Coinbase · Coinbase User Agreement · View original document ↗

Unilateral Agreement Amendment by Posting

Medium severity Unique · 0 of 352 platforms
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Recent governance activity Coinbase recorded 2 documented changes in the last 30 days.
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Document Record

What it is

Coinbase may modify the agreement at any time by posting a revised version on its website. Continued use of services after posting constitutes acceptance of the revised terms. The only remedy available to users who disagree with changes is to close their account.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision permits Coinbase to modify material terms of the agreement by website posting, with continued use constituting acceptance. The agreement does not specify a notice period for all changes, though certain state-specific disclosures (California, for example) require at least 14 days prior notice of material fee or term changes for residents of those states.

Recent Activity

This document changed recently

High Jul 23, 2026

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.

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Medium Jul 7, 2026

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.

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Medium May 2, 2026

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.

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What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Close Your Account
    If you do not agree with changes to the User Agreement, you may close your account at https://accounts.coinbase.com/profile/close before continuing to use the services.

If You Do Nothing

Continued use of Coinbase services after a revised agreement is posted constitutes acceptance of the new terms as stated in the agreement

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
We may amend or modify this Agreement at any time by posting the revised agreement on the Coinbase Site and/or providing a copy to you (a "Revised Agreement"). The Revised Agreement shall be effective as of the time it is posted but will not apply retroactively. Your continued use of the Services after the posting of a Revised Agreement constitutes your acceptance of such Revised Agreement. If you do not agree with any such modification, your sole and exclusive remedy is to terminate your use of the Services and close your account.

Excerpt from Coinbase's User Agreement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1. REGULATORY LANDSCAPE: Unilateral modification provisions in consumer financial contracts interact with state money transmission laws and consumer protection statutes, some of which impose minimum notice requirements for material term changes. The California disclosure section of the agreement specifically commits to at least 14 days prior notice of material fee or term changes for California residents, suggesting awareness of state-specific notice obligations. 2. GOVERNANCE EXPOSURE: Medium. The broad unilateral modification right is constrained in practice by state-specific notice requirements and the requirement that changes not apply retroactively. However, the structure places the burden on users to monitor for changes and act proactively to avoid acceptance. 3. JURISDICTION FLAGS: California requires 14 days prior notice of material changes for California residents per the state disclosures in Appendix 3. Other states with money transmission oversight may impose similar requirements. The agreement provides for varying notice periods based on applicable law, but does not establish a uniform minimum notice period for all users. 4. CONTRACT AND VENDOR IMPLICATIONS: Institutional or API users who have integrated Coinbase services operationally should establish a monitoring process for agreement changes, as the posting-based modification mechanism may not provide sufficient advance notice for operational adjustments. 5. COMPLIANCE CONSIDERATIONS: Legal teams should verify that the modification and notice procedures described in the agreement satisfy applicable state money transmission law requirements in all jurisdictions where Coinbase holds licenses, and evaluate whether the absence of a uniform minimum notice period creates compliance exposure in any state.

Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive acts or practices, including the adequacy of notice for material changes to consumer contract terms
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Provision details

Document information
Document
Coinbase User Agreement
Entity
Coinbase
Document last updated
May 5, 2026
Tracking information
First tracked
July 12, 2026
Last verified
July 12, 2026
Record ID
CA-P-00047005
Document ID
CA-D-00047
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a9f500133b028586c3ef699c5845c93a81e3d2523e0ad6b93c23e63feb318580
Analysis generated
July 12, 2026 02:00 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coinbase
Document: Coinbase User Agreement
Record ID: CA-P-00047005
Captured: 2026-07-12 02:00:01 UTC
SHA-256: a9f500133b028586…
URL: https://conductatlas.com/platform/coinbase/coinbase-user-agreement/unilateral-agreement-amendment-by-posting/
Accessed: July 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Coinbase's Unilateral Agreement Amendment by Posting clause do?

This provision permits Coinbase to modify material terms of the agreement by website posting, with continued use constituting acceptance. The agreement does not specify a notice period for all changes, though certain state-specific disclosures (California, for example) require at least 14 days prior notice of material fee or term changes for residents of those states.

Is ConductAtlas affiliated with Coinbase?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Coinbase.