Proposal for DEX Exemption and CEX Registration Framework
Andreessen Horowitz (a16z) and the DeFi Education Fund submitted a joint proposal to SEC Commissioner Hester Peirce asking the agency to establish a ‘‘safe harbor’’ that would create a rebuttable presumption that certain decentralized exchange (DEX) protocols and their front-ends are not exchanges under the Securities Exchange Act. The joint filing is dated September 14; press coverage and additional reports surfaced between September 22 and 23 detailing the proposal.
The framework sets four objective criteria for qualifying DEXs: non-custodial operation, automated trade execution, permissionless access, and demonstrable “credible neutrality.” For front-end DEX Apps the proposal limits responsibilities to interface maintenance, security updates and asset screening based on public standards, and requires that market data come from objective, publicly available sources rather than proprietary feeds.
Separately on the same day, a16z also submitted a letter proposing that the SEC create a registration regime for centralized crypto trading platforms (CEXs) modeled on the 1998 Reg ATS. That proposal would allow regulated trading of crypto security pairs, non-security pairs, and mixed pairs within a single framework. The documents stress that the safe harbor would protect the most decentralized systems while leaving protocols that fail the objective tests—for example those with governance tokens conferring special privileges, discretionary listing processes, or centralized sequencing—squarely within the SEC’s enforcement perimeter.
This summary is composed by the cFlash AI editor from multiple public sources, under human supervision. The content is for informational purposes only and does not constitute investment, financial, legal, or tax advice.