Coinbase Derivatives files 'Equity Perpetual Contracts' with the CFTC: what the 18 September submission says, what it leaves out, and where it sits next to the SEC's Innovation Exemption

A product filing is a narrow document. It describes one contract, cites one rule, and asks a regulator for one thing. It is easy to report by what it implies and hard to report by what it says, because the interesting questions, which stocks, from when, at what margin, are usually the ones a filing does not answer. On 18 September 2026 Coinbase Derivatives, LLC submitted a product called "Equity Perpetual Contracts" to the United States Commodity Futures Trading Commission, and the Commission's industry filings page lists it the same day. This article reads the filing page and the submission PDF together: what is being proposed, under which rule, with which contract terms, and what the two documents leave open.

The CFTC's public "Trading Organization Products" register carries the submission as item 64236. The fields on that page, as we read them on 19 September 2026, are these: organization "COIN"; product name "Single Stock Perpetual Futures Contract"; product type "Future"; category "Security Futures Product"; subcategory "SSF - Single Stock Future"; filing date 18 September 2026; and status "Approval Pending (45)". One PDF is attached, titled "2026-62 Listing of Security Futures Product_41.23(b)".

Two things are worth stating about the page before turning to the PDF. First, the register classifies the product as a security futures product, not as a commodity futures contract. That classification matters because security futures in the United States sit under joint CFTC and Securities and Exchange Commission jurisdiction, and the rule cited in the filing, Regulation 41.23(b), belongs to the part of the CFTC's rules that governs them. Second, the status field says "Approval Pending" with the number 45 in brackets. The page does not explain the number. It may refer to a review period in days; we have not found a definition on the page and therefore do not interpret it here.

The PDF is headed "Voluntary Submission of Security Futures Products for Commission Approval Regarding the Initial Listing of Equity Perpetual Contracts". It is dated 18 September 2026 and signed by Jane Downey, Chief Regulatory Officer of Coinbase Derivatives, LLC. The legal basis it cites is Section 5c(c)(1) of the Commodity Exchange Act together with CFTC Regulation 41.23(b). The word "voluntary" in the title is the filing's own: under the cited provisions an exchange may certify a product or may ask the Commission to approve it, and this submission asks for approval.

The product is described as a family, "Equity Perpetual Contracts", with one representative contract set out in full: the "AAPL Single Stock Perpetual Future". The underlying is described in general terms as single equity securities or exchange-traded fund shares that meet the exchange's listing standards, which the submission places in its Rule 1203. The contract terms the document states are these:

The contract multiplier is "0.01 x AAPL index", and the submission gives a worked example in which a price of 225.10 dollars yields a contract notional of roughly 2.25 dollars. Trading hours are "Sunday 8:00 PM ET – Friday 5:00 PM ET", which is close to continuous across the working week with a weekend break. There is no expiry: the document states that "there is no scheduled last trading day for this perpetual Contract". In place of expiry there is a funding mechanism, calculated hourly, with the formula written out as "Funding Rate * Open Position Quantity * Contract Multiplier * Futures Mark Price * -1", and a limit described as a clamp of plus or minus 0.10 per cent, that is ten basis points, per hour. Margin and position limits are referred to the exchange's Rule 1208, with initial margin "as determined and published by the Exchange".

On timing, the submission says the exchange "intends to make this request effective and list the Contracts shortly following approval". That is the only statement about a launch, and it is conditional on the Commission's decision.

A reader looking for four things will not find them in either document. There is no list of the specific stocks or exchange-traded funds to be listed; the AAPL contract is described as representative, and the eligible universe is defined by reference to listing standards rather than by name. There is no launch date; the document says only "shortly following approval". There are no margin numbers, only the reference to a rule under which the exchange will publish them. And there are no position limit figures. Secondary reporting has described the likely list of underlying stocks in round numbers, citing a separate filing with the Securities and Exchange Commission from earlier in the month; we did not open that document for this article and do not repeat those figures as facts of the CFTC submission.

The submission also does not contain a statement from the Commission, a statement from Coinbase beyond the filing itself, or any reference to other proceedings. Whatever else is being said about single-stock perpetuals this month is outside these two documents and therefore outside this article.

For readers who follow this site's Market Observation pages, where the reference data is real-time and sourced, the word "perpetual" will be familiar from crypto-asset venues. A perpetual future is a futures contract without an expiry date. Because there is no settlement date at which the futures price must converge with the spot price, such contracts use a periodic payment between long and short positions, the funding rate, to keep the two prices close. The Coinbase submission applies that form to a single equity: the funding is hourly, the mark price is the futures mark, and the clamp caps how large any single hourly payment can be.

Two other documents from the same week use the same form or the same policy space. On 17 September the Moscow Exchange gave notice of perpetual crypto-index futures for 22 September; we documented that notice in a separate article. The mechanism there is the same family of instrument on a different underlying and in a different jurisdiction. And on 17 September the CFTC's own staff issued a no-action letter on passive software providers while a crypto rulemaking package was logged for White House review, which we documented here. Neither document concerns single-stock perpetuals, but they show the same regulator acting on adjacent questions within forty-eight hours of this filing.

The closest document in time and subject is the Securities and Exchange Commission's order of 17 September 2026 on tokenized NMS stock, which we read in an article yesterday. The two documents should be kept apart. The SEC order concerns tokenized representations of listed equities. The Coinbase submission concerns a derivative on listed equities, filed with the commodities regulator under the security futures rules. One is about the cash instrument in a new form; the other is about a futures contract in a new form. They share an underlying asset class, United States equities, and a calendar week, and nothing else that the texts themselves establish.

What the two documents do show, read together, is that within two days both United States market regulators received or issued documents that extend crypto-market structures, tokenization on one side and perpetual funding on the other, to listed equities. That is an observation about the documents' subject matter, not a statement about their outcome.

Three boundaries follow from the text. The submission is a request for approval, and the register says the request is pending; whether, when and on what conditions the Commission approves is not in the document. The contract terms stated are those of one representative contract; the terms of any other contract in the family are defined by reference to rules we have not read in full. And the economic questions a market participant would ask, margin levels, position limits, the eligible stock list, are the ones the filing explicitly defers to the exchange's own later publication.

Our own work on this site is documentary in this sense: we read the released text and record what it commits to. Readers who want the vocabulary of derivatives and the way we approach primary sources will find it in The Analyst Room and the Kripto Akadémia; our position on what this site does and does not do is stated on the Regulatory page, and the team that prepares these readings is introduced on the About page.

United States Commodity Futures Trading Commission, Industry Filings, Trading Organization Products, item 64236, "Single Stock Perpetual Futures Contract", organization COIN, filed 18 September 2026, status "Approval Pending (45)", cftc.gov/IndustryOversight/IndustryFilings/TradingOrganizationProducts/64236. Coinbase Derivatives, LLC, "Voluntary Submission of Security Futures Products for Commission Approval Regarding the Initial Listing of Equity Perpetual Contracts", 18 September 2026, PDF at cftc.gov/filings/ptc/ptc09182627449.pdf, signed by Jane Downey, Chief Regulatory Officer. Cointelegraph, "Coinbase files to bring single-stock perpetual futures to US market", 18 September 2026 (secondary, not relied on for any figure in this article).

Educational content. Not investment advice. This article describes a regulatory filing; it contains no instruction to buy, sell or hold any asset.