On December 8, 2025, the U.S. Commodity Futures Trading Commission launched a pilot program that permits selected digital assets to serve as collateral in derivatives markets, formally opening a regulated route for crypto as collateral. The pilot authorizes Bitcoin (BTC), Ether (ETH) and USDC as margin collateral under a three‑month, monitored no‑action period for participating Futures Commission Merchants (FCMs). The initiative focuses on data collection and operational safeguards to inform potential broader rulemaking.
Pilot design and operational requirements
The program grants FCMs temporary permission to accept BTC, ETH and USDC as customer margin for futures and swaps during an initial three‑month phase. FCMs, the broker‑dealers that clear and handle customer margin for futures, are the only permitted participants in this pilot. Participants operate under a CFTC no‑action position while subject to mandatory weekly reporting to support intensive monitoring of liquidity, settlement mechanics and operational risk.
Regulatory context, legal framing and market implications
The CFTC withdrew Staff Advisory 20‑34 as part of this initiative, removing an older constraint on virtual asset collateral and signalling a technology‑neutral assessment of tokenized assets. The agency invited public comment on tokenized collateral, including stablecoins and tokenized money market funds, with a comment deadline set for October 20, 2025. The regulator frames the pilot as an empirical exercise to collect real‑world data before broader rulemaking, underscored by a brief statement: “Today’s announcement marks a significant milestone in the expanded adoption of digital assets in regulated markets”, the Commission said.
The pilot responds to high‑level recommendations to clarify treatment of tokenized non‑cash collateral and builds on the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), which it references for stablecoin issuer obligations. Under that legislative framework, stablecoin issuers are expected to maintain 1:1 reserves in high‑quality assets, a condition the CFTC cites as central to integrating payment stablecoins into regulated markets. The pilot is also presented as a potential input to subsequent legislative and regulatory work, including efforts to harmonize oversight across agencies and proposals such as the Digital Commodities Consumer Protection Act.
If maintained or expanded, the pilot could change operational profiles for treasuries, custodians and VASP‑like market intermediaries by enabling near‑continuous collateral movements and more dynamic collateral management. The CFTC emphasises monitoring for systemic and operational risks; weekly reporting is intended to surface liquidity stress, settlement failures and custody shortfalls early. Key practical considerations for participants include segregated custody arrangements, robust record retention, clear valuation and liquidation protocols for volatile token collateral, and enhanced audit trails to meet existing compliance obligations. The pilot’s focus on a narrow set of assets reflects a cautious approach to limit concentration and liquidity risk while testing 24/7 settlement dynamics against traditional market infrastructure.
The pilot establishes a controlled environment to test crypto as collateral and to gather evidence for future rulemaking. Its immediate implication is operational: FCMs must implement reporting and custody procedures for BTC, ETH and USDC; the broader outcome will depend on data collected during the three‑month window. Next verified milestone: public comments are due by October 20, 2025, and the CFTC will use pilot reports to inform subsequent regulatory decisions.
