Blockworks Asks SEC to Make Token Projects Disclose Market-Maker Deals and Promoter Payments

Introduction

Blockworks, a crypto‑data and media firm, has filed a comment letter on the SEC’s proposed Regulation Crypto Assets. The company asks the agency to tighten disclosure requirements for token projects and to recognize a new type of filing agent that could streamline on‑chain reporting. The comments are due on Oct. 20, 2026, and the proposals could shape how emerging crypto offerings disclose financial and operational details.

More granular disclosure requirements

Blockworks wants the SEC to embed specific line items from its Token Transparency Framework into the final rule. Under the current draft, issuers must cover broad topics such as token supply, lock‑up periods, and related‑person holdings, but the language leaves the exact content open‑ended. Blockworks proposes that issuers also disclose:

• Token loans and liquidity arrangements – details on any borrowing of tokens or mechanisms used to maintain market liquidity.
• Agreements with exchanges and market makers – the terms of contracts that facilitate trading and price stability.
• Payments to advisers, influencers, and promoters – any token or cash compensation provided to third‑party promoters.
• Key wallet and contract addresses – the on‑chain locations that hold or manage the token.
• Supply‑calculation methodology – a clear description of how total and circulating supplies are derived.

By making these items mandatory, Blockworks argues that investors would gain a clearer picture of a project’s financial health and potential conflicts of interest.

Introducing a Qualified On‑Chain Disclosure Agent

Another centerpiece of Blockworks’ letter is the call for a new filing role: the Qualified On‑Chain Disclosure Agent (QODA). This independent provider would be subject to standards set by the SEC and would handle the technical collection and verification of on‑chain data. The envisioned workflow includes:

1. Connection to project wallets and contracts – the agent’s software pulls publicly visible on‑chain information.
2. Project‑provided supplemental data – issuers fill in any non‑on‑chain details required by the rule.
3. Verification and approval – the agent checks the completeness and accuracy of the filing before submission.
4. Public archive – each filing is stored in a searchable, timestamped repository, preserving a clear audit trail.

The SEC’s current proposal does not mention a third‑party filing agent, so Blockworks is suggesting a structural change that could reduce the reporting burden on issuers while enhancing data integrity.

Handling projects without existing filings

Blockworks also addresses tokens that have never filed a disclosure or have ceased reporting. It proposes two mechanisms:

• Third‑party disclosures – exchanges or other qualified entities could compile and file disclosures on behalf of projects that lack an internal filing capability.
• Post‑mortem record keeping – a designated agent would maintain a labeled archive of a project’s disclosures after it shuts down or exits mandatory reporting, ensuring historical transparency.

These ideas aim to close gaps where the SEC’s draft places the entire disclosure duty on the issuer, potentially leaving some market participants unaccounted for.

Context and next steps

The SEC’s Regulation Crypto Assets, released in August 2026, would allow token startups to raise up to $5 million over four years or up to $75 million in a 12‑month window. The agency is still reviewing public comments before finalizing the rule. Blockworks’ suggestions, backed by its Transparency Alliance—whose members include major exchanges and institutional investors—add a concrete, industry‑driven perspective to the ongoing debate.

Stakeholders will watch how the SEC responds to these proposals, especially the introduction of a qualified disclosure agent and the push for more prescriptive line items. If adopted, the changes could raise the bar for transparency in the crypto fundraising space and provide investors with richer, more reliable information.

--- This article was prepared with AI assistance and reviewed by editorial staff for accuracy.