The SEC issued a no-action letter stating it “will not recommend enforcement action” against DoubleZero, finding the 2Z token does not resemble a security — clearing the way for DoubleZero’s Solana mainnet-beta launch and participant rewards without immediate SEC enforcement risk.
-
SEC confirms 2Z is not treated as a security under its stated facts.
-
DoubleZero’s 2Z will be earned by network contributors and later stakable; mainnet-beta launches on Solana.
-
DoubleZero raised $28M in a token round; DePIN sector growth cited by World Economic Forum estimates.
DoubleZero no-action letter: SEC says 2Z is not a security, clearing Solana debut — read key takeaways and next steps for DePIN projects. Learn more.
What is the SEC no-action letter for DoubleZero?
The SEC no-action letter informs DoubleZero that the Commission “will not recommend enforcement action” based on the facts presented, effectively saying the 2Z token does not resemble a security. This clears regulatory uncertainty for the token’s Solana mainnet-beta debut and participant reward mechanics.
How did the SEC reach this decision?
The two-paragraph letter assessed DoubleZero’s structure and token mechanics, noting programmatic transfers tied to network participation. The SEC’s review considered factors such as the token’s functionality, the absence of token sales used to fund platform development, and marketing focused on utility rather than profit.
How does the 2Z token work on Solana?
DoubleZero’s 2Z is designed as a functional incentive: users contributing hardware or bandwidth to the network earn 2Z based on performance and reliability. According to DoubleZero, tokenholders will later have staking options to secure network operations and receive additional protocol-level incentives.
| Feature | 2Z Token | Traditional Security |
|---|---|---|
| Primary purpose | Incentivize infrastructure participation | Raise capital or promise profit |
| Transfer restrictions | Programmatic transfers to contributors | Often freely tradable as investment |
| Regulatory outcome | No-action letter (per SEC facts) | Subject to securities law |
Why does this matter for DePIN projects?
Regulatory clarity reduces legal risk for decentralized physical infrastructure networks (DePIN). Experts quoted in reporting — including Jack Graves, Syracuse University College of Law — say the letter creates a limited safe harbor under an assumed set of facts, enabling builders to operate with more certainty.
SEC Commissioner Hester Peirce noted that these tokens differ from shares or promises of profit and function primarily as incentives for infrastructure buildout. Arie Trouw, CEO of XYO, emphasized that treating such tokens as securities would hinder real-world infrastructure deployment.
How can projects seek SEC no-action clarity?
Projects can pursue clarity through documented, transparent steps. The following HowTo schema summarizes a standard approach for requesting a Commission response.
Frequently Asked Questions
Does the SEC no-action letter mean 2Z is definitively not a security for all purposes?
The no-action letter states the SEC will not recommend enforcement based on the specific facts DoubleZero provided. It is not a blanket legal determination for all circumstances; future facts or marketing could lead to different outcomes.
When does DoubleZero’s mainnet-beta launch?
DoubleZero’s mainnet-beta is expected to go live on Friday, with early contributors eligible to earn 2Z tokens tied to performance and reliability metrics.
Key Takeaways
- Regulatory clarity: The SEC’s no-action letter reduces immediate enforcement risk for 2Z under the facts presented.
- Functional token: 2Z is framed as an incentive for infrastructure contribution, not an equity-like promise.
- Industry impact: The decision signals a potential shift in how regulators view DePIN tokens and could influence project behavior and funding.
Conclusion
The SEC no-action letter for DoubleZero marks a notable development for DePIN projects and token design, as it finds the 2Z token does not resemble a security under the presented facts. Project teams should document mechanics, remain transparent, and monitor regulatory updates. COINOTAG will continue to track developments and publish updates as new information becomes available.
