OCC Responds to Request for Comment on the Extension of Standard Futures Contracts to 24/7 Trading and on Perpetual Contracts Referencing Physically Delivered or Storable Energy Commodities

On June 25, the CFTC issued a Request for Comment on two related developments in the energy derivatives markets: the extension of standard energy futures contracts to a 24/7 trading schedule without any change to their fixed expiration, delivery, or settlement terms, and the potential listing of perpetual contracts referencing physically delivered or storable energy commodities, such as crude oil. 

On August 26, 2026, OCC submitted a comment letter responding to the CFTC’s request for comment. OCC’s comment raised the following key points: 

• OCC believes that the extension of trading hours to 24/7 is best accomplished through a deliberate and phased progression in coordination with industry participants rather than an immediate move to fully continuous operations.
• Additional risk management tools are necessary for a DCO to effectively manage the risk of 24/7 trading compared to regular trading hours. Primarily, DCOs need to be able to manage their credit exposure at a time when traditional payment rails are closed.
• While many offshore marketshave relied on auto-liquidation to manage the risks of perpetual contracts, auto-liquidation on its own is not always an adequate foundation for managing risk across a market, particularly during periods of stress.

OCC’s full letter is available here.