Discoverability & the Solicitation Rules
When you tokenize an offering on ioniqx, the token's classification is visible on-chain to anyone who looks. This page explains why that visibility is not, by itself, "advertising" your deal — and what stays your responsibility so it doesn't become that.
The short version
A token existing and being discoverable on a public blockchain is not a general solicitation. The rules that restrict how private offerings can be marketed — under Regulation D, Rule 502(c) — target the offer itself: the pitch, the terms, the numbers, anything that invites the public to invest. They do not target the plain fact that a security exists and can be identified.
ioniqx is built around that distinction. The information we put on-chain describes what the asset is. The information that could count as an offer — price, minimums, projected returns, the offering memorandum — stays behind access controls that you decide, keyed to the exemption you're relying on.
What's on-chain, and why it's safe
The on-chain classification for your token carries a deliberately narrow set of facts: what class of real-world asset it represents, what kind of claim the holder has, the jurisdiction, and a pointer to where extended data lives. It carries an attestation binding those facts to an accountable party so they can't be spoofed.
What it never carries: price, availability, minimum investment, projected or past returns, valuation, or any term of your offering. Those fields don't exist in the classification. That absence is the point — it's what keeps the public, discoverable layer descriptive rather than promotional.
What stays your responsibility
ioniqx provides the infrastructure; the offering is yours, and so is the exemption analysis. The platform can enforce access gating, but it can't decide for you which exemption you're using or who is allowed to see your offering materials. Concretely:
- Keep offering terms out of public fields. Anything a stranger could fetch — the on-chain classification, the public discovery document, endpoint names — must stay free of price, terms, and projections.
- Gate the offering materials to match your exemption. The memorandum, subscription docs, and anything that markets the deal sit behind access control appropriate to how you're raising.
- Get your own counsel's sign-off. Nothing on this page or in the platform substitutes for your lawyer's review of your specific structure.
It depends on which exemption you're using
The discoverability question sharpens or disappears depending on how you're raising. The two most common paths on ioniqx:
| Path | Can you market publicly? | What discoverability means for you |
|---|---|---|
| 506(b) | No general solicitation. You may only offer to investors you have a pre-existing, substantive relationship with. | This is where the line is sharpest. The on-chain layer and any public discovery document must stay purely descriptive. Offering materials go behind a relationship gate. |
| 506(c) | General solicitation is permitted — to verified accredited investors. | The solicitation question largely falls away. Your obligation shifts to taking reasonable steps to verify accredited status before a sale. |
Under 506(c), the same kind of on-chain attestation ioniqx uses for classification can also help you collect and evidence the investor representations that support streamlined accredited-investor verification — handled through the platform's eligibility flow, which is separate from the asset classification described above. Classification describes the asset; eligibility gates the investor. We keep those two things distinct.
This isn't legal advice
Last reviewed August 2026 · Questions about how the platform enforces access gating? Contact support.