SEC-Registered Transfer Agent Proposes Allowing Product Users and Contributors to Qualify as Investors
NEW YORK, Feb. 5, 2026 /PRNewswire/ — Fairmint, a pioneer in on-chain equity infrastructure, has submitted written recommendations to the Securities and Exchange Commission’s Crypto Task Force proposing a new path for individuals to qualify as accredited investors based on their knowledge, expertise, or sophistication as investors. The full submission is available here: Modernizing investor accreditation for on-chain capital markets
The proposal, which complements Fairmint’s prior submission to the Task Force regarding a framework for on-chain equity securities, expands on an important element of that framework: the accreditation rules that determine who may invest in private placements of securities. More meaningful accreditation rules would allow individuals to invest in particular companies based on verified relationships, such as sustained product usage, employment history, code or other work contributions, commercial engagement with a company, or industry expertise. Current accredited investor rules for individuals mostly rely on income or wealth thresholds, requiring, for example, $1 million in net worth or $200,000 in annual income.
Two-Part Reforms
The submission proposes two complementary approaches:
Knowledge-Based Accreditation: Development of a financial sophistication exam that would qualify investors regardless of wealth or income, similar to professional certifications the SEC added to accreditation criteria in 2020, but more easily distributable online and not reliant on sponsorship by an SEC-registered organization or other complex prerequisites.
Usage-Based Accreditation: A new category allowing investors to qualify for specific offerings based on:
- Active product usage over a minimum period, documented on-chain
- Employment at the issuing company
- Code contributions to open-source protocols or communities
- Existing customer or supplier relationships
- Demonstrated expertise in the company’s industry
The proposal is complementary, not an alternative, to the current framework, and does not comment more broadly on investor protection, disclosure requirements or anti-fraud provisions.
Regulated Infrastructure for On-chain Accreditation
As a transfer agent, Fairmint maintains records of securities ownership for private issuers and applies transfer restrictions and other conditions specified by issuers and applicable law. Fairmint’s Open Cap Table Protocol can verify relationships without exposing personal data. Smart contracts encode eligibility requirements directly into securities infrastructure, preventing transfers to wallets that don’t meet regulatory criteria. Fairmint’s blockchain-native cap table infrastructure has successfully processed over $1 billion in securities transactions, providing a proven foundation for the future of on-chain equity.
The submission suggests that, if policymakers determine that additional accreditation eligibility categories are appropriate, SEC-registered entities, including transfer agents and broker-dealers, could operationalize and supervise those criteria using both traditional and on-chain data sources. The full recommendations submitted to the SEC Crypto Task Force can be accessed at: Modernizing investor accreditation for on-chain capital markets
About Fairmint
Fairmint is an SEC-registered transfer agent building on-chain equity infrastructure. The company turns capitalization tables into smart contracts, facilitating the issuance, management and transfer of equity securities. Fairmint’s Open Cap Table Protocol enables programmable equity with embedded compliance and real-time settlement. Founded in 2019 by Joris Delanoue and Thibauld Favre, Fairmint has processed over $1 billion in securities transactions. Equity moves on-chain at Fairmint.com
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SOURCE Fairmint
