When the Beats Go Blockchain - Nasdaq’s Tokenization Rave Awaits SEC Approval

Carlton Fields
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Carlton Fields

Nasdaq is gearing up to drop one of the biggest beats the securities industry has heard since Nasdaq created the first electronic facility for trading securities: a proposal to permit tokenized securities to trade alongside non-tokenized securities. Under Nasdaq’s proposal, Nasdaq would collaborate on a new festival with the Depository Trust Company (DTC) to execute, clear, and settle tokenized securities. If the SEC presses “play,” tokenized trading could go live by late 2026.

Tokenization itself is a genre shift — representing real-world assets, such as securities, with cryptographically secured tokens. Tokenization opens new opportunities to efficiently transfer value between parties. In Nasdaq’s proposal, tokenized and non-tokenized securities would share the same order book, execute trades according to the same priority rules, and maintain identical rights, from voting to dividends to liquidation.

But Nasdaq is not the only festival organizer. The DTC, serving as Nasdaq’s tokenization partner, received an SEC no-action letter in December 2025, permitting the DTC to offer its tokenization services for three years without the festival shutting down. To the extent that the DTC and Nasdaq have varying visions of their festival, these differences will likely need to be resolved before the SEC signals the green light. The SEC will need to evaluate key priorities before approval, such as the types of legally permitted trading venues, ledger discrepancies, and settlement times — a full lineup of issues before the festival may begin.

Nasdaq is mixing older regulatory rules with the rhythm of blockchain infrastructure. If the SEC approves the proposal, capital markets could transition into a more modern pulse — one that turns every investor-selected tokenized trade into a synchronized dance routine with its non-tokenized security counterpart on Nasdaq’s trading facilities.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

© Carlton Fields

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Carlton Fields
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