Provision record
Uniswap · Uniswap Terms of Service · View original document ↗

Protocol Non-Control and Non-Fiduciary Disclaimer

High severity Medium confidence Explicitdocumentlanguage Common · 292 of 352 platforms
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Document Record

What it is

The agreement states that Uniswap Labs does not control or operate any version of the Uniswap Protocol, does not operate liquidity pools, and does not control trade execution, asserting that users are not buying or selling digital assets from Uniswap Labs when using the Interface.

This analysis describes what Uniswap'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 asserts a structural and legal separation between Uniswap Labs as the Interface operator and the underlying Protocol as autonomous open-source smart contracts. This distinction is Uniswap Labs' stated position and is relevant to ongoing regulatory analysis of whether the Interface operator's role constitutes broker-dealer, exchange, or money transmission activity under applicable law; the regulatory determination of this question is not settled by this agreement language.

Interpretive note: The regulatory significance of this provision depends on unresolved legal and regulatory determinations regarding whether Interface operators constitute regulated financial intermediaries under applicable U.S. and international law.

Recent Activity

This document changed recently

Medium Jul 8, 2026

The updated terms establish new contractual representations that users must make when agreeing to the agreement. Users now represent that they are not subject to economic or trade sanctions administered by any governmental authority, including OFAC lists, and that they are not citizens or residents of sanctioned jurisdictions. Users also represent that their access and use will comply with all applicable laws and will not be used to conduct or facilitate illegal activity. These representations are legally binding attestations that may be verified. Users in OFAC-sanctioned countries cannot truthfully make these representations and would be unable to use the platform.

View change record →
Medium Jun 19, 2026

The updated terms establish new restrictions on user conduct and add affirmative representations regarding asset eligibility. Users trading tokenized real-world assets (such as tokenized stocks, ETFs, or commodities) must now represent that they have reviewed issuer information and comply with any restrictions on trading or holding those assets. The terms also explicitly prohibit circumventing access restrictions, including geographic blocks and transfer limitations imposed by token issuers. By continuing to use the platform, users affirm they are legally eligible to trade tokens under their jurisdiction's laws.

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Medium May 28, 2026

The updated terms establish that Uniswap does not warrant that any digital asset accessible through its products is available for trading, holding, or transacting in your jurisdiction, or that you are legally permitted to do so. The revised language places the burden on you to determine whether a digital asset is lawfully available to you and to comply with any applicable transfer restrictions imposed by asset issuers or regulatory authorities. This means accessing or trading an asset through the Uniswap interface does not constitute Uniswap's determination that you are eligible to do so under your local laws.

View change record →

Clause Stability Mostly Stable

1
Change
4
Months Monitored
May 21, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 4462 other provisions on other platforms.
This clause has changed once in 4 months of monitoring.

Consumer impact (what this means for users)

Under this clause, the agreement asserts that Uniswap Labs bears no responsibility for trade execution, liquidity pool operations, or digital asset transactions conducted through the Protocol, and that users transact with the Protocol directly rather than with Uniswap Labs. The practical implication of this disclaimer for regulatory protection, dispute recourse, or liability allocation depends on how regulators and courts characterize Uniswap Labs' role, which this agreement language alone does not determine.

How other platforms handle this

Tinder Medium

TINDER ASSUMES NO RESPONSIBILITY FOR ANY CONTENT THAT YOU OR ANOTHER USER OR THIRD PARTY POSTS, SENDS, RECEIVES, AND/OR ACTS ON THROUGH OUR SERVICES, NOR DOES TINDER ASSUME ANY RESPONSIBILITY FOR THE IDENTITY, INTENTIONS...

Perplexity AI Medium

we do not warrant that Offering descriptions are accurate, complete, reliable, current, or error-free.

Skillshare Medium

Please note that these third parties are responsible for their own privacy practices.

See all platforms with this clause type →

Monitoring

Uniswap has changed this document before.

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▸ View Original Clause Language DOCUMENT RECORD
"
The Interface is distinct from the Uniswap Protocol and is one, but not the exclusive, means of accessing the Protocol. The Protocol itself has four versions, designated as v1, v2, v3, and v4, each of which comprises open-source or source-available self-executing smart contracts that are deployed on various public blockchains, such as Ethereum. Uniswap Labs does not control or operate any version of the Protocol on any blockchain network. By using the Interface, you understand that you are not buying or selling digital assets from us and that we do not operate any liquidity pools on the Protocol or control trade execution on the Protocol.

Excerpt from Uniswap's Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: The SEC and CFTC have both asserted jurisdiction over digital asset platforms, and the question of whether an interface operator like Uniswap Labs constitutes an exchange, broker, or dealer under the Securities Exchange Act or Commodity Exchange Act is an active regulatory and litigation issue. The CFTC has brought enforcement action against Uniswap Labs previously (this is a matter of public record), and the SEC has scrutinized decentralized finance platforms. This disclaimer represents Uniswap Labs' legal position and does not constitute a regulatory determination. 2) GOVERNANCE EXPOSURE: High. If regulators determine that the Interface operator's role in facilitating access to the Protocol constitutes exchange or broker-dealer activity, the disclaimer of control and non-fiduciary status asserted in this provision would be subject to regulatory challenge. The provision's operational significance depends substantially on regulatory classification outcomes that remain unsettled. 3) JURISDICTION FLAGS: U.S. federal securities and commodities regulatory frameworks create the primary exposure. EU markets in crypto-assets (MiCA) regulation may impose obligations on providers of crypto-asset services that interact with the Interface operator role. The non-control assertion may also interact with money transmission licensing determinations at the state level. 4) CONTRACT AND VENDOR IMPLICATIONS: Third-party partners integrating the Interface or accessing the Protocol through Uniswap Labs-provided APIs should assess their own independent regulatory classification status and should not rely on Uniswap Labs' non-control disclaimer as determinative of their own obligations. 5) COMPLIANCE CONSIDERATIONS: Compliance teams at institutional users should assess whether transacting through the Interface, given Uniswap Labs' stated role, satisfies their internal requirements for counterparty due diligence, regulated intermediary engagement, and best execution obligations. The absence of a broker or intermediary relationship, as asserted by this provision, has implications for investor protection frameworks that presuppose a regulated intermediary.

Full institutional analysis

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

Applicable agencies

  • SEC
    The SEC has asserted jurisdiction over digital asset trading platforms and the question of whether Interface operators constitute exchanges or brokers under federal securities law directly interacts with this provision's non-control disclaimer
    File a complaint →
  • FTC
    The FTC's consumer protection jurisdiction covers representations about the nature of services provided, including disclaimers of intermediary and fiduciary status in consumer-facing agreements
    File a complaint →

Applicable regulations

FTC Act Section 5
United States Federal

Provision details

Document information
Document
Uniswap Terms of Service
Entity
Uniswap
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-013118
Document ID
CA-D-00303
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c1d35f33490ba678f2bcbc199052724d38fc70909e41d9182f0a898576833667
Analysis generated
May 21, 2026 05:16 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Uniswap
Document: Uniswap Terms of Service
Record ID: CA-P-013118
Captured: 2026-05-21 05:16:34 UTC
SHA-256: c1d35f33490ba678…
URL: https://conductatlas.com/platform/uniswap/uniswap-terms-of-service/provision/CA-P-013118/protocol-non-control-and-non-fiduciary-disclaimer/
Accessed: July 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Uniswap's Protocol Non-Control and Non-Fiduciary Disclaimer clause do?

This provision asserts a structural and legal separation between Uniswap Labs as the Interface operator and the underlying Protocol as autonomous open-source smart contracts. This distinction is Uniswap Labs' stated position and is relevant to ongoing regulatory analysis of whether the Interface operator's role constitutes broker-dealer, exchange, or money transmission activity under applicable law; the regulatory determination of this question …

How does this clause affect you?

Under this clause, the agreement asserts that Uniswap Labs bears no responsibility for trade execution, liquidity pool operations, or digital asset transactions conducted through the Protocol, and that users transact with the Protocol directly rather than with Uniswap Labs. The practical implication of this disclaimer for regulatory protection, dispute recourse, or liability allocation depends on how regulators and courts characterize …

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 292 platforms. See the full comparison.

Is ConductAtlas affiliated with Uniswap?

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