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Look past the label and establish who holds each asset, what the automation service is authorized to do, and who can access the keys or sign transactions. A service may not hold your assets directly yet still have broad trading authority or rely on a separate broker, exchange, custodian, wallet or smart contract. “Non-custodial” is not, by itself, a guarantee of safety, regulation or insurance.
Is the investment service really non-custodial?
There is no single test that applies to every investment product. The answer depends on the assets involved, the account structure, the permissions granted and the service’s actual operations. Check securities and crypto separately: a product can use a broker to hold securities while using a self-custodial wallet for crypto, for example.
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For investment advisers, the SEC describes custody as holding client funds or securities directly or indirectly, or having authority to obtain possession of them. Its guidance treats withdrawal authority as an important warning sign and distinguishes authorized trading from broader powers to dispose of assets. The label on an app is therefore less useful than its agreements and actual permissions. See the SEC investor bulletin on custody of investment assets.
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Scan for outdated or missing drivers - takes under a minuteDriver Scan →Clear out junk files and repair common Windows errorsFree Scan →Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →Ask the provider to name the legal entity that holds each kind of asset and say whether it is a broker-dealer, bank, qualified custodian, exchange, wallet provider or another intermediary. Find out whose name appears on the account and whether you receive statements directly from the custodian. For advisers with custody, the SEC says a qualified custodian is generally required, subject to limited exceptions; the adviser should tell clients who the custodian is and how assets are held.
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Can the service withdraw or transfer my money?
Inspect the actual authorization, not just a summary such as “read and trade only.” In a brokerage account, the key distinction is whether the service can submit trades within your account or also withdraw cash or securities, change destination instructions, write checks or dispose of assets beyond authorized trading. The SEC’s custody guidance makes that distinction relevant to assessing an adviser’s authority.
For an exchange connection, open the exchange’s permission settings and review each API scope. For a wallet connection, examine the signing flow, contract approvals, delegated operators and any smart-contract administrator or upgrade powers. Determine whether the service can choose a destination address and transfer assets, or whether a separate signature from you is required for each transfer. The exact controls vary by platform, so confirm them in that platform’s own documentation.
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Also establish how to revoke access. Check whether you can disable an API key, revoke a wallet approval or end an account authorization yourself, and whether doing so depends on the provider’s cooperation. Keep a record of the permissions you approved and review them after changing services or account settings.
Who holds my crypto private keys?
Ask who generated the keys, where they are stored, who can access encrypted or decrypted key material, and who can sign or co-sign transactions. A public address is not a private key: a public key can help verify transactions and receive assets, but cannot authorize a transaction. The SEC’s crypto asset custody bulletin explains that with self-custody, the investor has sole control over access to the private keys and is responsible for securing them. Losing a key can mean losing access permanently.
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- WORKS WITH 1000+ ACCOUNTS: Compatible with popular accounts like Google, Microsoft, and Apple. A single YubiKey 5 NFC secures 100+ of your favorite accounts, including email, password managers, and more
- FAST & CONVENIENT LOGIN: Plug in your YubiKey 5 NFC via USB and tap it, or tap it against your phone (NFC), to authenticate. No batteries, no internet connection, and no extra fees required
- MOST SECURE PASSKEY: Supports FIDO2/WebAuthn, FIDO U2F, Yubico OTP, OATH-TOTP/HOTP, Smart card (PIV), and OpenPGP. That means it’s versatile, working almost anywhere you need it
- PRIMARY & SPARE KEYS: Just like having a spare house key, we recommend buying two YubiKeys - one for daily use and one as a spare. That way you’ll never get locked out of your accounts
A service’s interface can be separate from the wallet holding the keys. In an April 13, 2026 staff statement, SEC Trading and Markets describes a self-custodial wallet as one where neither the wallet provider nor an associated covered interface has custody of or access to the user’s encrypted or decrypted private key. That statement addresses specified interfaces preparing user-initiated transactions involving crypto asset securities; it is not a blanket legal finding about every automation service or asset. Read the statement and its stated scope.
Self-custody shifts key security and recovery responsibility to you. A hardware wallet is one optional physical cold-wallet form; the SEC notes that it can reduce exposure to internet cyberthreats, but it can also be lost, damaged or stolen. Using one does not establish that an automation provider has no other access or authority.
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- WORKS WITH 1000+ ACCOUNTS: Compatible with Google, Microsoft, and Apple. A single Security Key NFC secures 100 of your favorite accounts, including email, password managers, and more.
- FAST & CONVENIENT LOGIN: Plug in your Security Key NFC via USB-A and tap it, or tap it against your phone (NFC) to authenticate. No batteries, no internet connection, and no extra fees required.
- TRUSTED PASSKEY TECHNOLOGY: Uses the latest passkey standards (FIDO2/WebAuthn & FIDO U2F) but does not support One-Time Passwords. For complex needs, check out the YubiKey 5 Series.
- BUILT TO LAST: Made from tough, waterproof, and crush-resistant materials. Manufactured in Sweden and programmed in the USA with the highest security standards.
What happens if the provider, custodian or exchange fails?
Ask how client assets are separated from the provider’s own property and how they would be returned if the provider, custodian or exchange stopped operating. Find out whether assets can be lent, used as collateral, rehypothecated or commingled, and whether your consent is required. Request the written terms for any insurance, including what it covers and excludes, who pays its cost, and any transfer or account-closure fees. The SEC crypto custody bulletin identifies these as relevant diligence questions; an insurance label alone does not establish which losses are covered.
Rules depend on location and service type. For crypto custody services within MiCA’s scope in the EU, Article 75 requires a client position register and custody policy, return procedures and segregation of client holdings from provider holdings; it also addresses liability for certain attributable losses. It calls for position statements at least every three months. These requirements apply to in-scope services under that framework, not automatically to every platform worldwide. See MiCA Article 75.
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- WORKS WITH 1000+ ACCOUNTS: Compatible with popular accounts like Google, Microsoft, and Apple. A single YubiKey 5 secures 100+ of your favorite accounts, including email, password managers, and more.
- FAST & CONVENIENT LOGIN: Plug in your YubiKey 5 via USB and tap it to authenticate. No batteries, no internet connection, and no extra fees required.
- MOST SECURE PASSKEY: Supports FIDO2/WebAuthn, FIDO U2F, Yubico OTP, OATH-TOTP/HOTP, Smart card (PIV), and OpenPGP. That means it’s versatile, working almost anywhere you need it.
- BUILT TO LAST: Made from tough, waterproof, and crush-resistant materials. Manufactured in Sweden and programmed in the USA with the highest security standards.
How to verify a service before connecting an account
- List every asset and where it sits. Separate conventional securities, cash, crypto assets and tokenized securities. For each, identify the broker, bank, custodian, exchange, wallet or protocol involved; do not assume one custody arrangement covers everything.
- Get the governing documents. For securities, request the account-opening documents, advisory agreement, power of attorney and standing authorizations. Identify the custodian’s full legal name, check whose name is on the account and ask whether statements come directly from that custodian.
- Read each permission at the platform. Check brokerage authorities, API scopes and wallet or contract approvals where they are configured. Compare those settings with what the provider’s written disclosures say it can do.
- Trace who can authorize a transaction. For crypto, establish who controls keys and signing devices, who can co-sign, and whether an administrator or delegated operator can move assets or change contract behavior. Find out whether you must approve every transfer separately.
- Check the failure and recovery arrangements. Ask about segregation, asset use, return procedures, insurance terms and relevant fees. For self-custody, understand how you would recover access if a device is lost or the provider’s interface becomes unavailable.
- Verify the entity and keep evidence. Confirm the legal entity behind the product, its regulatory status for the activity it performs and the named custodian. Save agreements, permission records, statements and the method for revoking access; check for conflicts, venue relationships, fees and how trading information is used.
How to compare non-custodial claims
| What to check | Evidence to look for |
|---|---|
| Asset location | Legal name and role of the broker, bank, custodian, exchange, wallet or protocol holding each asset. |
| Withdrawal and transfer authority | Whether the provider can withdraw cash or securities, change destination instructions or transfer crypto without a separate user signature. |
| Key and signing control | Who controls keys, signing devices, recovery phrases, co-signers, contract administrators and delegated operators. |
| Scope of authority | Whether permissions are limited to instructed trading or extend to other disposal, lending, pledging or account changes. |
| Segregation and failure process | Whether client assets are separated and what legal and operational process applies to returning them if a provider fails. |
| Transparency and revocation | Whether agreements, statements, fee and conflict disclosures, permission records and a workable revocation method are available. |
What the “non-custodial” label does not establish
It does not establish that a service is safe, regulated, insured or free of control risks. A provider may operate an interface without holding a user’s private key while an intermediary or custodian elsewhere in the arrangement holds assets. Whether an arrangement amounts to custody depends on the asset, authority and actual operations, as well as applicable law.
Regulatory materials also have defined status and limits. The SEC’s crypto custody bulletin is educational guidance, not a rule, regulation or Commission statement, and it creates no new obligations. The SEC’s October 1, 2026 custody-rule fact sheet describes proposed amendments, not rules in force. Among the proposal’s conditions for adviser self-custody of crypto are safeguarding expertise, systems for private-key management, joint authorization by at least two people and separate client crypto addresses; these are proposed provisions, not current requirements established by that fact sheet. The proposal also describes quarterly reviews of certain adviser self-custody determinations and at least annual review of safeguarding systems. See the SEC fact sheet on the October 1, 2026 proposal.
For interfaces addressed by the April 2026 SEC staff statement, the statement identifies disclosures concerning the interface’s role, fees, conflicts, cybersecurity and venues. Its scope is limited to specified crypto asset securities activity and should not be generalized to all investment services. The legal result for a particular product depends on its assets, permissions, actual operation and jurisdiction.
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