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tokenized-rwa

Robinhood Stock Tokens

Adverse research finding
Research assessment
adverse
Firm shelf
excluded by policy
Model-client eligibility
ineligible
Selection
not considered
Action and amount
Not set by research
Reviewed
2026-09-23 · v1
Next review
2026-12-23
Research basis
Individual research
Chains
Robinhood Chain · hybrid
Symbols
SPY NVDA SPCX META GOOGL QQQ AAPL TSLA
Eligibility file
What the holder owns and who may hold it

Research, firm shelf, model-client eligibility, and advisor selection are recorded separately. The scheduled date is the outside bound; new evidence can reopen the file sooner.

Robinhood sells two things called stock tokens, and neither is a share a US advisor’s client can own. The tokens that live in wallets on Robinhood Chain are debt securities issued by Robinhood Assets (Jersey) Limited, an unregulated Jersey company wholly owned by Robinhood Markets, Inc. through Robinhood International, Inc., under a base prospectus dated 25 June 2026 that Liechtenstein’s FMA approved and notified to 29 other EEA states. Each token is a unit of a tracker certificate: the issuer owes the holder the price of a US stock or ETF, backed by shares Alpaca Securities holds for the issuer and pledged to a Swiss security agent. Holders ”do not have any direct rights or claims” to the share, no vote, and a claim limited to that series’ collateral. Under the SEC staff statement of January 28, 2026, that is a synthetic tokenized security. The older Classic Stock Tokens in the Robinhood Europe app are thinner still: an OTC derivative contract with Robinhood Europe, UAB, whose token cannot be transferred at all. Both are closed to US persons. The Jersey tokens are not EU-only; Robinhood says they reach more than 120 countries through Robinhood Wallet, with the US, Canada, the United Kingdom and Switzerland restricted. There is no minimum and no allowlist: anyone outside those places can buy on a Robinhood Chain DEX and move the token wallet to wallet. Only the Authorised Participant, today Bitstamp Global Ltd, may create or redeem with the issuer. An ordinary holder can redeem directly only if every Authorised Participant fails or the issuer posts a notice allowing it. The contracts carry more power than the prospectus describes. The prospectus limits destroying tokens to the issuer’s own holdings, redemptions and court-ordered cancellation. The deployed code, read on 2026-09-23, lets one role burn any holder’s balance, even while the token is paused or the holder is blocked. One contract holds the blocklist, the global pause and the code for all 195 tokens, and every one of its ten roles, including the key that can swap that code with no delay, is a single externally owned address. Robinhood Chain itself is rejected in this registry’s chain review. For a US advisor the answer is no: the client may not hold it, it is not the share, and one key can take it back.

The research file

What the holder owns

The base prospectus calls the Products ”debt securities which are securitised in the form of cryptographic tokens” and ledger-based securities under Article 973d of the Swiss Code of Obligations; Swiss law governs them. Each is ”a unit of a fully collateralised tracker certificate, which tracks the listed value” of one stock or ETF (FAQ 2.2). The issuer’s debt is the Redemption Amount: the underlying’s price on the reference exchange, less investor fees and execution costs, paid in US dollars. Condition 4.3 says holders have no direct right to the underlying or the collateral, no vote, no pre-emption right and no share in the underlying company’s profits. Nobody can demand the share: Condition 2.3 settles every redemption in cash.

The backing is real but held by others. Each series is collateralised by the underlying shares, held by Alpaca Securities LLC as broker and custodian, with cash at JPMorgan Chase Bank, N.A., London Branch. The issuer grants security over that collateral to Security Agent Services AG of Zug, which also acts as verification agent. Recourse is limited: if the collateral falls short, holders have no claim on any other asset of the issuer or any other series. The Final Terms read for NVDA, SPY, SpaceX and Apple all make Lending of the Underlying applicable, so the issuer may lend the shares to a Prime Borrower who may lend them on, against collateral of at least 100%. The issuer may substitute another special purpose vehicle as debtor, and change the terms, without holder consent.

Dividends are not paid out. The issuer reinvests them, net of withholding, and raises each token’s multiplier (read through uiMultiplier() under ERC-8056). The investor fee is 0% on subscription, 0% on redemption for 90 days after each Final Terms, then 0.05%, and may rise to 2.50% on 30 days’ notice. The issuer may also start a management fee of up to 0.50% a year and collect it by shrinking every holder’s balance.

Who may hold, and how a holder gets out

The issuer’s FAQ says the tokens ”are not available in the US or to US persons” and are restricted in Canada, the United Kingdom and Switzerland; its restricted-jurisdictions page adds eleven prohibited countries. The prospectus rests on Regulation S: the Products may be sold only outside the United States to non-US persons. Nothing confines them to the EU. Robinhood’s July 2026 launch post says they are available in Robinhood Wallet in more than 120 countries. Every Final Terms read states ”There is no Minimum Investment Amount.”

Only Authorised Participants subscribe with the issuer, after KYB; today the sole one is Bitstamp Global Ltd of the British Virgin Islands. Holders buy from it under its KYC, or swap on Robinhood Chain through RFQ aggregators and AMM pools such as Uniswap, where no one checks who they are. The prospectus calls the tokens ”freely transferable on the secondary market,” and the contract has no allowlist. Minting and burning run Monday 02:00 to Saturday 02:00 CET; trading on chain runs all week.

The exit is a sale. Under Condition 9.6 an ordinary holder may redeem with the issuer only if every Authorised Participant is insolvent, has resigned or been removed with no replacement for 30 days, or the issuer posts a notice allowing it, and then only after the issuer’s KYC, AML and sanctions checks. The issuer may reject any redemption on a negative finding. In practice a holder sells to a market maker or into a pool, at whatever price the pool offers. Robinhood publishes a page for tokens that trade 5% or more away from their underlying for seven trading days.

Who keeps the record, and who can freeze or take back

The chain is the record. The Registration Agreement in Condition 3 says ”the entitlement to the Products exclusively results from the Securities Ledger,” the token contract on Robinhood Chain, and one block confirmation makes a transfer legally effective. There is no transfer agent and no register behind it.

The same condition lists the powers the issuer keeps as Tokenizer: create, destroy, freeze, pause, block an address, update the code, and seize, meaning ”transfer Products to competent authorities.” It may use them on a Sanctions Event, on an order from a court or regulator, or where it finds money laundering. It limits destroying to tokens the issuer holds, redemptions and court cancellation. It may also move the whole ledger to another chain without consent.

The deployed contracts go further. Each token is a beacon proxy whose beacon is AccessControlsRegistry (0xe10b6f6b…), and every token runs implementation 0xb35490d6… (both verified on Sourcify). In that code, adminBurn(address, uint256) burns any holder’s balance for ADMIN_BURNER_ROLE with no pause check and no block check. BLOCKER_ROLE writes the one blocklist every transfer consults. PAUSER_ROLE stops all 195 tokens; TOKEN_PAUSER_ROLE stops one. BEACON_UPGRADER_ROLE can point every token at new code in one transaction, with no timelock. Read from the RoleGranted log and confirmed with hasRole on 2026-09-23, each of the ten live roles (admin, minter, burner, admin burner, two pausers, oracle pauser, beacon upgrader, factory upgrader, blocker) is held by one address with no contract code: a single key, not a multisig. The code can take a token from any wallet for any reason; the prospectus says it will not. This is the same gap the xStocks memo found in Backed’s Solana mints.

The size of the program

Robinhood’s asset API listed 195 active tokens on 2026-09-23, all on Robinhood Chain and nowhere else. Priced at DefiLlama’s quotes that day, their supply was worth about $166 million. SPY ($21.7 million) and NVDA ($20.5 million) lead, then SpaceX ($11.1 million), the SPDR Gold Shares token ($9.1 million), META ($6.2 million), GOOGL ($6.1 million), QQQ ($5.4 million), AAPL ($5.4 million) and TSLA ($4.8 million). The Robinhood Chain bridge’s TVL on DefiLlama, about $824 million that day, is ETH and other assets bridged from Ethereum; stock tokens are minted on Robinhood Chain and never cross it. Series 1 (NVDA) and the first batch of Final Terms were posted on 30 June 2026, a day before the 1 July mainnet launch; 196 Final Terms were posted by 23 September. On 21 September the issuer gave notice that it will add atomic settlement, hold USDG as temporary collateral with Bitstamp as a new custodian, and amend every series without holder consent once the FMA approves a supplement.

Classic Stock Tokens

The first generation, launched on Arbitrum in June 2025 and renamed Classic Stock Tokens in July 2026, is still sold in the Robinhood Europe app. Its Key Information Document, dated 1 July 2026, calls it an OTC derivative: ”you enter into a financial derivative contract with Robinhood Europe,” a Lithuanian investment firm the Bank of Lithuania supervises. Robinhood Europe is the sole counterparty; the product cannot be redeemed for shares and has no compensation scheme. Its Description of Services says the token ”is non-transferable and non-assignable” and is burned when the contract closes. It is a receipt for a bilateral contract, closed to US persons like the rest, and it never leaves the app. The Bank of Lithuania asked Robinhood for clarifications on its OpenAI and SpaceX tokens in July 2025.

The comparison

The Jersey tokens copy the xStocks design almost clause for clause: a Jersey SPV, a Swiss ledger-based tracker certificate, an FMA-approved prospectus, Alpaca as custodian and Security Agent Services AG as security agent. They differ in three ways. There is no minimum where xStocks sets $5,000 for direct dealing. Ordinary holders cannot redeem directly unless the Authorised Participant fails. And the token lives on one chain run by the issuer’s parent, which this registry rejects for its transaction filter and permissioned validators. Dinari’s global dShare gives the same answer by a different route: a Regulation S token with no title to the share. None of the three gives a US client a share; the only US-available tokenized equities in this registry are the issuer-sponsored records in the Superstate Opening Bell and Exodus memos.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

Inherited controls

The research above describes the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The most administered layer sets the position’s effective control grade; that is a control description, not a quality or suitability score.

ChainVerdictGradeControl constraint
Robinhood ChainAdverse hybrid one sequencer and two permissioned validators sit beneath an emergency council and transaction filter that can defeat the normal force-inclusion backstop.
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