SEC Staff No-Action Relief for DTC Pilot Provides a Pathway for Tokenized Securities

On December 11, 2025, the staff of the Division of Trading and Markets of the Securities and Exchange Commission issued a no-action letter to The Depository Trust Company (“DTC”) concerning a pilot version (the “Preliminary Base Version”) of a securities tokenization program, referred to as the “DTCC Tokenization Services." The letter permits DTC to conduct a limited, voluntary, three year pilot under which DTC participants may elect to have their security entitlements to DTC-held securities recorded using distributed ledger technology, rather than exclusively through DTC’s current centralized ledger. While the relief is subject to conditions and limited in scope, it materially accelerates DTC’s ability to launch the pilot version relative to a traditional rule filing and approval process and is a significant step toward on-chain market infrastructure. DTC plans to launch the Preliminary Base Version in the second half of 2026.