MetaMask does not hold or control your funds or private keys, and if you lose your Secret Recovery Phrase, the company cannot help you recover it and your assets may be permanently inaccessible.
This analysis describes what MetaMask'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
Unlike a bank or custodial exchange, MetaMask has no ability to restore access to your wallet if you lose your recovery phrase, meaning a single mistake can result in total and permanent loss of your cryptocurrency with no remedy.
Users bear sole and total responsibility for protecting their Secret Recovery Phrase, and any loss of that phrase results in permanent, unrecoverable loss of all funds in the wallet with no recourse against MetaMask.
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"MetaMask is a non-custodial wallet software, meaning you are solely responsible for the custody of the cryptographic private keys to your digital asset wallets. You should never share your Secret Recovery Phrase (SRP) or private key(s) with anyone or any site. We are not able to help you recover your SRP. If you lose your SRP, you may lose access to your MetaMask wallet and all of the assets therein permanently.— Excerpt from MetaMask's MetaMask Terms of Use
(1) REGULATORY LANDSCAPE: Non-custodial wallet providers occupy a distinct regulatory position from custodial exchanges. In the U.S., non-custodial wallets are generally not subject to FinCEN money transmission licensing requirements, though this interpretation has been subject to ongoing regulatory scrutiny. MiCA in the EU addresses non-custodial wallet providers in a more limited manner than custodial services but may impose some obligations. (2) GOVERNANCE EXPOSURE: Medium. While the non-custodial model is a genuine technical characteristic of MetaMask's architecture, the terms' framing of absolute user responsibility, combined with the liability cap, means institutional users deploying MetaMask to customers assume reputational and potential legal exposure if customers lose funds and claim inadequate disclosure. (3) JURISDICTION FLAGS: Consumer protection regulators in the EU and UK may scrutinize whether the disclosure of non-custodial risk is presented with sufficient prominence and clarity to satisfy informed consent standards. The permanence of loss and absence of any consumer protection fund or insurance analog is a material risk that some jurisdictions may require to be disclosed more prominently. (4) CONTRACT AND VENDOR IMPLICATIONS: Businesses building on MetaMask's non-custodial infrastructure should ensure their own customer disclosures replicate and reinforce the key recovery risk in plain language, particularly if their customer base includes retail users unfamiliar with blockchain wallet mechanics. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether customer onboarding flows adequately capture informed acknowledgment of the non-custodial model and the permanent loss risk associated with SRP loss, including documentation of that acknowledgment for regulatory purposes.
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Unlike a bank or custodial exchange, MetaMask has no ability to restore access to your wallet if you lose your recovery phrase, meaning a single mistake can result in total and permanent loss of your cryptocurrency with no remedy.
Users bear sole and total responsibility for protecting their Secret Recovery Phrase, and any loss of that phrase results in permanent, unrecoverable loss of all funds in the wallet with no recourse against MetaMask.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by MetaMask.