Coinbase states it can change the terms of this agreement at any time by posting updated terms online or notifying you. If you continue using Coinbase after changes take effect, the agreement states that you have accepted the new terms.
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
The agreement authorizes Coinbase to modify its terms unilaterally, and the agreement states that continued use of the platform constitutes acceptance of those changes. This means material changes to fees, data practices, liability limits, or arbitration terms could take effect without requiring affirmative consent.
Interpretive note: Enforceability of continued-use acceptance for material changes, particularly to arbitration terms, may vary by jurisdiction and is subject to evolving court and regulatory interpretation.
The updated terms establish a new arrangement for USDC designated as 'Secured USDC' in connection with the Coinbase One Card. Under the revised language, if you designate USDC in your wallet as Secured USDC, you agree that Coinbase may transfer that amount to a third party designated as the secured party, and you will be restricted from withdrawing or transferring those funds. Additionally, the secured party's instructions to Coinbase regarding those assets take priority over any conflicting instructions you provide. The agreement states that you consent to all such permitted transfers. This arrangement operates independently of amounts owed to Coinbase, meaning Secured USDC will not be debited to satisfy debts you owe to Coinbase.
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 →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.
View change record →Users who do not regularly review the Coinbase User Agreement may be bound by updated terms, including changes to fees, arbitration requirements, or data practices, simply by continuing to use the service after changes are posted. The agreement does not specify a minimum advance notice period for all types of changes.
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"We may amend or modify this User Agreement at any time by posting the revised agreement on the Coinbase website and/or providing notice to you. The amended User Agreement shall be effective immediately upon posting or notice, as applicable. Your continued use of Coinbase Services after the effective date of any amendment or modification shall constitute your acceptance of the revised User Agreement.— Excerpt from Coinbase's Coinbase User Agreement
REGULATORY LANDSCAPE: Unilateral amendment provisions in consumer financial services agreements may interact with state consumer protection requirements for material change notifications, particularly in states that require affirmative consent for changes to arbitration terms, fee structures, or privacy practices. The FTC's authority over unfair or deceptive practices in commerce may be relevant where changes are made without adequate notice. CFPB supervisory guidance on financial product disclosures may also apply. GOVERNANCE EXPOSURE: Medium. The provision's breadth, covering any amendment without a specified minimum notice period, creates compliance monitoring obligations for institutional users and compliance teams who must track changes to the agreement on an ongoing basis. The treatment of continued use as acceptance is standard in online services but may face enforceability challenges for material changes to core terms such as arbitration provisions, where some courts and regulators require affirmative opt-in. JURISDICTION FLAGS: California law has imposed requirements for affirmative consent to certain changes in consumer contracts, particularly those affecting arbitration or dispute resolution terms. The enforceability of the continued-use acceptance mechanism for material changes may vary by state. EU and UK users are subject to separate agreements and consumer protection frameworks that generally require affirmative consent for material contract changes. CONTRACT AND VENDOR IMPLICATIONS: Institutional counterparties should establish systematic processes for monitoring Coinbase User Agreement updates and assessing whether material changes require renegotiation or updated risk assessments. Vendor management programs should include Coinbase in periodic contract review cycles triggered by posted amendments. COMPLIANCE CONSIDERATIONS: Compliance teams should implement agreement monitoring workflows that flag Coinbase User Agreement updates and assess their materiality relative to existing compliance frameworks. For any updates to arbitration, liability, or data-sharing terms, legal review should assess whether the continued-use acceptance mechanism is sufficient or whether affirmative consent is required under applicable law.
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The agreement authorizes Coinbase to modify its terms unilaterally, and the agreement states that continued use of the platform constitutes acceptance of those changes. This means material changes to fees, data practices, liability limits, or arbitration terms could take effect without requiring affirmative consent.
Users who do not regularly review the Coinbase User Agreement may be bound by updated terms, including changes to fees, arbitration requirements, or data practices, simply by continuing to use the service after changes are posted. The agreement does not specify a minimum advance notice period for all types of changes.
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