SEC’s No-Action Letter for DoubleZero Signals Shift Toward Decentralized Infrastructure

U.S. Securities and Exchange Commission Commissioner Hester Peirce has long championed regulatory clarity for blockchain projects. This week, the SEC granted DoubleZero a no-action letter, signaling a potential shift in how decentralized physical infrastructure networks (DePIN) are treated. The decision allows DoubleZero to issue tokens without SEC registration complaints, provided they are used for specific DePIN purposes.

Peirce argues that DePIN projects operate outside traditional securities frameworks. These networks reward participants for providing real-world services—like storage or bandwidth—through peer-to-peer systems rather than centralized corporate structures. The Howey Test doesn't apply, she contends, because tokens compensate work rather than representing investments in managerial efforts.

The MOVE reflects growing recognition of decentralized infrastructure's unique economic model. No-action letters like this one provide much-needed guidance for blockchain innovators navigating uncertain regulatory waters.