.[2]
- 24 Sep 2026 · AmendedFAQs updated to cover investing customer funds in tokenised permitted investments and blockchain recordkeeping.[2]
Instruments
- CFTC Staff Letter 25-39: guidance on tokenised collateral in derivatives marketsGuidance · In force · 8 Dec 2025
- CFTC Staff Letter 25-40 (reissued as 26-05): no-action position for FCMs accepting digital assets and payment stablecoins as marginNo-action relief · In force · 8 Dec 2025
Deployments operating under it
None recorded with a source yet.
Likely relevant to
| Deployment | Status | Assets | Use cases | Last reviewed |
|---|---|---|---|---|
| BNY and Goldman Sachs tokenised money market fund shares (LiquidityDirect and GS DAP)Updated 18 Oct 2026 BNY | Live (limited) | Reviewed 13d ago | ||
| Canton Network on-chain US Treasury financing (industry working group)Updated 18 Oct 2026 Digital Asset Canton applications | Pilot | Reviewed 11d ago | ||
| Decibel usDCBL exchange stablecoinNew Open Issuance | Live (limited) | Reviewed 17d ago | ||
| DTCC Collateral AppChain (tokenised real-time collateral management)Updated 6 Nov 2026 DTCC ComposerX | Proof of concept | Reviewed today | ||
| DTCC Tokenization ServiceUpdated 7 Nov 2026 DTCC ComposerX | Live (limited) | Reviewed 1d ago | ||
| Kinexys Tokenized Collateral Network (TCN)Updated 28 Oct 2026 Kinexys Digital Assets | Live (limited) | Reviewed 13d ago | ||
| Société Générale tokenised collateral, repo and CoinVertible on Canton Digital Asset Canton applications | Announced | Reviewed today |
Sources
- [1]Acting Chairman Pham Announces Launch of Digital Assets Pilot Program for Tokenized Collateral in Derivatives Markets — Commodity Futures Trading Commission, 8 Dec 2025. Accessed 12 Oct 2026.A
- [2]CFTC Staff Releases Updates to FAQs Concerning Registrants and Registered Entity Activities Relating to Crypto Assets and Blockchain Technologies — Commodity Futures Trading Commission, 24 Sep 2026. Accessed 14 Oct 2026.A
- [3]CFTC Staff Reissues Letter 25-40 Updating Payment Stablecoin Definition — Commodity Futures Trading Commission, 6 Feb 2026. Accessed 12 Oct 2026.A