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Should Base Be Regulated as an Exchange?

Olivia Capozzalo & Camila Russo
September 23, 2025

gm, Defiers!

Today’s big story:

  • With a potential token launch in the works, Base critics are now arguing it should be regulated like an exchange

In other news:

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Today’s Big Story

It’s a Stretch (and Low Move) to Call Base an Exchange

Critics of Base, Ethereum’s second-largest Layer 2, are coming out of the woodwork ahead of a possible native token launch, but the claims they’re making—that Coinbase’s Layer 2 should be regulated as an exchange—are a stretch.

The latest flare-up on Crypto Twitter began after Coinbase Chief Legal Officer Paul Grewal pushed back against the idea that Base is functionally an exchange. In a post, Grewal argued that Base is closer to cloud infrastructure, like AWS, than a trading venue: it batches transactions, it doesn’t match buyers and sellers, and it doesn’t hold custody of assets.

Still, a wave of critics seized on the idea that because Base’s sequencer controls transaction ordering, it should be seen as exchange-like. Solana-tied researcher Max Resnick wrote on X that “a centralized sequencer that can change the matching/execution of orders obviously must be regulated.” The underlying worry: if one entity has control over transaction ordering, it could tilt the playing field for traders, an argument that echoes the SEC’s expansive definition of “exchange.”

Exchange Claims Don’t Hold Up

But the “Base is an exchange” claim doesn’t hold up to closer scrutiny. Base’s is an Ethereum Layer 2 built on the OP Stack, providing infrastructure for applications to deploy on top of. It does not run a matching engine or pair off buyers and sellers; those functions are performed by decentralized applications like Uniswap, according to Base docs.

Independent monitors back this up. L2BEAT, the go-to tracker for rollups, shows that in April 2025, Base advanced to Stage 1 security status after establishing a Security Council, which is a multisig of external parties with a high threshold to approve upgrades. That means Coinbase no longer has unilateral control over the network’s core contracts. Far from looking like an exchange, Base is moving along a well-defined path toward greater decentralization, with checks and balances designed to prevent discretionary control.

The role of the sequencer is also narrower than critics imply. Sequencers order and bundle transactions before submitting them to Ethereum, but they don’t decide whether or not trades get executed. Execution is governed by the smart contracts users interact with, like Uniswap, Aave, or whatever else is deployed on Base. That’s a far cry from an exchange’s role under U.S. securities law, which involves bringing together orders of multiple buyers and sellers and providing a non-discretionary method to match them.

Vitalik: “Doing Things Right”

While critics have jumped on Base, it has also attracted a prominent fan.

Ethereum creator Vitalik Buterin said the chain is “doing things the right way:” it’s non-custodial, users are always protected by Ethereum’s Layer 1 security. In his words, and uses centralized features to proide stronger UX. Base is “doing things right” by progressively decentralizing and strengthening user guarantees.

Why It Matters Now

The timing of this debate is no coincidence. Last week, Base teased that it may soon launch a native token. Suddenly, whether Base looks like a neutral infrastructure network or like Coinbase’s captive exchange platform has major consequences. A token framed as infrastructure-level governance and sequencing (similar to OP or ARB) is one thing. A token that regulators view as an “exchange coin” like BNB or FTT would be an entirely different, riskier proposition.

That explains the sudden uptick in regulatory FUD: the framing today could shape how policymakers and investors perceive a Base token tomorrow.

The Bigger Picture

There’s also a broader angle worth mentioning. I have to agree with crypto lawyer Jake Chervinsky and Paradigm’s Dan Robinson here, when they argue that attacking competitors on regulatory grounds is shortsighted: all of crypto loses when the industry invites regulators to crack down harder. Calling Base an exchange might feel like a clever dunk, but if that line of reasoning were ever embraced in Washington, it could put every chain at risk.

This is pretty straightforward when you look at how Base works: the chain is infrastructure, not an exchange. Sometimes, CT tribalism makes people forget that while competition is stiff among chains, in the end, everyone is in the same industry, trying to rebuild finance. That’s already a tall order; no need to try to make it harder.

With love,

Cami, founder of The Defiant

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