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Is BlackRock USD Institutional Digital Liquidity Fund (BUIDL) a security?

#47 by market cap · Last updated Oct 19, 2026 (evidence re-checked)
$1.00 ▲ 0.00%Mkt cap $2.2B

At a glance

Likely security-type risk
  • Confidence
  • US exchange accessCoinbase custody only
  • Regulator (if enacted)SEC
  • Evidence4 sources · 1 official

Is BlackRock USD Institutional Digital Liquidity Fund (BUIDL) a security?

Unclear. The issuer's own documents describe the token as a share or note in an investment fund or product offered under securities laws (or securities-law exemptions). The SEC states that 'a security is a security regardless of whether it is issued... onchain.'

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What this means for you

This token is treated as a security, so US securities laws already apply to it. Whether you can buy or hold it depends on the issuer's own eligibility rules, so check the issuer's official documents before acting.

What should I do if my token is "security risk"? →

Background 2Exchange listing 1Regulator 11 official3 third-party

Why this status

  • R4: the issuer's own documents describe the token as a share or note in an investment fund or product offered under securities laws (or securities-law exemptions). The SEC states that 'a security is a security regardless of whether it is issued... onchain.'
  • This is a security by design, not a finding of wrongdoing. These products are usually only for eligible (often non-US or accredited) investors.

Decentralisation ("mature blockchain" test): Issuer-controlled fund share (centralized by design).

Evidence (4 sources)

1 official
  1. BackgroundThird-partyOct 19, 2026 · CoinGecko

    No project description found on CoinGecko.

    CoinGecko: BlackRock USD Institutional Digital Liquidity Fund ↗
  2. Exchange listingThird-partyAbsent / not foundOct 19, 2026 · Coinbase

    BUIDL does not appear on Coinbase's 'US (incl. NY) Trading Assets' list (it is on Coinbase's custody list).

    Coinbase Digital Asset Disclosures: 'US (incl. NY) Trading Assets' list ↗
  3. RegulatorOfficial sourceMar 23, 2026 · Federal Register (SEC & CFTC)

    SEC interpretation: 'A security is a security regardless of whether it is issued, or otherwise represented, offchain or onchain.' Tokenized securities remain securities.

    SEC interpretation (with CFTC guidance): Application of the Federal Securities Laws to Certain Types of Crypto Assets, Release 33-11412 ↗
  4. BackgroundThird-partyMar 20, 2024 · Securitize / BlackRock

    BlackRock's tokenized fund. Shares are issued under Rule 506(c) of the Securities Act and Section 3(c)(7) of the Investment Company Act, for qualified investors only ($5M minimum).

    Securitize: BlackRock launches its first tokenized fund, BUIDL ↗

Rules by country

🇺🇸United States
Security risk

Likely security-type risk (ClarityCheck estimate, medium-high confidence). The CLARITY Act is not law, so today the SEC's and CFTC's existing frameworks apply.

🇪🇺European Union (MiCA)
Token filing not checked

Under MiCA, trading in the EU runs through authorised crypto-asset service providers (CASPs). We haven't yet checked token-specific MiCA white paper filings for BUIDL. ESMA register ↗

🇬🇧United Kingdom (FCA)
Firm rules from Oct 25, 2027

The UK's new FCA cryptoasset regime starts on Oct 25, 2027. Firms can apply from Sept 30, 2026 until Feb 28, 2027. There's no token-by-token classification list; the rules apply to the firms that offer the token. FCA ↗

BUIDL questions

Is BlackRock USD Institutional Digital Liquidity Fund (BUIDL) a security?

There's a strong basis for treating it as a security: The issuer's own documents describe the token as a share or note in an investment fund or product offered under securities laws (or securities-law exemptions). The SEC states that 'a security is a security regardless of whether it is issued... onchain.' Not legal advice.

Can I buy BUIDL on US exchanges?

US access: Coinbase custody only. Availability can differ by state and by exchange. See our exchange safety checker.

What would the CLARITY Act change for BUIDL?

This token is treated as a security, so US securities laws already apply to it. Whether you can buy or hold it depends on the issuer's own eligibility rules, so check the issuer's official documents before acting.

How reliable is this BUIDL status?

Confidence is Medium-High. It comes from fixed rules applied to 4 cited sources (checked Oct 19, 2026), not from opinion. Statuses can change as courts, regulators and Congress act.

Change log

3 entries
  1. Status review
    Evidence-based review: status set to 'Likely security-type risk' (Medium-High confidence) using ClarityCheck rules. Replaces earlier illustrative demo data.
  2. SEC interpretation: 'A security is a security regardless of whether it is issued, or otherwise represented, offchain or onchain.' Tokenized securities remain securities. Source ↗
  3. BlackRock's tokenized fund. Shares are issued under Rule 506(c) of the Securities Act and Section 3(c)(7) of the Investment Company Act, for qualified investors only ($5M minimum). Source ↗

Snapshot Oct 19, 2026 · Prices by CoinGecko