Who can trade
Eligibility
CRX is open to Eligible Contract Participants ("ECPs"). An ECP is a qualified institution: a fund, a bank, a corporate treasury, or a market-making desk. Some jurisdictions add a second, local professional-investor test on top of the ECP floor. Where they do, a firm must satisfy both to become a taker.
The ECP test
The federal definition is in CEA section 1a(18). An entity qualifies on either of two paths:
| Path | Threshold |
|---|---|
| By size | total assets exceeding US$10 million |
| By hedging | net worth exceeding US$1 million, and entering the trade to hedge or manage a commercial risk of its business |
This is the floor. A firm below it does not trade on CRX.
Attestation is not verification
A participant attests to its ECP status before trading, by representation in the onboarding agreement. This is the standard ISDA mechanism, and the conventional way ECP status is established.
CRX does not rest on the attestation alone. Each firm is verified against the test before its wallet is added to the on-chain allowlist. A self-asserted checkbox is not eligibility. A mocked whitelist is not eligibility. The allowlist admits a firm only once its status is established in fact.
The local gate
ECP status is the federal floor. Several jurisdictions layer their own professional-investor test on top, and the firm satisfies both. Open any jurisdiction below for the category, the regulator, and what the firm shows.
JurisdictionGate on top of ECPRequirements
- Eligible Contract Participant (ECP) under Commodity Exchange Act (CEA) §1a(18). There is no second gate — the federal ECP test is the entire check.
- Qualifies with total assets above US$10 million, or net worth above US$1 million when the trade hedges a commercial risk of the business.
Notes
- The participant attests to ECP status before trading. No local professional-investor overlay applies.
Requirements
- Professional client under MiFID II (EU Markets in Financial Instruments Directive II). Per-se: credit institutions, investment firms, insurers, funds, large undertakings.
- A large undertaking meets two of three: €20M balance sheet, €40M net turnover, €2M own funds.
Notes
- Every counterparty holds a valid Legal Entity Identifier (LEI), a 20-character entity code. No LEI, no trade.
Requirements
- Professional client under Financial Conduct Authority (FCA) rules implementing UK MiFIR — the retained, post-Brexit MiFID framework.
- Same substance as the EU test: per-se professionals plus large undertakings at the same size thresholds.
Notes
- Every counterparty holds a valid Legal Entity Identifier (LEI), a 20-character entity code.
Requirements
- Clears the Securities and Commodities Authority (SCA) client-classification rules — the federal UAE regulator outside the DIFC and ADGM free zones.
- Professional Investor: experience to assess risk (natural-person floor ~AED 4M net assets). Qualified Investor: governments, international bodies, licensed institutions, and corporates meeting size tests.
Notes
- Either classification is sufficient at the eligible booking point.
CRX applies the ECP floor in every jurisdiction, not only where U.S. law compels it. One standard everywhere, rather than resting on whether the federal test reaches a given offshore trade between non-U.S. firms.
Other jurisdictions
CRX onboards firms in additional jurisdictions case by case, with local counsel, provided the firm meets the ECP floor and any local professional-investor test. Contact CRX to begin that review.
Disclaimer
For eligible contract participants only. Nothing here is an offer, a solicitation, or legal advice. Eligibility positions are CRX's working view, subject to counsel and to change.