CA-C-000688
Coinbase — Coinbase User Agreement
Entity
Date detected
April 28, 2026
Effective date
April 28, 2026
Severity
Low
Direction
Neutral
Affected users
all users us users
Taxonomy
Consent expansion
Changes
5 sentences modified
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What Changed

Coinbase updated their User Agreement on April 28, 2026, making mostly formatting adjustments to how quoted terms are displayed (removing extra spaces around quotation marks). More notably, the agreement now explicitly covers 'Coinbase Custom Stablecoin' alongside wrapped tokens, meaning users who obtain, hold, or use these new stablecoins are also bound by the agreement. This expansion of scope is worth noting for users who interact with Coinbase-issued stablecoins.

Consumer Impact (what this means for users)

Coinbase's updated User Agreement now explicitly states that obtaining, holding, or using a 'Coinbase Custom Stablecoin' — not just wrapped tokens — binds you to the full terms of the agreement. The remaining changes are purely cosmetic formatting corrections with no effect on your rights. If you use or plan to use Coinbase Custom Stablecoins, you should review the full User Agreement to understand the obligations that apply to you.

Obligation Changes (what shifted)

1
New obligations
Consumers Added

If you use Coinbase's new Custom Stablecoin product, you are automatically agreeing to all of Coinbase's terms and conditions.

Applicable regulations

CCPA/CPRA
California, USA
CFAA
United States Federal
CAN-SPAM
United States Federal
FCRA
United States Federal
GDPR
European Union
GLBA
United States Federal
TCPA
United States Federal
UK GDPR
United Kingdom

Why It Matters (compliance & risk perspective)

The addition of 'Coinbase Custom Stablecoin' signals a new product rollout and means users of that product are automatically subject to Coinbase's full terms. Users considering holding or using Coinbase stablecoins should be aware they are entering a binding legal agreement.

Key Clauses Affected

Scope of Agreement Acceptance

The agreement now explicitly binds users who obtain, hold, or use a 'Coinbase Custom Stablecoin,' expanding the product categories covered by the terms.

Defined Terms Formatting

Extra spaces around quoted defined terms (e.g., 'User,' 'Coinbase,' 'Agreement') were removed — a cosmetic correction with no substantive legal effect.

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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
How to Cite
ConductAtlas Policy Archive
Entity: Coinbase | Document: Coinbase User Agreement | Record: CA-C-000688
Captured: 2026-04-28 06:03:44 UTC
URL: https://conductatlas.com/change/2026-04-28-coinbase-coinbase-user-agreement-688/
Accessed: May 2, 2026

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Institutional Analysis (Compliance & legal intelligence)

Assessment

Coinbase amended its Individual User Agreement on April 28, 2026, primarily making cosmetic formatting corrections (removing extraneous spaces in quoted defined terms) but also expanding the scope of agreement acceptance to include 'Coinbase Custom Stablecoin' issued by Coinbase, alongside the previously listed wrapped tokens. This touches consumer contract formation and the scope of binding terms. The stablecoin addition may implicate money transmission, e-money, or payment instrument regulatory frameworks depending on jurisdiction. Compliance teams at fintechs or neobanks that integrate Coinbase services should note this product category expansion and assess whether it affects their own customer disclosures or vendor agreements. Low urgency but warrants a flag for any team tracking Coinbase's stablecoin product rollout.

Regulatory Exposure

1. FinCEN / Bank Secrecy Act (31 U.S.C. § 5311 et seq.) — Coinbase Custom Stablecoins may qualify as value that substitutes for currency; money services business obligations could attach to users or intermediaries.

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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-000688.

Full Changes

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

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Document Context

Document
Coinbase User Agreement
Entity
Coinbase
Captured
April 28, 2026
Source URL
https://www.coinbase.com/legal/user_agreement/united_states
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