Tokenized U.S. equities are moving out of a crypto-native experiment and into the regulatory perimeter of the traditional securities market.
In a Sept. 21 report titled Equity Tokenization Primer: Innovation Exemption, Operating Models, Industry Structure and Potential Winners, Bernstein said the U.S. Securities and Exchange Commission’s new Innovation Exemption is a major turning point for the U.S. tokenized securities market. The firm said public blockchains, automated market makers, and DeFi infrastructure have now been brought into the existing U.S. securities trading framework for the first time.
Bernstein frames the exemption as a breakthrough for onchain equities
According to the report, equity tokenization had previously been concentrated in offshore markets or offered through third-party synthetic structures that gave users price exposure to U.S. stocks. The new exemption, by contrast, explicitly allows qualified tokenized securities venues to operate on public blockchains and certain DeFi rails.
Bernstein said that gives networks and protocols such as Ethereum, Solana and Uniswap their first practical validation inside a U.S. securities regulatory structure.
Near-term volume may stay limited, but the regulatory test bed matters more
Bernstein said the SEC has taken a cautious approach. Rather than setting up a permanent regime for tokenized securities, the agency is allowing qualified Tokenized Securities Venues to receive temporary relief from parts of the traditional exchange rulebook under specified conditions.
The report said the framework still includes multiple guardrails, including issuer participation requirements, limits on trading scale and caps on the number of securities that can be listed. For that reason, Bernstein does not expect the exemption on its own to generate large amounts of new trading volume or revenue in the short run.
Its main significance, in the firm’s view, is that the SEC is now permitting a real-world experiment in combining the traditional securities market with a 24/7 onchain capital market inside a regulated structure.
For regulators, that creates a way to observe the risks tied to onchain trading, settlement and market structure. For industry participants, it opens room to test how equities could be issued, transferred and settled on public blockchains. Bernstein said tokenized securities could begin to have a material effect on U.S. stock trading volumes only if rules mature over time and current limits on trading and listings are eased.
Bernstein outlines three main models for stock tokenization
The report said stock tokens in the market today are not a single product category. Bernstein divided them into three operating models.
Issuer-led model
In this structure, a listed company directly takes part in tokenizing its shares. The onchain token corresponds to the underlying stock and seeks to replicate the economic and governance rights attached to traditional shares as fully as possible, including ownership, dividends and voting rights. Bernstein said this comes closest, legally and economically, to true onchain equity.
Depository-led model
Under this model, a bank, custodian or another regulated financial institution holds the underlying securities and issues corresponding tokens onchain. Bernstein compared the setup to a depository receipt structure in traditional finance, with ownership records and transfer records moved onto blockchain infrastructure.
Third-party-led model
The third structure involves a platform purchasing or holding the underlying asset and issuing tokens to users that provide economic exposure to a specific stock. Bernstein said many early crypto stock products fit this category, with a design closer to stock price mapping or synthetic assets than to actual onchain equity.
The report also said the boundaries between the three models are starting to blur. More third-party issuers are using legal structures to pass through dividends, voting rights and even parts of ownership interests to token holders. Bernstein said that could shift the basis of competition away from which token looks most like a traditional share.
Distribution, liquidity and all-hours price discovery are the real moat, Bernstein says
If issuing stock tokens becomes easier, Bernstein argues that the durable edge will come from three areas: onshore distribution, liquidity and 24/7 price discovery.
The report said many U.S. listed companies have historically been cautious or openly opposed to offshore stock token products. One core reason is that those products are usually not issued with company authorization, leaving issuers without control over market structure, investor mix or price formation.
If tokenized securities can operate on regulated U.S. platforms while keeping blockchain features such as around-the-clock trading, faster settlement and DeFi composability, Bernstein said issuers’ attitudes could change. That is why the firm sees the Innovation Exemption as more than a blockchain wrapper around existing stocks. In its view, the framework could reshape how equities are issued, traded, settled and distributed globally.
Offshore activity has already shown there is real demand
Bernstein said that even if some offshore stock tokens do not meet the SEC’s definition of formal tokenized securities, they have already established one point: there is real global demand for onchain access to U.S. equities.
For overseas users who do not have easy access to the U.S. securities market, stock tokens offer an experience that is closer to crypto trading, including 24/7 access, onchain settlement, direct exchange against stablecoins and routes into DeFi.
The report said that product-market fit is already visible in trading data. Robinhood launched Robinhood Chain in July, and more than $160 million in stock tokens are now onchain there, with cumulative DEX volume above $10 billion.
Bernstein said that suggests stock tokens are no longer just a proof of concept. They are already supporting real onchain trading activity. The firm added that stock token trading also increases demand for the underlying blockchain networks, DEXs, stablecoins and other crypto-native infrastructure.
That dynamic, according to the report, is also an important backdrop for renewed capital attention on assets such as ETH, SOL and UNI.
Bernstein highlights five listed companies as potential beneficiaries
Among the public companies under Bernstein’s coverage, the firm said the benefit channels are not the same. Figure and Bullish are building tokenized securities products that sit closer to the issuer-led end of the market. If direct issuer participation becomes the dominant model for onchain equities, platforms that can provide issuance, trading and infrastructure services could gain an important position.
Robinhood and Coinbase, meanwhile, have already entered the offshore stock token market. Bernstein said stock tokens are not just another trading category for those two firms. If equities, crypto assets and stablecoins increasingly trade inside the same onchain system, both companies could bring traditional securities users deeper into their crypto infrastructure stacks.
The report said Robinhood has already started building its own onchain ecosystem. In that case, stock trading may produce more than brokerage commissions or payment-for-order-flow revenue. It may also feed revenue tied to the underlying blockchain, DEXs and other onchain businesses.
Bernstein identified Circle as another direct beneficiary. Whatever tokenization route equities eventually take, the onchain market will need a stable and liquid settlement asset, and stablecoins remain the most natural option.
The firm said USDC combines relatively strong liquidity, a regulatory compliance base and meaningful DeFi market share. As tokenized stock trading scales up, Bernstein said, USDC usage as a settlement currency for onchain securities could rise with it.
In Bernstein’s view, the end market is not limited to equity trading alone. Stock tokenization could also reprice a broader infrastructure stack, from public chains such as Ethereum and Solana to DEXs such as Uniswap, then out to trading gateways such as Coinbase and Robinhood and the stablecoin settlement layer represented by Circle. The SEC’s Innovation Exemption is the step that starts plugging this crypto-native stack into the U.S. traditional securities market.