Blockchain Legal Resource

In a recent social media post and television interview, Securities and Exchange Commission Chairman Paul Atkins announced that US capital markets are "poised to move on-chain.” At the same time, on December 11, 2025, the SEC staff issued a no-action letter to a prominent registered clearing agency and securities depositary to launch a  securities tokenization pilot program. The pilot program will allow participants to transfer tokenized securities to registered wallets of other participants.

The no-action letter imposes a series of conditions on the trading platform and grants three-year waivers from various provisions of the federal securities laws to facilitate operation of the pilot program. Under the no-action letter, tokenized securities trading is limited to certain large-cap companies, Treasury securities, and exchange-traded funds that track major stock indices. The depositary has agreed to provide quarterly reporting to the SEC staff on a range of data points regarding trading activity.

The no-action letter also calls for a measure of public transparency. For example, the depositary must disclose the blockchain and tokenization protocols applicable to the pilot program, a list of approved blockchains, and any fees or charges imposed on users in connection with the program. The letter further requires the depositary to provide participants with regular reporting on account information and related data. The SEC imposed several other conditions as well.

This step marks the SEC’s latest efforts to modernize its securities regulatory regime to facilitate innovation in the blockchain space. We expect 2026 to be an active year for the SEC on this front.