SEC Innovation Exemption · in effect since Sept 17, 2026
The Innovation Exemption is live. Is your permissioning?
Tokenized Securities Venues (TSV) can now operate under the SEC's Innovation Exemption, provided only verified participants and approved wallets can trade. InvestReady and accreditoken give you the operating workflow to meet that condition, plus the hands-on consulting to stand it up quickly.
Operational and compliance-workflow consulting. We work alongside your securities counsel. We don't replace them.
In effect
Innovation Exemption
A conditional exemptive order for on-chain trading of tokenized NMS stocks through permissioned venues and liquidity providers.
Effective Sept 17, 2026Expires Sept 17, 2031
Proposed
Regulation Crypto Assets
Proposed startup (up to $5M over four years) and fundraising (Tier 1 up to $20M, Tier 2 up to $75M a year) exemptions, plus an investment contract safe harbor.
Proposed Aug 18, 2026Comments due Oct 20, 2026
What the order expects
Permissioned access is the price of admission.
The Innovation Exemption is open to retail participants, not only institutions. What it does require is that you can show who is trading and which wallets they use.
Access
Verified participants only
Only verified or credentialed participants and wallet addresses may trade, enforced through mechanisms like wallet allow-lists.
Screening
Identity and eligibility checks
An active identity verification or eligibility screening process is a condition of operating a venue under the order.
Sanctions
OFAC compliance
A venue must be a U.S. person and comply with applicable OFAC sanctions requirements.
Oversight
Outsourcing keeps the duty
If a third party handles permissioning, the venue retains responsibility for compliance. You need a provider whose records you can stand behind.
Services
Three ways in. One more on the way.
Start with consulting, plug in the permissioning layer, or both. Every engagement is scoped after a 30-minute readiness call.
InvestReady ConsultingVenues and liquidity providers
Innovation Exemption readiness
A fixed-scope engagement that maps how your platform will meet the order's operating conditions, then builds the workflows and records to run it every day.
Operational gap assessment against the order's permissioning, screening and OFAC conditions
Participant onboarding and wallet allow-listing workflow design
Third-party provider oversight program and due-diligence file
Evidence, recordkeeping and monitoring procedures your team can run
Workplan and deliverables organized for handoff to your counsel
Format Fixed-fee engagementTimeline Scoped on the call
accreditokenVenues and liquidity providers
Permissioning as a service
The verification layer behind your allow-list. Every approved wallet ties back to a verified person or entity, with an evidence trail you can produce on request.
KYB on the venue, covered firms and institutional participants
Participant KYC with OFAC and global watchlist screening
Wallet-to-identity binding and an allow-list feed for your venue
Ongoing re-screening, with bot and compromise monitoring on wallets
Suspension workflow and exportable evidence records
Optional Bad Actor verifications on the venue's principals and covered firms
Format Setup plus monthly servicePricing Per the current guide
InvestReady ConsultingToken projects and issuers
Regulation Crypto Assets readiness
For teams planning to raise under the proposed startup or fundraising exemptions. We get the operational groundwork done now so you aren't starting from zero when the final rule arrives.
Fact-gathering on eligibility items such as U.S. organization and asset location
Project management for the disclosure workstream, run with your counsel
Investor onboarding design, including the proposed 10% investment limit
A tracker for the managerial-effort commitments that later bear on the safe harbor
Rule-change monitoring through the comment period and final adoption
Optional Bad Actor verifications on the issuer, its principals and promoters
Format Fixed-fee engagementStatus Rule is proposed, subject to change
InvestReadyComing soon
Reg Crypto Assets investor onboarding
A ready-made onboarding module for offerings under the proposed exemptions, built for high-volume retail participation.
Capture of the investor's representation on the 10% investment limit
Red-flag screening, so you aren't relying on a representation you have reason to doubt
KYC, OFAC and watchlist checks in the same flow
Optional Bad Actor verifications on the issuer side
KYB and KYC confirm who an entity or person is. A Bad Actor verification goes further, into regulatory and disciplinary history, including actions by the SEC, FINRA and the CFTC. Add it to any engagement so everyone behind the venue or the offering is covered, not just the people trading.
Delivered as an InvestReady Bad Actor Verification Certificate for each entity or person checked.
Who we can check
Venue operatorsCovered firmsIssuersOfficers and directorsSignificant ownersPromotersPlacement agents
Scope of engagement
Consulting and operations. Your counsel handles legal advice.
What we do
Workflow design and implementation
Verification, KYB, KYC, Bad Actor checks and screening
Vendor oversight and evidence files
Project management and rule tracking
Coordination with your legal team
What we don't do
Legal opinions or advice
Drafting or filing legal documents
Deciding whether an exemption applies to you
Broker-dealer or trading activity
Promising regulatory outcomes
InvestReady is not a law firm and does not provide legal advice. It is also not a broker-dealer. Our services are designed to support your compliance processes. Whether and how an exemption applies to your business is a question for your securities counsel. If you don't have counsel yet, ask us for introductions.
Why InvestReady
Independent since 2013. Still independent.
2013verifying investors since
42,000+verification certificates issued
55+countries served
0broker-dealer or venue ownership
No conflict in the permissioning layer.
Most verification providers are now owned by trading platforms or broker-dealers. We aren't, so the provider checking your participants isn't competing with your venue.
Built for regulated programs.
Our work supports some of the longest-running Reg D programs in the market, including a $1B+ Rule 506(c) demand note program we've supported for close to a decade.
How it works
From first call to go-live.
01
Readiness call
30 minutes on your model, timeline and existing onboarding stack.
02
Scoped proposal
A fixed-fee consulting scope and, if you need it, a permissioning setup plan.