# CFTC Issues No-Action Position for Passive Software Providers

The Commodity Futures Trading Commission (CFTC) has issued a no-action position for providers of passive software that facilitate trading activities with registered futures commission merchants, introducing brokers, and designated contract markets. This position exempts these software providers from enforcement actions related to registration as introducing brokers or associated persons, provided they meet specified conditions. This development clarifies compliance obligations for software vendors operating in the derivatives trading ecosystem and may influence procurement decisions and vendor selection criteria for regulated entities.

- **Why this matters:** Software vendors offering passive trading facilitation tools can operate without registering as brokers under the CFTC's enforcement framework, reducing regulatory burdens.
- Procurement professionals should consider this regulatory clarity when evaluating software solutions for derivatives trading platforms.
- Vendors may leverage this position to expand offerings to CFTC-regulated entities with reduced compliance risk.
- Organizations should review the specified conditions of the no-action position to ensure vendor compliance and mitigate legal exposure.

**Jurisdictions:** federal
**Industries:** Information Technology
**Topics:** Regulatory Compliance
**Published:** September 18, 2026

### Government Entities
- Commodity Futures Trading Commission (CFTC)

### Sources
- [CFTC Staff Issues No-Action Position to Providers of Passive Software | CFTC](https://www.cftc.gov/PressRoom/PressReleases/9300-26) - CFTC