A party that qualifies as an exempt commercial entity is eligible to participate in ICE's OTC markets. Participants must satisfy certain asset-holding and other criteria, able to incur risks relating to a particular commodity or have the proven ability to make or take delivery of a given commodity. Financial institutions that provide risk-management or hedging services to these entities are also candidates for participatory status.

Registered traders and locals with floor or electronic trading privileges on any regulated U.S. futures exchange qualify as exempt commercial entities and are eligible to execute OTC transactions on the ICE trading platform. All qualifying criteria is outlined in the below Annex B. Before making a transaction each applicant must execute ICE's standard Participant Agreement, which governs the terms and conditions of the participant's relationship with ICE and grants a non-exclusive, non-transferable, revocable license to access the ICE platform.