A local electrode atom probe has been used to analyze the solute partitioning during bainite transformation in a novel, nanocrystalline bainitic steel. Atom probe results show the absence of any partitioning of substitutional elements between the phases involved. The results are fully consistent with the diffusionless transformation of austenite to bainite. However, substitutional elements are expected to redistribute approaching an equilibrium phase boundary as the mixture of bainitic ferrite and retained austenite is tempered. The compositional analysis of the austenite/ferrite interface by atom probe tomography indicates that retained austenite decomposes during tempering before equilibrium is reached at the interface.