Bullish exchange profile: institutional trading, fees and regional entities

Bullish is a centralised digital-asset exchange built around institutional execution, with individual access in selected jurisdictions. Its order book combines customer orders with automated market making, while REST, WebSocket and FIX connections support professional workflows. Access to the brand can involve a regional counterparty rather than direct membership of the same venue. This distinction affects the contractual trade, product set and custody arrangement.[1]

The venue rules use automated price-time priority for order matching, with equal-price AMM orders sharing proportionally. An AMM instruction generates orders from a customer’s chosen parameters; the rules say it does not pool that customer’s assets with other members’ assets. Its inventory can change as orders fill. This is an exchange trading instruction, not a fixed interest account.[4]

The mobile app serves individual accounts in eligible regions and currently supports spot execution only. Institutional accounts cannot use it. Published pricing is the same as the website. Mobile-to-web login can use a scanned passkey prompt; web-to-mobile access uses a synchronised passkey or configured TOTP. Product availability on the desktop therefore should not be assumed to carry over to the phone.[19]

Fee classification uses trading volume, not simply whether an account belongs to a company. Standard institutional taker rates also depend on Same Direction Score: how often another participant’s trade immediately follows in the same direction. The rate displayed in the ticket or API prevails. Liquidation-engine fills add 0.5%.[12]

EU customers pay no additional regional charge over the referenced general tariff, but only their approved markets apply. Commission is only one part of execution cost: a market order can encounter a spread and several price levels, and a resting order may never fill. The comparative question is the cost of the intended transaction at its actual size and account rate.[13]

Borrowing interest is charged hourly in advance, with at least one hour payable even if the loan is repaid sooner. The published formula includes the asset’s APR, the borrowed quantity and a multiplier linked to the borrower’s taker fee. A displayed APR alone consequently does not describe the entire financing calculation. Interest is separate from the commission on opening or closing the trade.[14]

Perpetual funding runs hourly and uses the position held at the end-of-hour snapshot. Longs or shorts pay according to the funding rate, and the amount enters unsettled P&L before settlement. If the settlement asset is insufficient, an enabled account may automatically borrow; otherwise collateral can be sold to meet the obligation. Bullish may set funding to zero when price data is incomplete. An indicative rate therefore differs from a guaranteed holding cost.[15]

Deposits carry no exchange fee.[12]

For individuals, completing identity onboarding does not by itself release withdrawals. Source-of-wealth and tax declarations, plus address evidence where applicable, are required. Failure to complete the declarations within 30 days blocks deposits and trading as well as withdrawals. A manually reviewed declaration or address check can take one to two business days. This is an operational account restriction, not a minimum holding period for a trade.[25]

Crypto destinations are approved by network, so one whitelisted Solana address can serve supported tokens on that network. Approval requires 2FA and an email code in the web interface. Customers in certain jurisdictions must also verify a self-hosted wallet with a small transfer test. An address nickname can be edited, but changing the actual destination requires removing it and adding the replacement.[20]

The 24-hour whitelist lock is optional and off by default. Once enabled, it delays newly added crypto addresses, including API withdrawals to them. It does not affect existing approved addresses or bank accounts. Disabling the feature itself takes 24 hours, during which protection stays active. This should not be described as an automatic 24-hour hold on every new Bullish withdrawal.[21]

The withdrawal flow requires the correct network, destination and any memo, followed by passkey or TOTP approval. Once the blockchain withdrawal is initiated, it cannot be cancelled. Some tokenised securities additionally require issuer or transfer-agent whitelisting; approval inside the exchange alone may be insufficient.[24]

Account recovery depends on which credentials remain available. Losing 2FA or all recovery credentials sends the customer to support, which may request identity documents and a photograph. The inspected recovery article does not establish a universal post-recovery withdrawal-hold duration. Recovery review and the optional new-address lock are separate processes.[22]

Bullish describes customer assets as fully backed in segregated customer omnibus accounts, reconciled daily, and says it does not lend them or use them for its own investment or trading. Omnibus custody combines customers’ holdings operationally while separating them from company assets; it is not a wallet whose private keys the customer controls. These are company disclosures, rather than an independently reproduced reserves audit in this profile.[26]

BTH, Bullish’s treasury and asset-management division, is also a registered exchange customer and liquidity provider affiliated with the venue operators. The company discloses AMM and immediate-or-cancel trading by that business and says customer orders take priority at the same price. Account statements can identify trades with BTH as counterparty. That disclosure matters when assessing how much liquidity comes from the wider group.[26]

Individual onboarding follows a published list of supported countries and US states, with eligibility based on verified residence. The list separates rest-of-world, EU and US access and can differ from a group company’s licensing footprint. A regulator’s permission establishes what an entity may do; it does not establish that every resident, asset or client category is accepted. Product approval remains a separate account-level decision.[30]

The US contract requires individual residence in an eligible state. Corporate applicants need a US incorporation or registered office and a principal place of business in an eligible state. The current disclosure page lists licensed states separately from places where BUSO says a specific state licence is not required. It is not a promise of universal US product availability.[7][33]

The GI outage guide aims to give at least 24 hours’ notice of scheduled maintenance and warns that open orders may be cancelled. After affected trading maintenance, Bullish may provide a window, typically 15 minutes, for cancelling limit orders, terminating AMM instructions, adding collateral or transferring balances. Risk calculations and liquidation resume afterwards. Deposits sent during an outage may not appear in the balance until maintenance ends. The guide does not establish a telephone dealing facility.[36]

Bullish is publicly traded on the NYSE as BLSH and combines exchange services with CoinDesk’s media, data, indices and events businesses. Its August 2026 results release reported a second-quarter IFRS net loss of about $280 million and non-IFRS adjusted revenue of $92.6 million. These group figures measure different things and are not interchangeable with exchange commissions, trading volume or customers’ custody balances.[3]

The company’s unaudited metrics table reports August 2026 volume of $42.5 billion: $35.8 billion spot, $4.7 billion options and $2.0 billion perpetuals, subject to rounding. That gives a dated measure of trading activity for this institutionally focused venue. Although the linked report is titled September 2026, its visible table ends at August; no September value is inferred. The media business’s audience is not an exchange-user count.[2][1]

Operator

Regional Bullish entities; venue operators include Bullish (GI) Markets Limited and Bullish HK Markets Limited

Exchange model

Centralised

Service scope

Institutional order-book venue with AMM liquidity, regional spot access and eligible derivatives; individual mobile app is spot-only.

Client types

Retail clients; Professional clients; Institutional clients

Pricing publication

Public and quoted pricing

Pricing scope

Public market-category tariff with account-specific rates; regional and negotiated arrangements can differ.

Funding scope

Approved crypto destinations and regional bank rails; declarations and account controls determine withdrawal availability.

Custody and asset handling

Regional custodial arrangements and customer omnibus balances; HK insurance and derivatives default fund have distinct scope.

Client eligibility

Verified residence, accepted account category and product approval; EU and US counterparties provide separately scoped services.

Support

Email support, regional formal complaints and public service-status page.

Authorisation and registration scope

GFSC venue permissions, German MiCA custody/exchange/execution/transfer authorisation, SFC licensed HK venue and NYDFS US licences apply to named entities.

Exchange metadata checked 20 Oct 2026Source 1Source 5Source 10Source 9Source 8Source 11Source 12Source 30Source 26Source 34Source 19

History exports produce a ZIP containing separate CSV files and a data dictionary for trades, spot balances, subaccount transfers, deposits, withdrawals and OTC activity. Requests are limited to 100 per subaccount per day, access follows subaccount permissions, and generated files remain available for 30 days. Other transaction types may require the relationship manager or support. These operational records do not by themselves calculate a customer’s complete tax liability.[37]

Some trading symbols use multiplied units: one SHIB1M represents one million SHIB. Custody API endpoints use ordinary token quantities instead of the multiplied trading format. Integrations and exports must keep those unit conventions distinct to avoid a million-fold quantity error; a trading symbol is not necessarily the withdrawal asset label.[39][24]

The EU terms address six years of dormancy from the last instruction, after which assets may be disposed of under internal procedures. They require a written warning 30 days before that point and allow termination on ten days’ notice. This is a dormant-asset procedure, not evidence of a recurring monthly inactivity tariff.[6]

Bullish’s Telegram AI service agent is available to eligible institutional customers for answers based on public help, API, FIX and connectivity documentation. Its article says it does not retain conversation context. No authority to place trades, move funds or manage an account is described. It should be treated as an information interface; account instructions require the relevant authenticated service.[38]