The agreement authorizes Coinbase to stake eligible digital assets on behalf of users, states that staked assets may be illiquid for a period, discloses that staking rewards are not guaranteed and may change, and states that Coinbase may charge a commission on any staking rewards earned.
This analysis describes what Coinbase's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that participation in Coinbase staking services authorizes asset lockup for unspecified periods, that rewards are not guaranteed, and that Coinbase takes a commission from any rewards generated, which affects both asset liquidity and effective yield calculations.
Interpretive note: The regulatory classification of Coinbase's staking services under federal securities law is subject to ongoing enforcement and litigation and cannot be determined from the agreement text alone.
The updated terms expand Coinbase's authority to liquidate customer assets without notice to cover clearinghouse losses. Previously, liquidation was authorized only if you failed to pay for securities purchased or failed to deliver securities sold. The revised language now also permits liquidation if a transfer of securities into your account at CCM fails or is reversed. This means the platform can use your property to cover losses stemming from incoming transfer failures, in addition to settlement failures on your own trades. The authorization continues to require only that CCM make a demand for payment to Coinbase, without notice to you.
View change record →The updated terms establish procedures for handling protocol upgrades and define Coinbase's role in migrating customer assets to new versions. Under the revised language, by maintaining a Coinbase account, customers are deemed to have instructed Coinbase to conduct Coinbase Supported Migrations on their behalf at times and in manner Coinbase solely determines appropriate. The agreement further states that Coinbase shall not be liable or responsible for any loss resulting from inability to transfer Digital Assets during a migration or from the Asset Transformation itself. This expands Coinbase's authority to act without advance notice while eliminating liability for migration-related losses.
View change record →The updated terms now explicitly disclose Coinbase's fee structure for California residents, establishing a $10 maximum fee for transactions under $200 and a 6% maximum for larger transactions, though actual fees displayed at checkout may be lower based on payment method, order size, market conditions, and location. The revised agreement also clarifies that virtual currency transactions may be irreversible and provides links to procedures for reporting unauthorized transactions, updating contact information, and accessing transaction receipts. Coinbase commits to providing California residents at least 14 days' prior notice of material changes to fees or terms affecting their accounts.
View change record →Removal of staking-specific terms from main User Agreement suggests relocation to separate documentation, potentially reducing visibility of lock-up periods and commission risks.
View full change record →This new provision governs an expanded service offering (staking), disclaiming reward guarantees, establishing commission rights, and disclosing inaccessibility risks for staked assets.
View full change record →Under the staking terms, users' digital assets may be locked and inaccessible for periods determined by the underlying protocol. Staking rewards are disclosed as non-guaranteed and subject to change, and Coinbase charges a commission on any rewards earned.
How other platforms handle this
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"When you use our staking services, you authorize Coinbase to stake your eligible digital assets on your behalf. Staking involves locking up your digital assets in a smart contract or protocol, which may mean your assets are inaccessible for a period of time. Staking rewards, if any, are not guaranteed and are subject to change. Coinbase may charge a commission on staking rewards.Excerpt from Coinbase's User Agreement
1) REGULATORY LANDSCAPE: Coinbase's staking services have been the subject of SEC enforcement proceedings, with the SEC asserting that certain staking-as-a-service offerings constitute securities subject to registration requirements under the Securities Act.
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This provision establishes that participation in Coinbase staking services authorizes asset lockup for unspecified periods, that rewards are not guaranteed, and that Coinbase takes a commission from any rewards generated, which affects both asset liquidity and effective yield calculations.
Under the staking terms, users' digital assets may be locked and inaccessible for periods determined by the underlying protocol. Staking rewards are disclosed as non-guaranteed and subject to change, and Coinbase charges a commission on any rewards earned.
ConductAtlas has identified this type of provision across 231 platforms. See the full comparison.
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