Blockchain Legal Resource

On April 13, 2026, staff in the US Securities and Exchange Commission (SEC) Division of Trading and Markets issued a Staff Statement Regarding Broker-Dealer Registration of Certain User Interfaces Utilized to Prepare Transactions in Crypto Asset Securities. Absent further action by the SEC, the statement will be considered withdrawn five years from the date of issuance.

For purposes of the 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 or separately available for download, designed to assist users engaging in user-initiated crypto asset securities transactions on blockchain protocols (or blockchain-based smart contracts) utilizing the user’s self-custodial wallet. In the past, there has been some uncertainty whether developers or operators of Covered User Interfaces transacting in crypto asset securities would be deemed brokers in securities that must register with the SEC.

The statement provides that persons who create, offer, or operate Covered User Interfaces need not register as a broker-dealer with the SEC so long as they satisfy over 20 separate conditions delineated in the statement. The statement also notes that it does not extend to a Covered User Interface provider that engages in, or holds itself out as, providing any of the following services with respect to securities, including crypto asset securities:

• negotiating terms for any transaction;
• solicitating specific crypto asset securities transactions;
• making investment recommendations or providing advice;
• arranging for financing;
• processing trade documentation;
• conducting independent asset valuations;
• holding, having access to, handling, managing, or possessing user funds, securities, or stablecoins;
• executing or settling transactions; or
• taking or routing orders.

SEC Commissioner Hester Peirce also issued a public statement commending the SEC staff for taking this action, but expressing her preference that the SEC engage in a more comprehensive review of its interpretations of the broker-dealer definition through formal rulemaking.