Goldman Sachs said the U.S. Securities and Exchange Commission has opened a compliant route for tokenized stock trading in the United States, though the bank expects the order’s near-term impact to stay constrained by several conditions.
In a report dated Sept. 18, 2026, Goldman said the SEC issued an order on Sept. 17 granting certain exchanges and liquidity providers a five-year conditional registration exemption that allows them to offer tokenized stock trading in the U.S. These entities are referred to as tokenized securities venues, or TSVs. Goldman said the order marks the first broad authorization for tokenized U.S. equity trading and could support gradual growth in the market for tokenized American stocks.
Three limits keep the short-term effect in check
Goldman analyst James Yaro outlined three restrictions in the report.
First, only venues that use automated market maker, or AMM, order books can receive the exemption. Traditional exchanges and most centralized crypto exchanges use central limit order books, or CLOBs, and do not qualify.
Second, the exemption applies only to stocks with native tokenization features. Non-native, derivative-style tokenized equities are outside the scope.
Third, issuers can object before trading begins and block their shares from being tokenized.
Goldman said those three conditions are the main reason the exemption should have only a limited short-term effect.
AMM requirement narrows the addressable market
Goldman said AMMs are used mainly by decentralized exchanges, while CLOBs remain the standard model for traditional exchanges and most centralized crypto venues. AMMs provide liquidity for long-tail contracts through token inventories and fit newer markets better. As trading size grows, however, scarcity-based pricing in AMM smart contracts can increase slippage risk. CLOBs are more efficient in deeper and more liquid markets.
That technical difference, Goldman said, means the exemption is unlikely to reshape large, established markets in the near term.
The order also requires TSVs to operate under limits on the number of trading symbols and on trading volume. They must provide tokenized stock holders with shareholder rights and dividends comparable to those of holders of the underlying shares. AMM smart contracts must be auditable, public, and deployed on public blockchains. TSVs must also publicly disclose operating and trading information.
Goldman sees COIN as the biggest beneficiary
Goldman said Coinbase (COIN) and Robinhood (HOOD), both within its coverage universe, could build tokenized stock markets in the U.S. Among the two, Goldman said COIN is positioned to benefit the most.
According to the report, Coinbase’s tokenized stock brokerage product already has most of the features required under the exemption, including shareholder rights and dividends comparable to the underlying securities. Goldman said Coinbase would need only limited technical upgrades to offer tokenized stocks in the U.S. under the new framework.
Goldman also noted that Coinbase provides tokenization platform services and custody. If other companies use the exemption to build tokenized stock products, COIN could benefit there as well.
If Coinbase wants to use the exemption to build a tokenized stock exchange, though, it would need to develop new exchange technology because its current exchange uses a CLOB. Goldman said Coinbase routes brokerage trades to decentralized exchanges, and many decentralized exchanges use AMMs, which means that route could fit within the exemption.
Robinhood’s current tokenized stock product is offered only in Europe and is non-native tokenization, Goldman said, so it does not meet the exemption’s requirements. HOOD would need to develop a new tokenized stock product to qualify.
Goldman also said on-chain trading in tokenized stocks could increase the use of tokenized cash as a settlement currency and, in turn, support stablecoin adoption. Circle (CRCL), as the issuer of USDC, could benefit, and COIN also receives meaningful economic benefits from USDC.
Traditional exchanges face limited direct pressure
Goldman said the exemption creates only limited direct competitive risk for traditional exchanges. Nasdaq (NDAQ) and the New York Stock Exchange (ICE) already operate registered national securities exchanges and do not need an exemption from the definition of an exchange in order to trade tokenized stocks.
Instead, Goldman said both are advancing tokenization within existing market infrastructure rather than through the TSV route. That means they do not need to build AMM infrastructure to support their current tokenization plans.
Nasdaq received SEC approval in March 2026 to allow tokenized versions of DTC-eligible securities to trade on the same order book, with DTC handling tokenization and settlement. The pilot covers Russell 1000 constituents and index ETFs and runs for three years.
The New York Stock Exchange is pursuing a similar path and is developing a separate platform that supports 24/7 trading, instant settlement, and stablecoin financing, though that platform still requires regulatory approval.
Goldman said traditional exchanges retain a structural advantage in the most liquid stocks because tokenized orders on Nasdaq and the New York Stock Exchange interact with traditional equity orders in the same order book. By contrast, tokenized stocks on TSVs face limits on symbol count and trading volume and are open only to permitted participants. Goldman added that the DTC pilot covers Russell 1000 constituents and major index ETFs, which are exactly the kind of deep markets where CLOBs work better than AMMs.
Legislative reform remains the key variable
Goldman said the exemption is another step by the SEC and the Commodity Futures Trading Commission, or CFTC, toward clearer digital asset regulation.
Before this, the SEC proposed a crypto asset regulatory framework in August 2026 that would provide token issuance exemptions for smaller projects. On Sept. 17, the CFTC issued a no-action position exempting self-custodial wallet developers from registering as introducing brokers. Goldman said both agencies have signaled an intention to build a broader digital asset regulatory framework.
Still, Goldman argued that these regulatory moves are not enough to fully unlock broad digital asset adoption. Regulatory actions do not carry the permanence of legislation, the bank said, and future regulators could reverse or modify them through rulemaking.
Goldman said comprehensive legislative reform is still needed to fully unlock adoption, citing the CLARITY Act as an example. That bill failed in a procedural Senate vote on Sept. 15.
For traditional exchanges, Goldman’s view is that the competitive outcome under this exemption is better than what they would face if broader tokenization legislation were enacted. If the CLARITY Act were to pass and drive wider adoption, competitive pressure on traditional exchanges would be greater. Under the current exemption, the AMM requirement and issuer veto right limit the short-term spread of tokenized stocks, leaving the impact on traditional exchange volumes relatively contained.
Goldman’s conclusion was that the exemption opens the door to tokenized stocks, but not by much. The AMM requirement and issuer veto right keep that opening narrow. If issuers broadly choose to reject tokenization, or if the CLARITY Act returns to the agenda, the long-term value of this exemption framework could change materially.
This article is a rewrite and interpretation of a third-party broker research report. The ratings, target prices, earnings forecasts, and related judgments cited in the source material are the views of Goldman Sachs analysts in the Sept. 18, 2026 report, represent the position of that institution alone, and do not constitute investment advice.
