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Research

Token allocation disclosures are not verifiable on-chain

Of 13 widely held tokens we reviewed, none published the addresses or contracts holding their team, investor or founder allocations, so no outsider can check a single one of those allocations against chain state.

Updated 2026-10-30. The review was carried out before we filed our comment on the SEC’s proposed Regulation Crypto Assets, and the findings are stated in that comment.

What we found

  • Tokens reviewed

    13 widely held tokens.

  • Published figures we could compare

    4 of the 13 published allocation figures specific enough to compare against chain state. The other 9 did not.

  • Published holding addresses

    None. No token in the sample published the addresses or smart contracts holding the team, investor or founder allocations.

Why it matters

A stated vesting schedule cannot be confirmed by anyone outside the issuer without the holding addresses. The supply itself, the vesting contracts and the addresses holding mint, upgrade, pause or admin roles are all recorded on-chain and timestamped, so the information exists; what is missing is a pointer to where to look. That is the gap between disclosure and verification, and it is the one our comment asks the SEC to close.

Method

We took 13 widely held tokens and read their public allocation disclosures, then asked two questions of each: are the published figures specific enough to compare against chain state, and does the issuer identify the addresses or contracts holding each allocation category. The second question is the one that decides whether a disclosure can be checked at all.

Limitations

Thirteen tokens is a small sample, selected for being widely held rather than at random, so these counts describe the sample and are not an estimate for the market. The finding that matters is not the proportion but the floor: zero of thirteen is enough to show the practice is not established, and a larger sample would be needed to say how rare it is.

What we recommended

That for each allocation category the issuer identify the holding addresses or smart contracts, or state that it cannot and why; and that it identify the addresses holding mint, upgrade, pause or admin roles. The full set of recommendations is in our write-up of the four comments, and the other filings are listed on our regulatory page.