CA-C-001450
Coinbase — Coinbase User Agreement
Entity
Date detected
April 28, 2026
Effective date
April 28, 2026
Severity
Low
Direction
Neutral
Affected users
all users users holding or using coinbase custom stablecoin
Changes
5 sentences modified
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Event Summary

Coinbase updated its User Agreement on April 28, 2026 to clarify punctuation in defined terms and expanded the scope of governed instruments to explicitly include Coinbase Custom Stablecoin alongside wrapped tokens. The change adds 'a Coinbase Custom Stablecoin' to the list of digital assets whose issuance, holding, or use triggers acceptance of the User Agreement. This expands which Coinbase-issued products are contractually governed by the same agreement terms.

LOW

Consumer Impact

The updated User Agreement now explicitly states that obtaining, holding, or using a Coinbase Custom Stablecoin triggers the same agreement acceptance as wrapped tokens previously did. The practical effect is that users of this new stablecoin product are contractually bound by the full terms of the User Agreement, including dispute resolution, limitations of liability, and other standard provisions. No new rights or obligations are introduced; the change clarifies that this stablecoin product falls under the existing agreement framework.

Governance Analysis

The updated language ensures that Coinbase Custom Stablecoin products are explicitly subject to the User Agreement framework, clarifying contractual governance for this new asset category. This eliminates any potential ambiguity about whether different Coinbase-issued instruments may be subject to different terms or policies.

Key Clauses Affected

Agreement scope and product coverage

Coinbase Custom Stablecoin now explicitly included alongside wrapped tokens as instruments whose issuance, holding, or use triggers User Agreement acceptance

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This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology

Evidence Verification

✓ Verified
Previous Version
ec3f715cd374d421902fdfa264d5cb729dade5dc82f051dcdbf43a1f49290017
April 19, 2026 06:04 UTC
✓ Verified
Current Version
083db31069404f7d973c08a8a61750b550e7a91fb44ab45db471ea8d3fc38ed9
April 28, 2026 06:03 UTC
✓ Verified
Change Detected
April 28, 2026 06:03 UTC
Analysis Methodology
Citation Record
Entity: Coinbase
Document: Coinbase User Agreement
Record ID: CA-C-001450
Captured: 2026-04-28 06:03:44 UTC
URL: https://conductatlas.com/change/2026-04-28-coinbase-coinbase-user-agreement-1450/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

This change expands the contractual scope of the User Agreement to explicitly cover a new product category (Coinbase Custom Stablecoin) alongside existing wrapped tokens. The change itself is procedural and clarifying rather than substantive—it ensures that new stablecoin products are clearly governed by the same terms users accept when opening Coinbase accounts. No new regulatory obligations appear to be created by this language addition. However, organizations using this platform should verify that their vendor risk assessments and DPA scoping cover any new Coinbase-issued instruments they support or process.

Regulatory Exposure

FinCEN (if stablecoins are treated as money transmitter or payment instruments); SEC (if stablecoin issuance involves securities law implications); state money transmitter regulators; FINRA (if offered in brokerage context). Regulatory treatment of stablecoins remains unsettled; this change does not itself alter regulatory classification but makes contractual scope explicit.

Full compliance analysis

Obligation analysis, escalation trigger, board language, and recommended action.

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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-001450.

Full Changes

See the full side-by-side comparison of every sentence added, removed, and modified.

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Document Context

Version history → Policy drift analysis → Document page →
Document
Coinbase User Agreement
Entity
Coinbase
Captured
April 28, 2026
Source URL
https://www.coinbase.com/legal/user_agreement/united_states
Other changes to Coinbase User Agreement
Previous change Apr 19, 2026
Coinbase updated its Individual User Agreement on April 19, 2026 to add Connecticut-specific disclosures about virtual currency risks. The new …
Medium Positive
Next change May 1, 2026
Coinbase updated its User Agreement on May 1, 2026 to explicitly permit the transfer of digital assets to third parties …
Medium Negative
View full version history →
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