Hyperliquid's Compliance Journey: From Permissionless to Permissioned via HIP-3

marsbitPublished on 2026-08-24Last updated on 2026-08-24

Abstract

Hyperliquid’s Compliance Path: From Permissionless to Permissioned HIP-3 Hyperliquid currently blocks U.S. access because its permissionless, on-chain infrastructure conflicts with U.S. market structure laws, which restrict futures trading to registered exchanges, clearinghouses, and brokers. Through its Hyperliquid Policy Center (HPC), the project is advocating for regulatory modernization, proposing that regulated entities be allowed to build products on HyperCore (its exchange and clearing layer) while fulfilling their compliance obligations. The platform’s modular stack separates roles like a traditional exchange (DCM), clearinghouse (DCO), and broker (FCM), but reconstructs them on-chain with code. This enables permissionless access, self-custody, and 24/7 global trading, but clashes with U.S. rules requiring KYC, specific margin models, and custodial arrangements. To resolve this, HPC is engaging with U.S. regulators (CFTC, SEC) to seek clarity that deploying on-chain software does not itself trigger licensing, and to establish exemptions allowing non-custodial wallets to route users to regulated derivatives. Recent political signals suggest openness to this approach. On the technical side, Hyperliquid Labs has introduced permissioned HIP-3 deployers on testnet. These allow regulated entities to launch markets, perform KYC, and whitelist compliant users. While these create separate order books, whitelisted market makers can bridge liquidity between them, ensuring de...

Author: shaundadevens

Compiled By: Baihua Blockchain

Hyperliquid still geoblocks the US market because its permissionless on-chain infrastructure conflicts with US market structure laws, which strictly confine futures trading to registered trading platforms, clearinghouses, and broker-dealers. The Hyperliquid Policy Center has urged the CFTC and SEC to modernize these regulatory frameworks, arguing that regulated entities, provided they take on corresponding compliance obligations, should be allowed to build products on HyperCore via builder and deployer seats. Now, with Trump's remarks confirming this direction, the path to Hyperliquid's onshoring via a permissioned HIP-3 DEX has become highly probable.

Core Details

Over the past year, much of our work on Hyperliquid has been to reposition it from a "decentralized perps exchange" to "modern market infrastructure: a globally accessible, composable platform for financial instruments encompassing perps, spot, and prediction markets.

Unlike monolithic crypto platforms like Coinbase and BN, which operate the full stack (user onboarding, custody, and trade execution) themselves, Hyperliquid's infrastructure layer resembles the separation of duties across entities in TradFi: a trading platform (DCM) lists contracts and matches trades, a clearinghouse (DCO) provides margin and ensures settlement, and a broker (FCM) handles user onboarding and routes trading access.

Similarly, Hyperliquid's modular tech stack embodies this exact separation. HyperCore (the trading and clearing layer) runs matching, margin accounting, and settlement as protocol-native logic, marks positions to market via validator oracles, and executes liquidations through a deterministic liquidation waterfall. Deployers must stake 500k slashable HYPE as insurance, are responsible for token listing, contract specs, leverage limits, and oracle configuration, and keep up to 50% of fees generated by their markets. Builders act as brokers, responsible for user onboarding and routing trading flow to HyperCore, earning a portion of trading fees.

However, Hyperliquid reconstructs these layers on-chain and enforces them via code: access and market creation are both permissionless, assets are fully self-custodied by users, other applications can be built on top, and all assets trade on a single global platform 24/7, eliminating geographic and legal fragmentation found in TradFi.

Hyperliquid's Regulatory Conundrum

Given this context, Hyperliquid's biggest challenge is regulation: US market structure laws are tailored for the traditional architecture, and every statutorily registered role is in structural conflict with Hyperliquid's foundational design. For example:

  • A Designated Contract Market (DCM) must adhere to 23 core principles under CEA Section 5(d), including market surveillance and customer identification. HyperCore is accessible to anyone with a wallet.

  • A Derivatives Clearing Organization (DCO) must compute margin via board-approved models with 99% confidence levels and settle via approved settlement banks (17 CFR §§39.13–39.14). HyperCore uses protocol logic for margin calculations and settles at the consensus layer.

  • A Futures Commission Merchant (FCM) must segregate customer funds under CEA Section 4d. Hyperliquid users are self-custodied, which is fundamentally different from the custodial FCM model.

These stringent requirements are why even centralized, KYC'd exchanges like Coinbase are forced to register as an FCM and acquire an existing DCM for their US operations. Hyperliquid cannot replicate this model, as acquiring a DCM and conforming to legacy regulations would betray its mission to "rethink infrastructure from the ground up"; thus, it has chosen to geoblock itself from the world's largest capital market.

Nonetheless, Hyperliquid's goal is not to remain offshore indefinitely: In February 2026, it announced the formation of the Hyperliquid Policy Center (HPC), funded with 1 million HYPE (~$72.5M at current prices), to work on integrating this new market structure into US law. In July, HPC and Phantom petitioned the CFTC to confirm that publishing on-chain software does not, in itself, trigger licensing requirements, allowing existing licensees to run matching, settlement, and margin calculation on-chain infrastructure, and to establish exemptions permitting non-custodial wallets to route users to regulated derivatives. In August, HPC and TradeXYZ brought the same logic to the SEC, proposing a regulatory framework for Pre-IPO perps (like SpaceX and Cerebras already trading on Hyperliquid) alongside disclosure and accreditation rules needed for US investor access. Early signs suggest this strategy is gaining traction and US regulators are receptive, most notably with Trump's announcement that Chairman Selig plans to advance Hyperliquid onshoring.

HPC's strategy is not to demand opening Hyperliquid directly to US investors without KYC, but to advocate treating it as neutral infrastructure: if US firms can use it while fulfilling regulatory duties under current law, then it should be an option alongside traditional DCMs. For instance, brokers could route client flow to HyperCore provided they perform KYC; or deployers could take on the registered exchange role, retaining listing discretion, market surveillance, and emergency action powers.

Hyperliquid's Compliance Prototypes

As the policy lobbying in Washington progresses, Hyperliquid Labs has deployed updates on testnet that theoretically enable this compliant access. The prime example is the permissioned HIP-3 deployer: unlike Hyperliquid's native markets and existing HIP-3 deployments which are fully open, these new deployments are only accessible to whitelisted users. Such deployments provide a clear path for regulated entities to list markets, perform KYC, and whitelist compliant users for trading.

These compliance prototypes will manifest as fragmented order books, as all markets (e.g., BTC and RWA markets) would need to be relisted. However, whitelisted market makers will bridge liquidity between the two order books, thus eliminating fragmentation and allowing new deployments to inherit Hyperliquid's deep liquidity while maintaining their own order book. This independent order book model has precedent (e.g., early BN US and now Lighter on Robinhood Chain), but the difference is that because both markets on Hyperliquid run on the same L1, sharing collateral and margin without cross-chain or cross-exchange bridging, liquidity flows seamlessly between order books rather than being siloed.

These exchanges also include other parameters, such as the "PA" (Privileged Actions) permission in the payload, allowing the DEX to directly operate on user accounts: submitting reduce-only orders, canceling orders, and transferring USDC within the DEX, closely resembling an FCM's close-out authority over client accounts. These elements together outline the path forward: US brokers and institutions now have the tools to build compliant Hyperliquid products on HyperCore. This option is additive and complementary — Hyperliquid's native markets remain permissionless, and its role as neutral infrastructure is preserved.

Research View

Hyperliquid's recent moves in Washington indicate that achieving compliant US market access is a top current priority; however, it's equally clear that operating via its native KYC-less frontend is not compliant under current US law. We believe HPC's efforts point to a path for KYC-compliant access: allowing the use of Hyperliquid's backend provided the enterprise offering access fully complies with regulations. With enabling tools now live on testnet (permissioned HIP-3 deployers, PA account control), we expect this implementation to provide US investors a compliant on-ramp to Hyperliquid markets while preserving the protocol's status as neutral infrastructure.

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Related Questions

QWhy did Hyperliquid geoblock the U.S. market, and what was the core conflict with U.S. regulations?

AHyperliquid geoblocks the U.S. market because its permissionless, on-chain infrastructure structurally conflicts with U.S. market structure laws, specifically the Commodity Exchange Act (CEA). These laws strictly confine futures trading to registered entities: Designated Contract Markets (DCMs), Derivatives Clearing Organizations (DCOs), and Futures Commission Merchants (FCMs). Hyperliquid's model, which features permissionless access, self-custody, and protocol-enforced settlement, is incompatible with the core principles and operational requirements of these regulated entities, such as mandatory KYC, specific margin models, and custodial segregation of customer funds.

QWhat is the role of the Hyperliquid Policy Center (HPC), and what specific regulatory changes is it advocating for?

AThe Hyperliquid Policy Center (HPC) is an initiative funded by Hyperliquid to modernize U.S. regulatory frameworks to accommodate new market infrastructures like Hyperliquid. Its strategy is not to seek permission for its native, non-KYC front-end but to advocate for Hyperliquid's recognition as neutral infrastructure. HPC is urging the CFTC and SEC to establish rules that allow regulated entities (like brokers or exchanges) to fulfill their compliance obligations (e.g., KYC, market surveillance) while using builders and deployer seats to operate products on HyperCore. This includes seeking confirmation that publishing on-chain software doesn't trigger licensing requirements and creating exemptions for non-custodial wallets to route users to regulated derivatives.

QHow does Hyperliquid's modular tech stack compare to the structure of traditional finance (TradFi)?

AHyperliquid's modular technology stack mirrors the separation of duties found in traditional finance but reconstructs them on-chain with code-enforced logic. HyperCore acts as the combined exchange (DCM) and clearing layer (DCO), handling matching, margin, and settlement. Deployers, who stake HYPE tokens, take on a role analogous to a DCM by listing tokens and setting contract parameters. Builders function like brokers (FCMs), responsible for user onboarding and routing trading flow to HyperCore. This contrasts with monolithic crypto platforms like Coinbase that handle the entire process internally, resembling the segregated entity model of TradFi but operating on a single, global, 24/7 accessible platform.

QWhat is HIP-3, and how does its "permissioned" version enable a potential path to U.S. compliance?

AHIP-3 is Hyperliquid's framework that allows third parties to deploy and operate their own markets on the HyperCore infrastructure. A new "permissioned" version of HIP-3, currently on testnet, enables compliance by restricting market access to a whitelist of users. This allows a regulated entity (e.g., a licensed broker or exchange) to act as the deployer, create a market, perform KYC/AML checks, and only permit vetted, compliant U.S. users to trade on that specific market instance. It provides a clear technical pathway for regulated entities to operate on Hyperliquid while fulfilling their legal obligations.

QHow does Hyperliquid plan to prevent liquidity fragmentation between its permissionless native markets and new permissioned, U.S.-facing deployments?

AHyperliquid plans to prevent liquidity fragmentation through whitelisted market makers who will bridge liquidity between the separate order books of the permissionless native markets and the new permissioned deployments. Because all markets exist on the same L1 blockchain (Hyperliquid L1) and share collateral and margin pools, liquidity can flow seamlessly between order books without needing cross-chain bridges or platform transfers. This design allows the new compliant deployments to inherit the deep liquidity of the main Hyperliquid ecosystem while maintaining independent, regulated order books for U.S. users.

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Agent S: The Future of Autonomous Interaction in Web3 Introduction In the ever-evolving landscape of Web3 and cryptocurrency, innovations are constantly redefining how individuals interact with digital platforms. One such pioneering project, Agent S, promises to revolutionise human-computer interaction through its open agentic framework. By paving the way for autonomous interactions, Agent S aims to simplify complex tasks, offering transformative applications in artificial intelligence (AI). This detailed exploration will delve into the project's intricacies, its unique features, and the implications for the cryptocurrency domain. What is Agent S? Agent S stands as a groundbreaking open agentic framework, specifically designed to tackle three fundamental challenges in the automation of computer tasks: Acquiring Domain-Specific Knowledge: The framework intelligently learns from various external knowledge sources and internal experiences. This dual approach empowers it to build a rich repository of domain-specific knowledge, enhancing its performance in task execution. Planning Over Long Task Horizons: Agent S employs experience-augmented hierarchical planning, a strategic approach that facilitates efficient breakdown and execution of intricate tasks. This feature significantly enhances its ability to manage multiple subtasks efficiently and effectively. Handling Dynamic, Non-Uniform Interfaces: The project introduces the Agent-Computer Interface (ACI), an innovative solution that enhances the interaction between agents and users. Utilizing Multimodal Large Language Models (MLLMs), Agent S can navigate and manipulate diverse graphical user interfaces seamlessly. Through these pioneering features, Agent S provides a robust framework that addresses the complexities involved in automating human interaction with machines, setting the stage for myriad applications in AI and beyond. Who is the Creator of Agent S? While the concept of Agent S is fundamentally innovative, specific information about its creator remains elusive. The creator is currently unknown, which highlights either the nascent stage of the project or the strategic choice to keep founding members under wraps. Regardless of anonymity, the focus remains on the framework's capabilities and potential. Who are the Investors of Agent S? As Agent S is relatively new in the cryptographic ecosystem, detailed information regarding its investors and financial backers is not explicitly documented. The lack of publicly available insights into the investment foundations or organisations supporting the project raises questions about its funding structure and development roadmap. Understanding the backing is crucial for gauging the project's sustainability and potential market impact. How Does Agent S Work? At the core of Agent S lies cutting-edge technology that enables it to function effectively in diverse settings. Its operational model is built around several key features: Human-like Computer Interaction: The framework offers advanced AI planning, striving to make interactions with computers more intuitive. By mimicking human behaviour in tasks execution, it promises to elevate user experiences. Narrative Memory: Employed to leverage high-level experiences, Agent S utilises narrative memory to keep track of task histories, thereby enhancing its decision-making processes. Episodic Memory: This feature provides users with step-by-step guidance, allowing the framework to offer contextual support as tasks unfold. Support for OpenACI: With the ability to run locally, Agent S allows users to maintain control over their interactions and workflows, aligning with the decentralised ethos of Web3. Easy Integration with External APIs: Its versatility and compatibility with various AI platforms ensure that Agent S can fit seamlessly into existing technological ecosystems, making it an appealing choice for developers and organisations. These functionalities collectively contribute to Agent S's unique position within the crypto space, as it automates complex, multi-step tasks with minimal human intervention. As the project evolves, its potential applications in Web3 could redefine how digital interactions unfold. Timeline of Agent S The development and milestones of Agent S can be encapsulated in a timeline that highlights its significant events: September 27, 2024: The concept of Agent S was launched in a comprehensive research paper titled “An Open Agentic Framework that Uses Computers Like a Human,” showcasing the groundwork for the project. October 10, 2024: The research paper was made publicly available on arXiv, offering an in-depth exploration of the framework and its performance evaluation based on the OSWorld benchmark. October 12, 2024: A video presentation was released, providing a visual insight into the capabilities and features of Agent S, further engaging potential users and investors. These markers in the timeline not only illustrate the progress of Agent S but also indicate its commitment to transparency and community engagement. Key Points About Agent S As the Agent S framework continues to evolve, several key attributes stand out, underscoring its innovative nature and potential: Innovative Framework: Designed to provide an intuitive use of computers akin to human interaction, Agent S brings a novel approach to task automation. Autonomous Interaction: The ability to interact autonomously with computers through GUI signifies a leap towards more intelligent and efficient computing solutions. Complex Task Automation: With its robust methodology, it can automate complex, multi-step tasks, making processes faster and less error-prone. Continuous Improvement: The learning mechanisms enable Agent S to improve from past experiences, continually enhancing its performance and efficacy. Versatility: Its adaptability across different operating environments like OSWorld and WindowsAgentArena ensures that it can serve a broad range of applications. As Agent S positions itself in the Web3 and crypto landscape, its potential to enhance interaction capabilities and automate processes signifies a significant advancement in AI technologies. Through its innovative framework, Agent S exemplifies the future of digital interactions, promising a more seamless and efficient experience for users across various industries. Conclusion Agent S represents a bold leap forward in the marriage of AI and Web3, with the capacity to redefine how we interact with technology. While still in its early stages, the possibilities for its application are vast and compelling. Through its comprehensive framework addressing critical challenges, Agent S aims to bring autonomous interactions to the forefront of the digital experience. As we move deeper into the realms of cryptocurrency and decentralisation, projects like Agent S will undoubtedly play a crucial role in shaping the future of technology and human-computer collaboration.

1.1k Total ViewsPublished 2025.01.14Updated 2025.01.14

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