The Commodity Futures Trading Commission has broadened its no-action position so any qualifying developer of passive software can avoid enforcement recommendations for failing to register as an introducing broker when its applications connect users with registered futures commission merchants, introducing brokers and designated contract markets. Staff Letter No. 26-25, issued on September 17, 2026, expands Letter 26-09, which the Market Participants Division issued to Phantom Technologies on March 17, 2026. The relief covers software that facilitates user-directed trading in Commission-regulated derivatives, including perpetual futures and prediction markets, but does not extend to applications that exercise trading discretion, hold user assets or otherwise operate as intermediaries. It remains in effect until a CFTC rulemaking or guidance addressing software developers and introducing-broker registration becomes effective. The move comes as the CFTC advances digital-asset policy under existing authority while broader crypto legislation, including the CLARITY Act, remains stalled.