Your Investment Portfolio. Onchain.
Today we submitted a proposal to the SEC's Crypto Task Force: let people invest in private companies based on what they know and do, not just how much they earn or what they own.
Since 1982, to qualify as an "accredited investor" you generally need $1 million in net worth or $200,000 in annual income (among a few other thresholds). Today, these thresholds lock out approximately 81 percent of U.S. households from private market investment.
Former SEC Commissioner Elad Roisman pointed out in 2020 that even some securities regulators might not meet the wealth test. When the people regulating markets can't participate in them, we're measuring the wrong thing.
We are advocating for two complementary paths to modernize access:
Qualification would be based on verifiable indicators, such as active product usage over a minimum period (say, 6+ months), employment status, code contributions, verified customer or commercial relationships, and demonstrated industry expertise.
In practice, this means a driver investing in the ride-sharing company they work for, or a developer owning equity in the project they help build. This is issuer-specific—qualifying for Company A doesn't qualify you for Company B. Smart contracts can be programmed to verify these criteria and revoke access if engagement ceases.
Traditional transfer agents rely on manual processes. Verifying usage-based criteria for thousands of investors simply wouldn't scale.
Blockchain infrastructure changes this. Fairmint has processed over $1 billion in private-company equity on blockchain rails, enabling privacy-preserving verification, pre-trade enforcement through smart contracts, and complete auditability.
As an SEC-registered transfer agent, if policymakers modernize eligibility categories, we can operationalize those criteria using both traditional and on-chain data sources.
This is our second submission to the SEC Crypto Task Force. In May 2025, we outlined how equity securities can operate compliantly on blockchain rails—covering transfer agent recordkeeping, regulatory observability, and standardized infrastructure.
Today's submission complements that prior submission by addressing who should be able to access these markets. Our vision is that of a compliant on-chain equity infrastructure that expands access to those who know companies best.
While accreditation rules do not directly regulate when a company goes public, they materially shape how, and from whom, companies raise capital while private. We're witnessing a fundamental restructuring of capital markets.
Companies went public early in the old model—Microsoft at under $1 billion in 1986, Amazon at $438 million in 1997. The largest IPOs in history are about to happen, and retail investors are locked out until after institutional investors have captured most value. SpaceX merged with xAI at a $1.25 trillion valuation ahead of a 2026 IPO, potentially the largest in history. OpenAI is targeting a $1 trillion public valuation. Anthropic raised at $350 billion.
The workarounds are telling. Secondary market platforms like Forge Global and EquityZen exist specifically because accredited investors need liquidity before IPOs. Meanwhile, companies are finding creative paths to public markets. Figure Technologies’ blockchain infrastructure demonstrates how technology can modernize capital markets.
The market is demanding access, and companies are building entire businesses around the gap in current rules.
Considerations of both fairness and market efficiency demand putting more individuals in the position to invest. When people building, using, and supporting companies can't invest in them, we're leaving economic signal on the table. Users often understand business risks better than external investors.
Current rules assume these people’s knowledge is insufficient to protect them from investment risk.
We've asked the SEC to advance knowledge-based examination standards, explore conditional issuer-specific accreditation, and engage with transfer agents on automated compliance infrastructure.
We are pleased with the responsiveness and interest demonstrated by the Commission to date, and remain confident that we can help progress the conversation around investor protection.
Read the full submission: Modernizing investor accreditation for on-chain capital markets.
Read the full press release: Fairmint Submits Usage-Based Investor Accreditation Recommendations to SEC
