Coinbase Global, Inc.

COMPETITION COMMISSION OF INDIA

Combination Registration No.C-2025/10/1342

Non-Confidential

16th December 2025

Notice under Section 6(2) of the Competition Act, 2002 given by Coinbase Global Inc. and DCX Global Limited

CORAM:

Ms. Ravneet Kaur

Chairperson

Mr. Anil Agrawal

Member

Ms. Sweta Kakkad

Member

Mr. Deepak Anurag

Member

Order under Section 31(1) of the Competition Act, 2002

1. On $31^{\text{st}}$ October 2025, the Competition Commission of India (Commission) received a notice (Notice), under sub-section (2) of Section 6 of the Competition Act, 2002 (Act), given by Coinbase Global Inc. (Coinbase) and DCX Global Limited (DCX) [Hereinafter, Coinbase and DCX are collectively referred to as the ‘Acquirers’]. The Notice has been filed pursuant to execution of the Share Subscription cum Shareholders’ Agreement dated $10^{\text{th}}$ October 2025 (SSSHA) inter alia between Coinbase and DCX.

2. The Notice is filed in relation to acquisition of up to an additional [unclear in source] shareholding in DCX (on a fully diluted basis) by Coinbase (Proposed Transaction), post which Coinbase’s shareholding in DCX will increase from [unclear in source] to [unclear in source]. Further, pursuant to the SSSHA, DCX proposes to acquire 100% of the equity share capital of Neblio Technologies Private Limited (Neblio), post which Neblio will become a direct subsidiary of DCX (Neblio Restructuring) [Hereinafter, Proposed Transaction and Neblio Restructuring are collectively referred to as the ‘Proposed Combination’. Further, Coinbase, DCX and Neblio are collectively referred to as the ‘Parties’].

3. In terms of Regulation 14 of the Competition Commission of India (Combinations) Regulations, 2024 (Combination Regulations), certain information(s)/clarification(s) relevant for the purpose of assessment of the Proposed Combination were sought vide letters dated $14^{\text{th}}$ November 2025 and $28^{\text{th}}$ November 2025. The complete response to the same was received on $05^{\text{th}}$ December 2025.

4. Coinbase is a publicly listed corporation incorporated in the United States. It operates global crypto-exchange platforms in more than 100 countries. It is the ultimate holding company of the Coinbase group, which includes Coinbase along with its affiliates that meet the Materiality Thresholds$^1$. Coinbase provides a platform that serves as a compliant on-ramp to the on-chain economy and enables users to engage in a wide variety of activities with their crypto assets in both proprietary and third-party product experiences enabled by access to decentralized applications. Among other things, it offers (i) consumers their primary financial account for the crypto-economy, (ii) institutions a full-service prime brokerage platform with access to deep pools of liquidity across the crypto marketplace, and (iii) a suite of products granting access to build on-chain.

5. In India, Coinbase is present through its affiliates, Coinbase India Private Limited (CIPL) and Coinbase India Services Private Limited (CISPL). CIPL is a wholly-owned indirect subsidiary of Coinbase in India, which has recently registered with the Indian

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$^1$ "Affiliates" in India are identified as: "affiliate" of another enterprise if that another enterprise has: (i) 10% or more of the shareholding or voting rights of the enterprise; or (ii) right or ability to have a representation on the Board of directors of the enterprise either as a director or an observer; or (iii) right or ability to access commercially sensitive information of the enterprise (collectively, ‘Materiality Thresholds’).

Financial Intelligence Unit (FIUIND/FIU) and launched its centralised digital exchange platform in India recently in October 2025. It provides Virtual Digital Asset (VDA) services including VDA consumer-to-consumer trading, derivatives, staking, and other services to Indian users. CISPL is an employing entity for individuals engaged in management and support services, including but not limited to, product, engineering, and design support; customer support (such as technical support); customer service relations; and administrative back-office support for captive use of its own group entities.

6. DCX, incorporated in Mauritius, is a company founded by Sumit Gupta and Neeraj Khandelwal (collectively, ‘Founders’). It also holds intellectual property in CoinDCX and BitOasis as well as the tech stack, which it licenses to various entities. In India, DCX Global has licensed its technology, brand, and other relevant IP and tech stack related to “CoinDCX” and “DCX” brands under a Licensing Agreement to Neblio.

7. Neblio, incorporated by the Founders, is an independent company, operating in compliance with regulatory framework prescribed by the FIU and applicable Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements. Pursuant to IP arrangements with DCX Global, which has certain common shareholders with Neblio, Neblio operates CoinDCX platform which allows customers to buy, sell and trade virtual digital assets. Neblio does not have any affiliates in India, which meet the Materiality Thresholds.

8. Based on the information provided in the Notice, it is noted that for the purpose of overlap assessment, the activities of the Coinbase Group (including affiliates) and DCX (including its affiliates and Neblio) in India have been considered. Accordingly, a horizontal overlap is identified in the ‘market for exchanges offering cryptocurrency services in India’ (Crypto-Exchange Market). Further, since both Coinbase and Neblio operate centralised crypto exchanges, the Parties have identified the narrow relevant market as ‘market for exchanges offering crypto currency services through Centralised Crypto Exchanges (CEX) in India’ (CEX Market).

9. The Commission decided to leave precise delineation of the relevant market open, as it was observed that the Proposed Combination is not likely to result in appreciable adverse effect on competition irrespective of the manner in which the relevant market is delineated, because of the reasons stated below.

10. Based on the submissions of the Parties, it is noted that the combined market shares of the Parties in the Crypto-Exchange Market and CEX Market are in the range of [unclear in source] only. Further, the incremental market shares as a result of the Proposed Combination are minimal. Also, each of these markets are characterised by the presence of other players. Thus, the Proposed Combination is not likely to raise competition concern in India.

11. Considering the material on record, including the details provided in the Notice and the assessment of the Proposed Combination based on the factors stated in Section 20(4) of the Act, the Commission is of the opinion that the Proposed Combination is not likely to have appreciable adverse effect on competition in India. Therefore, the Commission approves the Proposed Combination under Section 31(1) of the Act.

12. This order may stand revoked if, at any time, the information provided by the Acquirers is found to be incorrect.

13. The information provided by the Acquirers shall be treated as confidential in terms of and subject to provisions of Section 57 of the Act.

14. The Secretary is directed to communicate to the Acquirers accordingly.