SEC Staff Issues Statement On Broker-Dealer Registration For Crypto Asset Securities User Interfaces

On April 13, 2026, the Staff of the SEC's Division of Trading and Markets issued a statement clarifying that certain providers of front-end user interfaces (”Covered User Interface Providers”) — such as websites, browser extensions, and mobile applications — used to prepare user-initiated transactions in crypto asset securities will not be required to register as broker-dealers under Section 15(a) of the Exchange Act, provided they satisfy specified conditions.¹ The statement applies to interfaces that convert user-identified transaction parameters into blockchain-legible commands for signature and transmission via a user's self-custodial wallet.²

The statement notes that it “is not a rule, regulation, guidance, or statement of the Commission,” that the Commission has neither approved nor disapproved its content, and that it has “no legal force or effect.” Accordingly, the statement does not create binding precedent and could be withdrawn or modified by the Staff or superseded by future Commission action.

The statement is a shift from the prior administration’s approach to crypto asset regulation, which relied primarily on enforcement actions rather than forward-looking guidance to define the boundaries of broker-dealer registration requirements for crypto market participants. The current Commission, through its Crypto Task Force, has moved to provide regulatory clarity, and this statement is part of that effort.

The statement is expressly limited to circumstances where a Covered User Interface Provider: (i) permits users to customize default transaction parameters and provide educational materials to help users set those parameters; (ii) refrains from soliciting specific crypto asset securities transactions (as opposed to general marketing of the interface) ; (iii) limits compensation to fixed, objective, product- and route-agnostic charges paid solely by the user; (iv) uses only pre-disclosed, independently verifiable software parameters for preparing trading instructions and displaying market data; and (v) prominently discloses all material facts related to fees, conflicts of interest, cybersecurity policies, and integration with trading venues.

The statement does not extend to providers that negotiate transaction terms, make investment recommendations, hold or manage user funds or securities, execute or settle transactions, or take or route orders. It also does not apply to custodial wallet providers. The Staff has noted that this is an interim measure, and the statement will be considered withdrawn five years from its issuance absent further Commission action.³ The Staff is soliciting public comment on all aspects of the statement (File No. 4-894).

The statement leaves a number of issues unresolved. It is expressly limited to broker-dealer registration under Section 15(a) and does not address, among other things, the applicability of exchange or alternative trading system (ATS) registration requirements and the regulatory treatment of custodial wallet providers. Several of the conditions imposed — such as the requirement that compensation be “product, execution route, execution venue, and counterparty agnostic” and the prohibition on providing commentary characterizing execution routes — may be difficult to apply in practice.

Market participants operating or developing crypto asset user interfaces should evaluate whether their current or planned operations fall within the scope of permissible activities outlined in the statement. 

Footnotes

1 Securities Division of Trading and Markets April 13, 2026 The Staff of the Division of Trading and Markets ("Staff") of the Securities and Exchange Commission ("Commission") is issuing the following statement[1] to provide its views on the broker-dealer registration requirements under Section 15(a) of the Securities Exchange Act of 1934 ("Exchange Act") with respect to a person|[2] that creates, offers, and/or operates certain interfaces utilized by users to, among other things, prepare transactions in crypto asset securities[3] ("Covered User Interface Providers"). [4] This statement is part of an effort to provide greater clarity on the application of the (SEC.gov _ Staff Statement Regarding Bro...pdf)

2 crypto asset securities transactions. Specifically, it is the Staff's understanding that Covered User Interfaces prepare code enabling users to interact with blockchain protocols (or blockchain-based smart contracts) by converting user-identified crypto asset securities transaction parameters (e.g., buy/sell, volume, crypto asset security, and price or price range) into blockchain-legible commands for signature and transmission via the user's self-custodial wallet. [8] Covered User Interfaces may also provide users with market data, such as potential execution routes, asset prices, and estimated transaction costs (e.g., "gas" fees) for crypto asset securities transactions. Covered User Interface Providers generally charge users a fixed percentage (SEC.gov _ Staff Statement Regarding Bro...pdf, Page 1)

3 securities activities and the feedback it has received.[5] Accordingly, absent intervening action by the Commission, this statement will be considered withdrawn effective five years from April 13, 2026. For further information, please contact the Staff by emailing TradingAndMarkets@sec.gov. I. Covered User Interfaces For purposes of this statement, a "Covered User Interface" is an interface provided by a website, browser extension, or other software application (e.g., mobile application) that may be embedded in a wallet[6] or separately available for download, designed to assist users[7] engaging in user-initiated crypto asset securities transactions on blockchain protocols (or blockchain-based smart contracts) utilizing (SEC.gov _ Staff Statement Regarding Bro...pdf)