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Regulatory uncertainty clouds layer-2 sequencers as industry and SEC differ

September 22, 2025Updated:September 23, 2025No Comments2 Mins Read
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Regulatory uncertainty clouds layer-2 sequencers as industry and SEC differ
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Regulatory uncertainty clouds layer-2 sequencers as industry and SEC differ

Coinbase chief authorized officer Paul Grewal and Base founder Jesse Pollak argued that Layer-2 (L2) sequencers represent infrastructure somewhat than exchanges.

Their statements contradict the present regulatory stance, contemplating SEC Commissioner Hester Peirce has beforehand warned that centralized matching engines could face trade registration necessities.

Grewal in contrast Base’s sequencer to Amazon Internet Companies in a Sept. 22 submit, stating that layer-2 blockchains function as general-purpose infrastructure processing code deterministically.

He argued that L2s “batch all transactions whereas deferring any formal order interplay/matching guidelines to an app’s sensible contracts and frontend.”

Pollak offered technical particulars supporting the infrastructure argument, explaining that Base’s sequencer collects person transactions, orders them first-in/first-out, and batches them to Ethereum for settlement.

He emphasised that sequencers decide transaction processing order however don’t act as matching engines that pair purchase and promote orders.

In line with Pollak:

“Transaction matching or execution occurs on the software degree, inside sensible contracts. The sequencer ensures these transactions are executed in a constant, ordered method, nevertheless it doesn’t determine matches or management commerce logic.”

He additionally famous that customers can bypass the sequencer by transacting on Base immediately via Ethereum, preserving decentralization and censorship resistance from Ethereum’s validator set.

SEC regulatory perspective

Peirce outlined completely different regulatory issues throughout a Sept. 8 interview on The Gwart Present, distinguishing between really decentralized protocols and centralized entities utilizing blockchain know-how.

She famous that layer-2 options with centralized transaction ordering could face regulatory scrutiny:

“You probably have an identical engine that’s managed by one entity that controls all of the items of that, then that appears much more like an trade.”

Peirce added that operators should take into account trade registration in the event that they facilitate securities transactions via centralized methods.

Moreover, she emphasised the necessity to shield really decentralized protocols, describing them as code that “no person owns” and can’t register with regulators.

Pollak acknowledged Base’s present centralization, stating the platform has reached “stage 1 decentralization” and enabled permissionless block proposals. The workforce continues working towards “stage 2” decentralization and additional decentralizing block constructing.

The disconnect highlighted the necessity for a crypto regulatory framework to resolve points such because the state of Base.

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Bitcoin price stalls at $65K as holder selling risk rises
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