Americas Crypto & Exchanges Overviewing the SEC innovation exemption order permitting trading of tokenized equities

Equity Research 18 September 2026 | 1:22PM EDT

Overviewing the SEC innovation exemption order permitting trading of tokenized equities

On 9/17, the SEC issued an order granting a 5-year characteristics1 are exempt, whereas non-native, James Yaro | conditional exemption from registration for certain derivative-like tokenized equities that certain brokers Goldman Sachs & Co. LLC exchanges and liquidity providers (collectively termed offer outside of the US (e.g., HOOD) are not permitted; Alexander Blostein, CFA tokenized securities venues [TSVs]), so that they can and 3) the order appears to permit issuers to refuse | offer equities on the blockchain (tokenized equities) in tokenization of their equity - if issuers broadly choose Goldman Sachs & Co. LLC

the US. We believe that this order broadly permits US to do so, this could limit the TAM for the product. The Matthew Weng | tokenized equities for the first time, which could lead to requirement that only AMMs may avail themselves of Goldman Sachs & Co. LLC the growth of the tokenized US equity market over time. the exemption appears to be specifically targeted at Aditya Sharma, CFA | In particular, we expect brokerage innovators and crypto enabling innovation among smaller, more nascent Goldman Sachs India SPL companies to potentially build in this space, given execution venues in the decentralized finance (DeFi) existing tokenized equity products, including tokenized space, given AMMs function better at smaller scale, Divyam Harlalka | equities outside of the US. However, there are a number whereas CLOBs are more effective for deeper, more Goldman Sachs India SPL of considerations that could limit broad US tokenized liquid markets. Specifically, the order offers Exchange Act Anthony Corbin | equities adoption, and/or the speed of growth, including: registration relief for TSVs that have AMMs (from exchange Goldman Sachs & Co. LLC 1) the need to build new order book tech, given only registration) and their liquidity providers (from dealer Lokesh Kumar Sangewar venues that use an automated market maker (AMM) registration). Registration relief is subject to certain | order book are permitted to avail themselves of the conditions, including: 1) tokenized equities traded on a TSV Goldman Sachs India SPL

exemption - traditional exchanges and most centralized are subject to limits on the number of symbols and volume Thirukumaran R | crypto venues currently use central limit order books traded; 2) a TSV must verify that the tokenized equity offers Goldman Sachs India SPL (CLOBs), rather than AMMs; 2) the need to build new tokenized equities products, given only tokenized equities that have certain native tokenization 1 Note: These include shareholder rights and dividends that are comparable to those offered on the underlying equity.

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Goldman Sachs Americas Crypto & Exchanges

certain native tokenization characteristics, specifically the same rights and privileges as the equivalent traditional stock; and 3) before beginning trading, the TSV must provide written notice and an opportunity to object to the issuer of the stock.

This order represents a further step to clarifying regulation around the use of blockchain technology in US financial services, alongside: 1) the previous Regulation Crypto Asset proposal from August, 2026 (report here), which proposed exemptions around token issuance for smaller projects; and 2) the CFTC’s no-action position (also from 9/17) to providers of passive software (see here), which exempted developers of self-custody wallets from registration as introducing brokers. We believe further regulatory reforms could follow, as both the SEC and…