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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 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 →The updated terms eliminate language that previously allowed Coinbase to restrict your withdrawals if you designated USDC as Secured USDC and to comply with third-party secured party instructions without your consent. Under the revised agreement, Coinbase will not transfer, loan, or otherwise handle your Supported Digital Assets except as required by law or as you instruct. This means the One Card Secured USDC mechanism is no longer integrated into the core asset protection clause, and users no longer face withdrawal restrictions or loss of instruction authority tied to that designation. If you currently hold Secured USDC under a separate One Card cardholder agreement, that agreement remains in effect but is no longer cross-referenced in the main User Agreement's asset protection section.
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.
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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. The regulatory status of staking services under federal securities law remains an active area of enforcement and litigation, and the agreement's disclosure of staking commission and reward variability engages this regulatory landscape. 2) GOVERNANCE EXPOSURE: High. Institutional users offering staking services to clients through Coinbase should evaluate whether intermediating staking rewards constitutes a securities activity under applicable SEC guidance or enforcement positions. The non-guarantee of rewards and commission structure create additional disclosure and fiduciary considerations for asset managers. 3) JURISDICTION FLAGS: SEC enforcement posture on staking-as-a-service is a federal-level consideration applicable across U.S. jurisdictions. State securities regulators may impose additional requirements in specific states. 4) CONTRACT AND VENDOR IMPLICATIONS: Institutional users should assess whether using Coinbase's staking services creates regulatory exposure under applicable securities or investment adviser regulations and whether client disclosures regarding staking risks are adequate. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should monitor SEC enforcement developments regarding staking services and assess whether participation in Coinbase staking programs requires regulatory disclosure, registration, or client notification under applicable investment management or broker-dealer regulations.
Regulatory citations, enforcement risk, and due diligence action items.
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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 235 platforms. See the full comparison.
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