ECB Study: One-Third of Major DAO Voters Untraceable
An ECB study analyzing governance across Aave, Uniswap, MakerDAO, and Ampleforth from November 2022 to May 2023 found centralised exchanges hold between 3% and 22% of governance tokens, with about 50% of voting power tied to the protocols themselves.
Key Takeaway
Most DAO voting power sits with insiders and exchanges — not the retail token holders who believe they govern these protocols.
European Central Bank researchers could not identify around one-third of the top voters across four major DAOs in a study challenging claims that decentralised autonomous organisations actually distribute power.
The ECB paper titled "Who to regulate? Identifying actors within DeFi's governance" analyzed Aave, Uniswap, MakerDAO, and Ampleforth from November 2022 to May 2023. Centralised exchanges held between 3% and 22% of governance tokens across the four protocols. About 50% of voting power traced back to the protocols themselves — founders, developers, and DAO treasuries.
The lack of transparency complicates efforts to assess accountability and reinforces concerns about the concentration of power, ECB researchers wrote. The findings challenge the perception that DAOs are inherently decentralised. While these tokens are technically distributed across a large number of unique blockchain addresses, a small number of entities holds a majority of the supply.
Representative Sean Casten, Democrat from Illinois, raised the issue in a congressional hearing about Uniswap DAO. He pressed Uniswap Labs Chief Legal Officer Katharine Minarik on whether the Uniswap Foundation's unilateral decision-making power weakens any claim of decentralisation. Minarik responded that her employer is a distinct legal entity from the Uniswap Foundation and that the Foundation cannot make unilateral decisions.
The tension between decentralisation claims and regulatory reality matters because the EU Markets in Crypto-Assets Regulation explicitly excluded crypto services "provided in a fully decentralised manner." ECB researchers suggested creating tailored legal structures specifically for DAOs, clarifying responsibilities, liabilities, and governance obligations explicitly. Wyoming lawmakers passed the DUNA Act in March 2024, allowing DAOs to create legally-recognised entities in the state, with Uniswap DAO becoming one of the first to take advantage of the legal structure in 2025.
This article was written based on reporting from Dlnews.
