The Commodity Futures Trading Commission announced on September 17 that it would not pursue enforcement actions against qualifying passive software providers who fail to register as introducing brokers or associated persons, provided they meet ten specific conditions. The no-action position applies to software that connects users with registered derivatives exchanges, brokers and futures commission merchants. Providers must file a notice with the CFTC’s Market Participants Division, accept the agency’s jurisdiction, and ensure users maintain a direct relationship with regulated entities rather than the software developer. The relief does not constitute a blanket exemption from the Commodity Exchange Act but rather a temporary suspension of enforcement for activities described in Staff Letter 26-25. Ten conditions govern eligibility, including prohibitions on statutory disqualifications, restrictions on promotional material resembling brokerage advertising, and requirements that users can access regulated firms without relying solely on the provider’s software. The position also bars providers from becoming the sole conduit for customer relationships and mandates that marketing remains within limits that would not trigger National Futures Association pre-approval requirements. Enforcement powers remain intact for conduct outside the letter’s scope, such as fraud, market manipulation or unlawful solicitation. The CFTC’s action follows a separate five-year exemption granted by the Securities and Exchange Commission for eligible venues offering tokenized National Market System stocks, which similarly requires public and auditable smart contracts and direct ties to primary exchanges. Both agencies have operated within existing statutory authority after legislative efforts to clarify digital asset oversight stalled in the Senate. The CFTC’s relief is limited to passive derivatives software and does not extend to applications that exercise control over customer assets, execute trades on behalf of users, or generate explicit trading signals. Developers serving U.S. customers may use the position to offer tools that facilitate access to regulated derivatives markets without immediately assuming the full registration obligations of introducing brokers, though the framework remains subject to future rulemaking that could alter the conditions of relief.