Hyperliquid is preparing a structure that could bring its on-chain perpetual futures technology into the U.S. regulated market, with Kraken parent Payward positioned to use a new permissioned version of the protocol’s market-deployment framework.
The proposed arrangement would use Bitnomial, a derivatives exchange and clearinghouse registered with the Commodity Futures Trading Commission, to deploy and operate the market. NinjaTrader Clearing would serve as the futures commission merchant, or FCM, responsible for customer onboarding, accounts, and related access controls. Payward is the group entity named in the planned operating structure.
The model relies on HIP-3*, an extension of Hyperliquid’s HIP-3 framework for third-party perpetual futures venues. It adds an optional on-chain whitelist that could limit trading access to wallets approved after customer identity and eligibility checks. If the required approvals are granted, Bitnomial is expected to become the first CFTC-regulated HIP-3* deployer offering on-chain perpetual contracts to U.S. customers.
The proposal offers a possible route for a decentralized trading engine to operate behind the regulated customer, clearing, and market-surveillance structures required in U.S. derivatives markets. Rather than opening a standard permissionless market to anyone with a wallet, the deployer could determine which wallets can place orders and under what conditions.
Bitnomial and NinjaTrader Clearing would divide regulated duties
Under the outlined arrangement, Bitnomial would run the market itself, including the smart contracts handling clearing and settlement. It holds registrations as both a designated contract market, or DCM, and a derivatives clearing organization, or DCO.
A DCM registration covers the operation of a derivatives marketplace, including contract listings and trade surveillance. A DCO registration covers clearing, margin collection, settlement, and the management of counterparty risk after trades are executed.
NinjaTrader Clearing would operate as the FCM. In traditional futures markets, an FCM maintains customer accounts, handles client onboarding, and manages the relationship between customers and the clearing system. In the proposed HIP-3* design, that role would also connect regulated account controls with blockchain wallet permissions.
The separation creates a structure closer to existing U.S. futures-market arrangements than to a conventional crypto platform where one company handles matching, custody, customer access, and settlement. Bitnomial would manage the venue and clearing functions, while NinjaTrader Clearing would oversee the customer-facing account layer.
HIP-3* adds wallet permissions to Hyperliquid markets
HIP-3 allows external teams to launch perpetual markets using HyperCore, Hyperliquid’s trading infrastructure. A deployer can select the contracts it wants to list, choose price-oracle arrangements, and set leverage limits.
HIP-3* retains those functions while adding an on-chain permissioning tool. The deployer, or a sub-deployer it appoints, can maintain a whitelist of approved wallets. Once a customer completes identity checks through the regulated onboarding process, the associated wallet could receive permission to trade in the market.
That feature would give an operator a mechanism to apply customer-access rules directly at the smart-contract level. A wallet that is not approved could be prevented from trading, while a customer whose account status changes could potentially have permissions adjusted without altering the underlying market’s trading engine.
Hyperliquid has said the permissioned functions are optional. Existing HIP-3 markets would continue operating under their current arrangements, while new deployers could choose whether to activate whitelisting and other controls. The design therefore creates room for regulated, access-restricted venues on the same technical framework as markets that remain openly accessible.
Testing of the U.S.-oriented functions surfaced earlier on Hyperliquid’s testnet. A deployment labeled “Kraken HIP-3 test DEX” included tests involving wallet whitelists, order cancellations, reduce-only orders, and collateral transfers. Reduce-only orders allow traders to lower or close an existing position without increasing exposure, a feature commonly used in risk management.
Lighter is pursuing a different U.S. licensing model
Hyperliquid’s approach is emerging alongside a separate plan from Lighter, another on-chain perpetuals venue. Lighter has said it intends to apply to the CFTC in November 2026 for DCM and DCO registrations to support U.S. offerings that could include perpetual contracts and options.
The operational difference is substantial. Under the Payward-linked proposal, the legal and operational roles would be distributed among Bitnomial, NinjaTrader Clearing, and the HIP-3* market structure. Lighter has indicated it plans to seek the principal market and clearing permissions directly.
Lighter has also focused on distribution through external applications. The company said its Robinhood Wallet integration accounted for roughly 13% of Lighter’s network-wide trading volume in the third quarter, with users initiating activity through the wallet while Lighter supplied the perpetuals infrastructure. It has identified other wallets and centralized exchanges as potential distribution partners.
That strategy could give Lighter a route to U.S. customers through embedded trading interfaces if its regulatory applications succeed. Hyperliquid’s proposed structure, by contrast, puts the initial emphasis on connecting an existing on-chain trading framework to registered market, clearing, and brokerage entities.
Neither framework eliminates the regulatory complexity around perpetual futures in the United States. The HIP-3* model would need to reconcile blockchain-based wallet access with the customer protections, margin practices, surveillance obligations, and clearing procedures applied to regulated derivatives markets.
For Hyperliquid, the arrangement places the deployer rather than the base protocol at the center of those obligations. Bitnomial would decide which markets to list and operate under its registrations, while NinjaTrader Clearing would control who can access them. That division could become a template for other regulated firms seeking to use on-chain trading infrastructure without extending permissionless access to U.S. retail customers.
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