Change record
CA-C-001505
Coinbase User Agreement
Entity
Date detected
May 1, 2026
Effective date
May 1, 2026
Severity
Direction
Negative
Taxonomy
Rights removal
Changes
+51 sentences added · 34 sentences modified

Impact Summary

Medium Negative for users
Affected users
All users Users interested in Coinbase One Card US users

Coinbase updated its User Agreement on May 1, 2026 to explicitly permit the transfer of digital assets to third parties under a new 'Secured USDC' feature tied to the Coinbase One Card. Previously, the terms stated assets would not be transferred except as required by law or per user instruction. The updated language now establishes three exceptions: law-mandated transfers, user instructions, and transfers of USDC designated as 'Secured USDC' pursuant to a separate cardholder agreement. Users who designate USDC as secured agree they cannot withdraw or transfer those funds and that Coinbase may follow third-party instructions without further user consent.

1 new obligation 1 obligation expanded

Consumers: If you opt into the Secured USDC feature, you lose the ability to withdraw or move that money, and Coinbase can follow orders from a third party without asking you first.

Consumers: Coinbase now has explicit permission to move some of your USDC to a third party if you enroll in their Secured USDC card program.

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What this means for you

The updated terms establish a new exception to the prior prohibition on transferring user digital assets. Previously, Coinbase stated it would not transfer assets except as required by law or per user instruction. The revised language now permits Coinbase to transfer USDC designated as 'Secured USDC' to third parties pursuant to a Coinbase One Card cardholder agreement. Users who elect to use this feature agree they will be restricted from withdrawing or transferring the secured portion, and they consent to Coinbase following instructions from a designated secured party without further user approval, even if those instructions conflict with the user's own orders to Coinbase. The full terms of this arrangement are stated to be in Appendix 4, which is not included in this summary.

What you can do

→ Review Appendix 4 (Coinbase One Card with Security Deposit Cardholder Agreement) before designating any USDC as Secured USDC to understand the withdrawal restrictions and third-party instruction terms.

→ Confirm whether you intend to use the Coinbase One Card Secured USDC feature or prefer to maintain unrestricted withdrawal rights over your assets.

Historical Context

This is the 2nd significant Rights Removal change Coinbase has made since ConductAtlas began monitoring.

ConductAtlas has recorded 3 material changes to this document over 55 days of monitoring (since March 2026). An additional minor or cosmetic changes were excluded.

2 of Coinbase's significant changes have been classified as negative for consumers.

Key Clauses Affected

Secured USDC transfer exception

Added explicit authority for Coinbase to transfer USDC to third parties when designated as Secured USDC under a cardholder agreement, overriding the prior prohibition on asset transfers absent law or user instruction.

Third-party instruction compliance

New provision stating Coinbase may comply with third-party instructions for Secured USDC without user consent and without regard to conflicting user instructions.

Secured USDC withdrawal restriction

New provision establishing that users designated USDC as secured accept restriction from any withdrawals or transfers of that amount.

Full clause-by-clause analysis available with Insight.
ⓘ

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
083db31069404f7d973c08a8a61750b550e7a91fb44ab45db471ea8d3fc38ed9
April 28, 2026 06:03 UTC
✓ Verified
Current Version
d823322f18d74ef5482c915d5c3edf9bcc42d7ab91e1053bfc2ac18813db612d
May 1, 2026 06:02 UTC
✓ Verified
Change Detected
May 1, 2026 06:02 UTC
✓
Analysis Methodology
Citation Record
Entity: Coinbase
Document: Coinbase User Agreement
Record ID: CA-C-001505
Captured: 2026-05-01 06:02:04 UTC
URL: https://conductatlas.com/change/2026-05-01-coinbase-coinbase-user-agreement-1505/
Accessed: Sept. 26, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

Coinbase modified Section 2.7 of its User Agreement to carve out a new exception permitting asset transfers related to a 'Secured USDC' feature. This change introduces conditional asset control restrictions and third-party instruction rights that …

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Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.

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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-001505.

Full Changes

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Document Context

Version history → Policy drift analysis → Document page →
Document
Coinbase User Agreement
Entity
Coinbase
Captured
May 1, 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 2, 2026
Coinbase removed references to Secured USDC (a digital asset holding mechanism tied to its One Card product) from its core …
Medium Positive
View full version history →
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