TL;DR
Dinari is the only issuer already operating on the onshore-licensed route. US jurisdiction, underlying held with a qualified custodian, a direct-security structure, 724 instruments covering the entire S&P 500 (the widest in the category), and the only issuer in this series open to US persons — accredited investors only.
It is also small enough to appear on no size table. The top five are Ondo, bStocks, xStocks, Robinhood and Remora. Dinari is not among them.
My read: before the SEC Innovation Exemption of 2026-09-17, regulation was the ceiling on this route. After it, the binding constraint becomes distribution. Dinari has the structure, the coverage and the US channel; what it lacks is a way to turn those into scale.
One thing up front: this is a structural piece, not a market-data one. Neither research source gives Dinari's on-chain value, token-level volume or book depth — those cells are empty. I mark every gap explicitly rather than filling it with inference.
The structure: unlike everyone else
Put the first three issuers in this series beside it and the difference is immediate:
| Issuer | Jurisdiction | Wrapper | US persons | Instruments |
|---|---|---|---|---|
| Ondo Stocks | British Virgin Islands | Issuer claim | Blocked | 100+ |
| bStocks | ADGM | Tracker certificate | Blocked | ~80 |
| xStocks | Jersey | Tracker certificate | Blocked | 100+ |
| Dinari dShares | United States | Direct security | Accredited | 724 |
Three dimensions inverted at once: onshore jurisdiction, a direct security rather than a debt certificate, and US access.
That "direct security" classification matters. The SEC's Statement on Tokenized Securities (2026-01-30) splits the market into four structures, from "tokenized by the issuer or its agent" down to "the token provides price exposure only". xStocks and Ondo sit toward the back half — an SPV or issuer credit stands between the token and the security. Dinari's underlying is held by a qualified custodian, which places it further forward.
"Qualified custodian" is not marketing language. It is a defined concept under US securities law, carrying specific eligibility requirements and client-asset segregation duties. That is considerably more concrete than a generic "regulated custodian".
What 724 instruments means
Coverage across the field: Dinari 724, Robinhood 190+, Ondo 100+, xStocks 100+ (the September source reported 714 including ETFs), bStocks ~80, Coinbase 10.
724 covering the full S&P 500 means this is not a selection of popular names — it is a complete index.
But coverage is an easy metric to abuse. The same problem has appeared in both previous pieces: "contracts deployed" and "instruments with live supply" are different numbers. Coinbase deployed thirteen contracts with supply in four; xStocks shows 714 and 100+ side by side.
For Dinari's 724 I cannot separate the two — that is the first data gap. Until I have a count of instruments with non-zero supply, 724 is a ceiling rather than actual coverage.
The only US channel, and what it costs
Accredited-investor access is Dinari's most distinctive property on this table. Every other issuer blocks US persons outright.
But the accredited threshold in the US is a real barrier: $200,000 of individual income ($300,000 jointly) for two consecutive years, or $1,000,000 in net worth excluding the primary residence.
That threshold explains the size question. A product open only to accredited investors has given up the retail market by construction — while bStocks, with a $5 minimum and the Binance funnel, reached $914M in four months. They are not competing for the same users.
So it is wrong to say Dinari "lost" to bStocks. They answer different questions: bStocks asks how to let the most people buy it; Dinari asks how to let the people who buy it actually own it.
The regulatory turn: the binding constraint is moving
Two things in 2026 changed this route's outlook.
SEC Innovation Exemption (2026-09-17): qualifying tokenized securities venues may trade tokenized NMS stock through permissioned AMM pools without registering as an exchange or ATS, subject to caps on instruments and volume; market makers are separately relieved of broker registration. It covers both issuer-direct and unaffiliated third-party tokens.
Nasdaq's same-order-book rule approved: qualifying tokenized stocks and ETFs may trade in the same order book, at the same execution priority, as the traditional share — provided the two are fungible and carry identical rights. DTCC reports 50+ institutions in its tokenization service, and the DTC received SEC no-action relief in December 2025 for a three-year pilot.
Read together: "identical rights and fungible" is becoming the entry ticket to US liquidity. And that is precisely what the offshore route cannot structurally obtain — a tracker certificate or an issuer claim does not, by definition, carry the same rights as the share.
Dinari's structure sits natively closer to that threshold. It is its largest source of option value, and the only reason I keep tracking it.
Worth flagging: the reported five-year term and equal-rights conditions attached to the Innovation Exemption are secondary readings and should be checked against the SEC order itself. Details at that level decide who gets through the door; they are not something to take second-hand.
The data I do not have
Stated plainly, these are the questions I cannot answer today:
- On-chain value — empty in both sources' issuer tables, so no comparison against $914M / $847M is possible
- Token-level liquidity — no dShares token appears on any market-cap or volume leaderboard; spread, depth and turnover are all unknown
- How many of the 724 carry live supply — the real denominator of that coverage figure
- Redemption terms — cash or in-kind, minimum ticket, settlement time, fees
- Proof of reserve — whether a public PoR exists, at what cadence, and whether it reconciles against on-chain supply
- Voting and dividend handling — a direct-security structure should preserve both, but I found no explicit statement
Items 4, 5 and 6 are core grading inputs. Until they are filled in, Dinari stays at B — not because the structure is weak, but because the verifiable information is insufficient. That is the same reason bStocks stays at B.
Risks
| Risk | Severity | Detail |
|---|---|---|
| Insufficient verifiable information | High | Redemption, PoR and rights handling not publicly stated |
| Accredited-only threshold | High | Retail is given up by construction; the size ceiling follows |
| Unknown liquidity | High | Absent from every volume table; exit capacity cannot be assessed |
| Coverage methodology | Medium | 724 may be deployments rather than live instruments |
| Regulatory dependence | Medium | The route's value hinges on how TSV and Nasdaq rules land in detail |
What I will watch
- Whether it appears on rwa.xyz or CoinGecko issuer tables — becoming measurable is itself a signal
- How many of the 724 have live supply — turning coverage from a marketing number into a usable one
- Formal disclosure of redemption and proof of reserve — the only path from B to A
- Whether it is on the first TSV approval list — the dividing line between a structural advantage and an actual channel
- Any loosening of the accredited threshold — any move toward retail resets the size expectation entirely
Bottom line. Dinari is structurally the most correct issuer in the category: onshore jurisdiction, qualified custody, direct securities, the widest coverage, the only US channel. But a correct structure is not a working product — it is small enough to appear on no size table, and I cannot even obtain its on-chain value.
The regulatory environment is moving in its favour. Until the first TSV approvals are published and its redemption and reserve mechanisms are publicly verifiable, I treat it as a structural option rather than a tool anyone can use today.
Based on the structural descriptions in two research sources dated 2026-09-04 and 2026-10-15/16, plus public SEC and DTCC records. Data gaps are marked explicitly; no size or liquidity figure is inferred where a source does not provide one. Research, not investment advice.