CFTC No-Action Letter Lets Exchanges Convert Crypto Futures Into True Perpetuals
Key Takeaways
- •The CFTC's Division of Market Oversight granted conditional no-action relief on June 12, 2026, permitting designated contract markets to strip expiration dates from eligible digital commodity futures and convert them into true perpetual futures.
- •The relief was requested by Bitnomial Exchange for 16 contracts and Coinbase Derivatives for 22 contracts, products that had previously carried distant expiration dates of up to 25 years.
- •Only contracts tied to digital commodities with deep, active, and continuous spot markets qualify for the relief, with Bitcoin cited as the framework's example.
- •Exchanges must certify amendments under Regulations 40.5 or 40.6, solicit market feedback, and satisfy risk disclosure obligations before implementing any changes.
- •The relief takes effect immediately expires on June 30, 2026, giving exchanges less than three weeks to act under the letter.

The US Commodity Futures Trading Commission has issued a quiet but consequential update to how crypto derivatives trade on regulated American markets. On June 12, 2026, the agency's Division of Market Oversight released Staff Letter No. 26-19, granting conditional no-action relief to designated contract markets (DCMs) — the CFTC-regulated exchanges where futures contracts are listed. The relief allows them to convert existing perpetual-style digital commodity futures into true perpetual futures by removing expiration dates entirely. Perpetual futures are the contract format that originated in crypto trading — derivatives with no expiry date at all, rather than the fixed settlement dates traditional futures are built around.
What the CFTC actually approved
A no-action letter is a commitment from a regulator's staff not to recommend enforcement action if a firm complies with specified conditions. Rather than establishing a new rule, it functions as a written assurance that a particular move will not draw enforcement fire.
The move in question is straightforward: qualifying exchanges can delete the expiration date from eligible futures contracts.
The relief followed requests from two exchanges. Bitnomial Exchange, LLC sought relief covering 16 contracts, while Coinbase Derivatives, LLC filed a same-day request covering 22 contracts. Those products already behaved like perpetuals but carried very distant expiration dates, with some stretching as far as 25 years into the future — distant dates that kept the products inside a futures framework built around expirations.
The principal benefit is speed. Ordinarily, changing contract terms can trigger the self-certification timing requirements under CFTC Regulation 40.6. The letter permits DCMs to drop expirations without waiting through those customary delays.
The conditions attached
The relief is not a blank check, and its conditions are specific.
First, eligibility is narrow. Only contracts tied to digital commodities with "deep, active, and continuous" spot markets qualify. Bitcoin is the example cited in the framework.
Second, the paperwork burden remains. DCMs must submit amendments under Regulations 40.5 or 40.6 certifying compliance before they implement any changes.
Third, the framework requires DCMs to solicit market feedback and satisfy risk disclosure obligations.
Fourth, the clock is short. The relief takes effect immediately but expires on June 30, 2026, giving exchanges a window of under three weeks to act under the letter.
How it fits the CFTC's recent direction
The letter aligns US-regulated markets with the CFTC's recent decisions on how perpetual futures for digital commodities should be treated. The headline precedent is the approval of KalshiEX LLC's BTCPERP contract. Once a Bitcoin perpetual had cleared the bar, the awkward status of 25-year "perpetual-style" contracts looked increasingly outdated.
Staff Letter No. 26-19 effectively closes that gap. Exchanges that built workaround products can now convert them into the real thing rather than launching entirely new listings from scratch. For Bitnomial and Coinbase Derivatives, existing contracts, existing users, and existing positions can move to the new structure through a defined process.
What it means for traders and exchanges
For traders, the change is largely about clarity. A perpetual without any expiration date is easier to reason about than one with a far-off date that exists mainly for regulatory reasons. It also places a format long associated with crypto trading squarely under the CFTC's certification and disclosure requirements.
The eligibility rule is likely to shape competition among exchanges. Because only assets with deep, active, and continuous spot markets qualify, the first wave of true perpetuals will cluster around the most established digital commodities, with Bitcoin leading.
The short lifespan of the relief is the biggest open question. An expiration date of June 30, 2026 staff wanted a controlled, time-boxed transition rather than an open-ended exemption. Exchanges that miss the window may need to go through the standard process instead.
The actual amendment filings under Regulations 40.5 and 40.6 will be worth watching. Those documents will show how quickly Bitnomial and Coinbase Derivatives convert their 16 and 22 contracts, and how they handle the required risk disclosures.