CFTC’s Tokenized Collateral Guidance: Integrating Blockchain into Derivatives Markets

December 15, 2025

On December 8, 2025, the Commodity Futures Trading Commission (“CFTC”) issued CFTC Letter No. 25-39 providing staff guidance on the use of tokenized assets as collateral in derivatives markets and CFTC Letter No. 25-40 instituting a pilot program allowing futures commission merchants to accept BTC, ETH, and payment stablecoins as collateral. The guidance directly impacts the regulatory framework applicable to futures commission merchants (“FCMs”), derivatives clearing organizations (“DCOs”), and swap dealers (“Swap Dealers”). The pilot program represents the most significant digital assets regulatory development since the enactment of the GENIUS Act.

CFTC’s Tokenized Collateral Guidance: Integrating Blockchain into Derivatives Markets