The Commodity Futures Trading Commission’s (CFTC) Treasury reform is reconfiguring how digital assets can be used in corporate finance, notably by permitting certain tokens as regulated collateral and opening new trading venues.
The CFTC’s pilot program authorises non‑securities digital assets—specifically BTC, ETH and USDC—to be used as collateral in derivatives markets, creating a regulated route for treasuries to deploy digital holdings for margin and liquidity management. Complementary guidance addresses tokenized collateral, a digital representation of traditional assets or cash-equivalent funds used to secure obligations on-chain.
After passage of the GENIUS Act, the reform removes legacy constraints, enabling Futures Commission Merchants to accept virtual currencies as customer collateral where previously restricted. These changes are intended to reduce operational friction and improve capital efficiency for entities that hold crypto on their balance sheets.
In December 2025 the CFTC launched a digital-assets pilot allowing Bitcoin, Ether and USDC to serve as collateral and announced the first listed spot crypto products will trade on CFTC-registered futures exchanges, a step that directly affects Digital Asset Treasury (DAT) firms and corporate treasuries.
CFTC Treasury Reform: pilot program and market mechanics
Legislative proposals — including the CLARITY Act, FIT21 and the Digital Commodities Consumer Protection Act (DCCPA) — aim to classify most digital assets as commodities and consolidate market oversight under the CFTC. That legal clarity addresses long-standing jurisdictional uncertainty and is expected to simplify compliance for market participants.
Joint SEC–CFTC engagement, through roundtables and a September 2025 joint statement, clarified that registered exchanges may facilitate spot crypto trading under current law, reducing a major structural hurdle. The agency’s approval of regulated prediction markets and a Designated Contract Market (DCM) for a major platform illustrates how new product types can enter a supervised framework; a DCM is a regulated exchange authorised to list futures and other derivatives under statutory rules. Acting Chair Caroline D. Pham characterised the rollout as a milestone for integrating digital assets into regulated markets, saying: “Today’s announcement marks a significant milestone in the expanded adoption of digital assets in regulated markets with appropriate guardrails,” according to the CFTC statement.
By defining roles, permitting tokenized collateral and creating regulated spot venues, the reform reduces legal and operational uncertainty for treasuries and institutional participants, facilitating on‑ramps for larger-scale adoption. The CFTC has also intensified enforcement: enforcement actions involving digital assets rose by 59% in 2024, a trend that agency officials say strengthens market integrity by targeting fraud and mismanagement.
The combined effect is to broaden the set of compliant tools available to treasuries — from collateral diversification and margin optimisation to new hedging instruments — while also raising expectations for custody, KYC/AML and risk controls.
