CFTC Extends Public Comment Period on Proposed Rule on the Extension of Standard Futures Contracts to 24/7 Trading and on Perpetual Contracts Referencing Physically Delivered or Storable Energy Commodities

What Changed

• - The CFTC has extended the comment deadline on the RFC regarding 24/7 trading of standard futures contracts and perpetual contracts in energy markets by 30 days, moving the due date to 26 August 2026.
• The RFC focuses on the extension of standard futures contracts, including energy futures, to a 24/7 trading schedule while keeping fixed expirations but allowing potentially material economic changes to delivery or settlement terms.
• The RFC separately focuses on the listing and regulation of perpetual contracts that reference physically delivered or storable energy commodities, such as crude oil, and that have no fixed expiration date and use funding rate mechanisms.
• The Commission has added additional questions to the original RFC to probe market integrity, price formation, operational resilience, customer protections, and risk management implications of 24/7 trading and energy perpetuals.
• The RFC builds on and is informed by the CFTC’s May 29, 2026 coordinated actions on perpetual contracts and 24/7 trading in digital commodities, including the Policy Statement on perpetual contracts, staff advisory on 24/7 operations, and approval of
• All comments submitted in response to the RFC will be publicly posted on Regulations.gov, increasing transparency around industry positions and potentially shaping future rulemaking, guidance, or policy statements.

Suggested Considerations

• Identify and convene an internal cross‑functional working group (trading, risk, operations, compliance, legal, and IT) to assess potential impacts of 24/7 trading and energy perpetual contracts on your firm’s business model and control environment.
• Perform a gap analysis of current trading, clearing, surveillance, margin, and risk management frameworks against the operational and risk expectations articulated in recent CFTC staff advisories and policy statements on 24/7 markets and perpetual contracts.
• Draft and submit a data‑driven comment to the CFTC by 26 August 2026 addressing the RFC questions most relevant to your activities, including empirical analysis of liquidity, price formation, manipulation risk, funding rate behavior, and customer protection in energy derivatives.
• Review and update internal policies and procedures for trade surveillance, market abuse monitoring, and manipulation detection to address continuous 24/7 trading windows and any contemplated use of energy perpetual contracts.
• Assess whether current staffing models, systems support, and incident‑response processes can support 24/7 trading or clearing operations, and document enhancements or mitigations that would be needed to maintain operational resilience.
• Evaluate margin methodologies, stress testing, and collateral management practices for their ability to capture the risk characteristics of perpetual contracts (including funding rate dynamics) and extended trading hours in energy markets.

Key Dates

Who is Affected