Tokenized Real Estate and the SEC: 44 EDGAR Filers (2026)

Which door the token came through

A token does not choose its own legal regime. The issuer files under one of a few exemptions or registers, and each one fixes who may buy, how much, and what the issuer must publish afterwards. The text below is from the Code of Federal Regulations as of October 1, 2026; the last column is what we found on EDGAR.

Two details matter for a small buyer. First, Rule 506(c) is the door for a $50 token only if the buyer is accredited: the rule says all purchasers must be. Sixteen RealToken Form D filings claim it while stating minimums of $47 to $52, so (our reading) a US buyer of those tokens had to be accredited, and the Form D says nothing about non-US buyers. Second, the retail doors have a ceiling on you, not just on the issuer. In a Regulation A Tier 2 offering a buyer who is not accredited may spend no more than 10% of the greater of annual income or net worth, which means a $5,000 purchase needs at least $50,000 of income or net worth (our arithmetic). In Regulation Crowdfunding the cap is the greater of $2,500 or 5% of the greater of income or net worth when either is under $124,000.

The census: 44 filers, 5 active in 2026

We built the list from EDGAR full-text search for the phrases “tokenized real estate”, “real estate tokens” and “property tokens”, from company-name lookups, and from the SEC’s own comment letters. We then pulled each filer’s complete filing list on October 10, 2026. The list is not exhaustive: it is every EDGAR filer we could tie to tokenized real estate by its own filings. The 17 RealToken companies and 8 HoneyBricks LLCs are counted as separate filers because each is a separate legal entity with its own CIK.

For scale: the SEC’s quarterly index shows 598 new Regulation Crowdfunding Form C filings and 125 new Regulation A Form 1-A statements from January through September 2026 (our sums of three quarters). Tokenized real estate is a small corner of both.

RealToken: 17 property companies, one Form D each

Each “RealToken” company is a Delaware corporation at 980 N Federal Hwy, Boca Raton, Florida. RealT’s own website footer, read October 10, 2026, gives the same address and says the site is operated by RealToken Inc., which “is not a registered broker-dealer or investment advisor.” The Form D filings do not mention RealT, so linking them to RealT rests on the shared name and address (our inference). No filing has been made by any of the 17 since the dates below, and none has filed an amendment.

The amounts are as of each filing date. Offerings that stayed open after filing are not updated, because no amendment exists. The 11117 Worden St. filing states “02305” in the sold field, which we read as $2,305. Press reports in July 2026, cited in our Lofty review, say RealT announced a liquidation; nothing on EDGAR confirms or describes it, and we do not use any press figure here.

HoneyBricks: 8 LLCs, accredited investors only

HoneyBricks filed Form D notices for eight LLCs between August 19, 2022 and August 25, 2023, with a stated minimum of $1,000 each; LLC 002 also filed one amendment. The eight total offerings add to $3,070,000 (our sum). Investor counts at filing were 30, 0, 0, 0, 39, 20, 20 and 20 for LLCs 001 to 008. Seven of the eight report $0 sold, including four that list between 20 and 39 investors; LLC 007 reports $500,000 sold. The last filing for each LLC is dated between August 19, 2022 and August 25, 2023. Our HoneyBricks review covers the business; the filings confirm it used Regulation D, not a retail exemption.

The other 19: Regulation Crowdfunding, Regulation A and registration

Three SEC-reporting companies mention tokenized real estate and do not belong in the census. Stewards, Inc. (SWRD) writes in its July 16, 2026 prospectus that it “does not currently offer tokenized real estate interests.” TAP Real Estate Technologies, Inc. (RWAX) says in its 10-K of March 31, 2026 that tokenization “has not yet been widely adopted in the commercial real estate market” and has not yet begun generating revenue from planned principal operations. RedSwan Markets, LLC files Form X-17A-5 broker-dealer reports (latest March 31, 2026), not offering documents.

What a token holder legally owns

The SEC staff’s own taxonomy is the cleanest way to read the filings. Its January 28, 2026 statement describes an issuer-sponsored token as one where the issuer keeps its “master securityholder file” on a blockchain, so that “a transfer of the crypto asset on the crypto network results in a transfer of the security.” It also describes an issuer that keeps the file off-chain and issues a crypto asset that “does not convey any rights, obligations, or benefits of the security.” Real estate issuers in EDGAR use both models, and the wording decides what you hold.

Tirios is the clearest case, and it is also the best-documented because it went through SEC review. Its circular says the Manager “can freeze the tokens or block any transactions on blockchain,” that the tokens live on a permissioned Hyperledger Fabric network the Manager runs, and that the Company’s position is that tokens are not securities “because there is no expectation of profit from the Tokens alone.” That is the company’s position, not an SEC finding: the Series Interest is the security.

The practical point for a buyer: owning a token in a wallet does not by itself make you the owner of record. In Tirios’s structure, GroEstate’s structure and Deedflow’s structure the off-chain register controls. (Our reading of the wording; an attorney can tell you what it means for your facts.)

What the SEC said in 2025 and 2026, and what it left alone

Read together, the 2025-26 actions confirm what the filings already show: a real estate token is a security wrapped in a record format, and it is offered through Regulation D, Regulation Crowdfunding, Regulation A or registration. The proposed Regulation Crypto Assets says its exemptions cover investment contracts that involve a crypto asset and no other asset, so a token that represents a house falls outside it (our reading of the definition of “covered investment contract”).

How the SEC staff read Tirios’s marketing

The best public evidence of how the staff treats “tokenized real estate” is its comment letters to Tirios. Tirios filed its first Form 1-A on June 12, 2023 and was first qualified on September 27, 2024, about 15 months later (our arithmetic). Along the way the staff wrote on July 11, 2024 that it was “unclear why certain statements on your website … appear inconsistent with your offering statement disclosure.” Its example was a video saying the Tirios blockchain “allows investors to buy digital shares [emphasis added] called Tokens,” while the circular says a Token is a digital courtesy copy. On August 7, 2024 the staff asked Tirios to revise a risk-factor heading to say that “investors may erroneously associate your business model with using blockchain to offer and maintain fractional shares.”

For a buyer, that is the most useful sentence in this article. If an app, a video or a blog post describes your token as shares, check whether the filed document says the same.

Names that send people to the wrong filing

• Lofty AI. The EDGAR company lookup for “lofty ai” returns 0 entities. The names that do appear (Lofty Ventures Syndicate, LP series and LoftyInc funds) are not Lofty AI, as our Lofty review explains. Lofty’s tokens are therefore not something you can check in an offering circular on EDGAR.
• RealT. No EDGAR entity is named RealT. The only filings are the 17 RealToken Form D notices above, all from 2022.
• Roofstock onChain. No EDGAR entity carries that name. Roofstock One, Inc. filed a Form D/A on October 20, 2022 claiming Rule 506(c): $2,058,182 sold to 179 investors with a $5,000 minimum. EDGAR full-text search finds 0 filings with the word “token” for that company, so the filings do not show that this raise was a token offering.
• Propy. Propy, Inc. filed a Form D on August 5, 2026 for a $10,000,000 offering ($2,065,290 sold to 8 investors, Rule 506(b)) listing equity, options and a “Token Warrant.” That is a company equity raise, not an offering of property tokens.
• Landa. Landa’s shares are LLC membership interests in a series, sold through an app. Its filings do not use the word “token” or “blockchain” (0 filings across Landa App LLC, Landa App 2 LLC and Landa App 3 LLC). It is a Regulation A Tier 2 issuer, and our Landa review and investor outcomes page cover its record. One filing-based point is new here: Landa App LLC’s latest annual report on Form 1-K was filed May 10, 2023, and Landa App 3 LLC’s on June 3, 2024, while both still file Form 1-U current reports (latest July 23 and September 16, 2026). Rule 257(b)(1) requires a Form 1-K for each fiscal year after qualification unless the duty is suspended; we found no later 1-K and no Form 1-Z (our reading).

What a holder can do with this

• Find the issuer by its exact legal name in EDGAR. The form type tells you the door: Form D (private; if it says 506(c), buyers were meant to be accredited), Form C (crowdfunding), Form 1-A and 1-K (Regulation A), or 10-K and 10-Q (registered). If you cannot find the entity, you cannot check the offering document.
• Read the paragraph that defines the token. Search the circular for “Token” and read what it says you own and which record controls. Compare it with the marketing.
• Check the date of the last report. A Regulation A Tier 2 issuer owes a Form 1-K and a Form 1-SA each year; a crowdfunding issuer files a Form C-AR. A long gap is a fact to weigh before you add money or expect an exit.
• Check your own cap before you buy. A $5,000 position in a Regulation A Tier 2 offering needs $50,000 of income or net worth if you are not accredited (our arithmetic). In crowdfunding the floor is $2,500.
• Assume no liquid exit. Tirios’s circular says its securities “will not be listed or quoted on any securities exchange” and expects trading through its own secondary platform.
• Compare with the plain versions. Our guides to fractional real estate platforms and what they file and to every real estate Regulation A offering of 2025-26 show the same doors without the token layer. The red flags page lists what to look for in any of these filings.

FAQ

This is analysis of public documents, not investment, legal or tax advice.

Sources, read and saved on October 10, 2026: SEC EDGAR filings and company filing lists for the 44 filers in the census (Form D and D/A XML, Form C, C-U and C-AR XML and exhibits, Forms 1-A, 1-K, 1-SA, 10-12G, 15-12G, 10-K and 424B3), including the Tirios Propco Series LLC Form 1-A/POS of December 3, 2025, Form 1-K of May 1, 2026 and SEC staff letters of July 11, July 19 and August 7, 2024, and SEC orders declaring the MartelInvest 1 LLC and Realm Metaverse Real Estate Inc. offering statements abandoned; EDGAR full-text search and company lookups run October 10, 2026; EDGAR quarterly form indexes for 2025 to the third quarter of 2026 with our counting script; 17 CFR 230.251, 230.257, 230.506, 227.100, 240.12g-1 and 240.12g5-1 from the eCFR (current to October 1, 2026); Statement of Commissioner Hester M. Peirce (July 9, 2025); Division of Trading and Markets no-action letter to The Depository Trust Company (December 11, 2025); Statement on Tokenized Securities by the Divisions of Corporation Finance, Investment Management and Trading and Markets (January 28, 2026); Release Nos. 33-11434 and 34-106402; and RealT’s own website footer. Press reports about RealT’s July 2026 liquidation are cited as reported and not relied on for any figure.