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Tokenized real-world assets

Robinhood Stock Tokens

Not approved The evidence weighs against it

Review open since 2026-10-10: Robinhood Stock Tokens (tracker certificates by Robinhood Assets (Jersey) Limited on Robinhood Chain) on Robinhood Chain: the power to freeze a holder is now no, the file recorded yes (read at block 84111067). Ketju will review the file before any client action. A draft revision dated 2026-10-10 is under audit. The verdict stands until the review closes.

Verdict
Not approved
The evidence weighs against it
Who can freeze it
Mixed control
Withdrawals
The issuer’s FAQ says the tokens ”are not available in the US or to US persons.” They are restricted in Canada, the United Kingdom and Switzerland, and the restricted-jurisdictions page adds eleven prohibited countries.
Reviewed
2026-09-23
Researched memo

Summary

Ketju does not approve Robinhood Stock Tokens: they are closed to US persons, they give the holder a debt claim on a Jersey company instead of the share, and one key can burn any holder’s balance. The tokens in wallets on Robinhood Chain are debt securities issued by Robinhood Assets (Jersey) Limited, an unregulated Jersey company that Robinhood Markets, Inc. wholly owns through Robinhood International, Inc. Each token is a unit of a tracker certificate. The issuer owes the holder the price of a US stock or ETF. Alpaca Securities holds the backing shares for the issuer, and the issuer pledges them to a Swiss security agent. Holders ”do not have any direct rights or claims” to the share. The prospectus limits destroying tokens to the issuer’s own holdings, redemptions and court-ordered cancellation. The deployed code, which we read on 2026-09-23, lets one role burn any holder’s balance. A single externally owned address holds each of the ten roles on the contract that controls all 195 tokens. That includes the key that can replace the code with no delay. Ketju does not approve Robinhood Chain itself.

Research

Holder’s rights

Robinhood sells two products called stock tokens. The tokens on Robinhood Chain fall under a base prospectus dated 25 June 2026. Liechtenstein’s FMA approved it and notified it to 29 other EEA states. The base prospectus calls the Products ”debt securities which are securitised in the form of cryptographic tokens.” They are ledger-based securities under Article 973d of the Swiss Code of Obligations, and 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, because Condition 2.3 settles every redemption in cash. Under the SEC staff statement of January 28, 2026, the token is a synthetic tokenized security.

The shares exist, but other firms hold them. Each series is collateralised by the underlying shares, which Alpaca Securities LLC holds 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 we read for NVDA, SPY, SpaceX and Apple all make Lending of the Underlying applicable. The issuer may therefore 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.

Fees

The issuer does not pay out dividends. It reinvests them, net of withholding, and raises each token’s multiplier (read through uiMultiplier() under ERC-8056). The investor fee is 0% on subscription. It is 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.

Eligibility and withdrawals

The issuer’s FAQ says the tokens ”are not available in the US or to US persons.” They are restricted in Canada, the United Kingdom and Switzerland, and the restricted-jurisdictions page adds eleven prohibited countries. The prospectus relies on Regulation S: the Products may be sold only outside the United States to non-US persons. The tokens are not limited to the EU. Robinhood’s July 2026 launch post says they are available in Robinhood Wallet in more than 120 countries. Every Final Terms we 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 nobody 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, and trading on chain runs all week.

A holder gets cash by selling. Under Condition 9.6 an ordinary holder may redeem with the issuer only in three cases. Every Authorised Participant is insolvent; or it has resigned or been removed with no replacement for 30 days; or the issuer posts a notice allowing it. Even then the holder must first pass the issuer’s KYC, AML and sanctions checks. The issuer may refuse 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 controls it

The token contract on Robinhood Chain is the legal register of holders. The Registration Agreement in Condition 3 says ”the entitlement to the Products exclusively results from the Securities Ledger,” the token contract. One block confirmation makes a transfer legally effective. There is no transfer agent and no separate register.

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.” The issuer may use them on a Sanctions Event, on an order from a court or regulator, or where it finds money laundering. The condition limits destroying to tokens the issuer holds, redemptions and court cancellation. The issuer may also move the whole ledger to another chain without consent.

The deployed contracts allow more than the condition does. 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) lets ADMIN_BURNER_ROLE burn any holder’s balance with no pause check and no block check. BLOCKER_ROLE writes the one blocklist that every transfer checks. PAUSER_ROLE stops all 195 tokens, and TOKEN_PAUSER_ROLE stops one. BEACON_UPGRADER_ROLE can point every token at new code in one transaction, with no timelock. We read the RoleGranted log and confirmed each role 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, which means a single key. The code lets the role holder take a token from any wallet for any reason, and the prospectus says the issuer will not. The xStocks memo found the same gap in Backed’s Solana mints.

Size and holdings

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). DefiLlama showed about $824 million in the Robinhood Chain bridge that day. That figure is ETH and other assets bridged from Ethereum. Robinhood mints stock tokens on Robinhood Chain, and they never cross the bridge. The issuer posted Series 1 (NVDA) and the first batch of Final Terms on 30 June 2026, a day before the 1 July mainnet launch, and had posted 196 Final Terms by 23 September. On 21 September the issuer gave notice of three changes. It will add atomic settlement and hold USDG as temporary collateral with Bitstamp as a new custodian. It will amend every series without holder consent once the FMA approves a supplement.

Classic Stock Tokens

Robinhood launched the first generation on Arbitrum in June 2025 and renamed it Classic Stock Tokens in July 2026. Robinhood still sells it 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.” Robinhood Europe, UAB is a Lithuanian investment firm that the Bank of Lithuania supervises. Robinhood Europe is the sole counterparty. A holder cannot redeem the product for shares, and it has no compensation scheme. Its Description of Services says the token ”is non-transferable and non-assignable,” and Robinhood burns it when the contract closes. The token is a receipt for a bilateral contract. It is closed to US persons and it never leaves the app. The Bank of Lithuania asked Robinhood for clarifications on its OpenAI and SpaceX tokens in July 2025.

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. They have 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 that the issuer’s parent runs. Ketju does not approve that chain because of its transaction filter and permissioned validators. Dinari’s global dShare reaches the same result 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 tokenized equities in the Register that US clients can hold are the shares that issuers register for holders directly, in the Superstate Opening Bell and Exodus memos.

Sources

Each claim above comes from one of these sources. Where Ketju could not verify a number, the memo states that.

The asset and the chain

This memo covers the protocol. A position also holds an asset and settles on a chain. Whichever of the three holds the most power over the position decides who can freeze it. These tables describe control and do not judge quality.

ChainVerdictFreezeWhat it can do
Robinhood ChainNot approved Mixed control 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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