According to the policy statement on PoS (Proof of Stake) network staking activities issued by the U.S. Securities and Exchange Commission (SEC) on May 30, 2025, the following three types of staking activities are explicitly not considered securities issuance:

Self-staking: Node operators use their own crypto assets to participate in network validation.

Third-party non-custodial staking: Asset owners retain control over their assets and only delegate the rights to validate to a third party.

Compliant custodial staking: Custodians strictly isolate client assets and do not use client assets for operational activities or re-staking.

Regarding the staking activities of SSV.Network (ssv.network), based on current information, SSV.Network is a non-custodial staking protocol based on Distributed Validator Technology (DVT), designed to enhance the decentralization and security of Ethereum staking by splitting validator keys into multiple KeyShares and distributing them to different non-trust nodes. Its core feature is non-custodial, meaning users always retain complete control over their staked assets (ETH) and rewards while participating in staking by delegating validation rights to operators in the network.

Legality analysis of SSV.Network staking

Combining the SEC's policy statement, SSV.Network's staking model meets the definition of third-party non-custodial staking:

Asset control: Users of SSV.Network retain full control of their validator keys and withdrawal addresses during the staking process, with operators only responsible for validation operations and not holding user assets.

Delegated validation: Users delegate validation rights to SSV.Network's operators without transferring actual ownership or custody of the assets, which aligns with the SEC statement's description of "only delegating validation rights."

Decentralization and security: SSV.Network utilizes BLS signatures and distributed validator technology to ensure the security of user assets, and does not rely on the operation of a single node, thereby reducing custodial risk.

Additionally, SSV.Network's operational mechanism does not involve re-staking assets or using them for other operational activities, complying with the SEC statement on the regulatory requirements for non-custodial staking.