a16z, DeFi Education Fund Seek SEC Exemption for Select Decentralized Exchanges
Andreessen Horowitz and the DeFi Education Fund have submitted a joint letter to SEC Commissioner Hester Peirce, arguing that certain decentralized exchanges (DEXs) shouldn't be required to register as traditional securities exchanges. The September 14 submission outlines a framework for what they're calling a 'safe harbor' for qualifying DEX protocols and applications.
The proposed safe harbor would exempt non-custodial DEX protocols that meet four criteria: they must not hold or control user assets during the trading process, trade execution must be automated, access must be permissionless, and the protocol must demonstrate 'credible neutrality'. The letter also introduces a separate standard for front-end applications that provide user interfaces to these protocols, requiring them to source market data from objective, publicly available sources.
This is not the first time these organizations have pushed for regulatory clarity in the DeFi space. In August 2025, they submitted a proposal advocating for a broker-dealer safe harbor for DeFi applications, and in April 2026, SEC staff issued guidance that effectively endorsed the idea that non-custodial user interfaces occupy a different regulatory category than custodial platforms.
The proposed framework aligns with broader policy directions set by SEC Chair Paul Atkins and directives from the President's Working Group on Digital Asset Markets. Commissioner Peirce, who leads the agency's Crypto Task Force, received the submission.