Decentralized physical infrastructure networks (DePIN) are gaining recognition as a transformative application of blockchain technology, and U.S. Securities and Exchange Commission (SEC) Commissioner Hester M. Peirce underscored their importance in a Sept. 29 statement. Citing the SEC’s Division of Corporation Finance’s no-action letter regarding Doublezero’s token distributions, Peirce argued that these models highlight how innovation can flourish when regulators avoid stretching their authority beyond congressional intent. She stressed that the SEC was created to oversee securities markets, not to police all forms of economic coordination.
Peirce stated:
Today’s no-action letter from the Division of Corporation Finance concerning Doublezero’s token distributions designed to facilitate the programmatic functioning of a decentralized physical infrastructure network (i.e., DePIN) offers an opportunity to reflect on how we, as regulators, can foster innovation without expanding our reach beyond what Congress has mandated.
She outlined that DePIN tokens serve as incentives for providing tangible resources—such as bandwidth, storage, or energy—rather than speculative assets designed to attract outside capital.
Because participants earn rewards through active contributions, she noted, these tokens lack the hallmarks of securities offerings and do not satisfy the Howey Test.
The SEC commissioner further emphasized that treating these projects as securities would hinder the development of distributed service networks and risk slowing broader adoption of blockchain technology. Instead, she asserted, markets should determine whether these decentralized infrastructure efforts succeed. Peirce concluded that the SEC’s responsibility is to listen to innovators, apply its statutory mandate with precision, and avoid forcing every new use case into outdated frameworks. The Doublezero no-action letter, she said, demonstrates how regulatory restraint can allow builders to focus on real-world innovation rather than compliance burdens.