The CFTC launched a supervised pilot, effective December 2025, that permits a limited set of digital assets to be used as customer margin collateral in U.S. derivatives markets, opening a controlled route for crypto as collateral. The pilot names Bitcoin, Ethereum andUSDC as eligible assets and frames near-real-time margin settlement and enhanced custody oversight as primary objectives.
Pilot mechanics and eligible participants
The program allows approved futures commission merchants (FCMs) to accept BTC, ETH and USDC as customer margin under strict conditions. An FCM is a broker-dealer that handles customer futures and options orders and margin; in this context, participation requires demonstrable operational readiness and compliance capabilities.
Participating firms will face rigorous reporting obligations, including weekly disclosures of total customer holdings and prompt notification of significant operational incidents involving digital-asset collateral. The pilot is explicitly designed to test whether tokenized collateral can reduce settlement frictions and enable faster margining compared with legacy processes.
Regulatory purpose, jurisdictional implications and risk framework
The initiative is positioned as a practical experiment to assess supervision of crypto-linked collateral while asserting the agency’s role over commodities-classified digital assets. The pilot aligns with concurrent legislative efforts to define regulatory authority, referencing the Financial Innovation and Technology for the 21st Century Act (FIT21) and the Lummis‑Gillibrand Responsible Financial Innovation Act (RFIA) as part of the broader effort to clarify market oversight. The move also addresses the operational realities of 24/7 global trading by exploring surveillance and reporting frameworks adapted to continuous markets.
Designers of the pilot single out several risk vectors that the program must monitor. Price volatility poses collateral valuation challenges; custody breaches and smart‑contract failures represent operational hazards; and liquidity concentration could impair orderly margining during stress. The pilot seeks to measure whether enhanced custody standards and near‑real‑time settlement can materially reduce counterparty and settlement risk relative to existing collateral arrangements. It will also test whether liquidity in the selected assets is sufficient to support margin calls without creating excessive market impact.
The pilot is a staged effort to collect operational and market data on using crypto as collateral while strengthening custody and reporting standards; its practical outcome will hinge on the performance of enrolled FCMs and the pilot’s surveillance metrics. Next verified milestone: the onboarding of approved FCMs and the submission of the first weekly customer‑holdings reports, which will provide the initial empirical basis for any expansion or formal rulemaking.