| [Table 2] Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens | |||||
| Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens [abstract] | |||||
| General information | |||||
| 00 Table of content | boolean true | ||||
| 01 Date of notification | date | ||||
| 02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114 | boolean true | ||||
| 03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114 | boolean true | ||||
| 04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114 | boolean true | ||||
| 05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114 | boolean true | ||||
| 06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114 | boolean true | ||||
| SUMMARY | |||||
| 07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114 | boolean true | This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto –asset on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law. |
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| 08 Characteristics of the crypto-asset | textBlock | The Token does not represent nor confer any ownership, equity interest, participation, corporate governance rights, or any rights beyond the programmatic functionalities expressly described herein, nor any entitlement to business revenues, profit sharing, or other similar economic benefits in relation to the Network, the Association or any other entity or individual. |
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| 09 Further information about utility tokens | textBlock | ▪ Access the Network: The Token is required to access the decentralized storage of the Network. ▪ Interact with the Network: The Token is necessary to become a Validator or Delegator (as defined in D.04) of the Protocol. ▪ Interact with the Network Governance Mechanism The purpose of the Token governance is to create a stable and trustworthy ecosystem by allowing users who stake their Tokens to access and participate in Blacklight Staking Mechanism as detailed below in D.04 . Token holders only participate in technical and/or operational decision-making. They have no influence over the corporate governance/policy of the Association or any other party of the Nillion ecosystem. The Token to be admitted to trading (see E.12) are freely transferable. |
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| 10 Key information about the offer to the public or admission to trading | textBlock | ||||
| Part A - Information about offeror or person seeking admission to trading | |||||
| A.1 Name | text | ||||
| A.2 Legal form | text | ||||
| A.3 Registered address | |||||
| Registered addess | text | ||||
| Country | enumeration | ||||
| Sub-division | text | ||||
| A.4 Head office | |||||
| Head office | text | ||||
| Country | enumeration | ||||
| Sub-division | text | ||||
| A.5 Registration date | date | ||||
| A.6 Legal entity identifier | LEI | ||||
| A.7 Another identifier required pursuant to applicable national law | text | ||||
| A.8 Contact telephone number | text | ||||
| A.9 E-mail address | text | ||||
| A.10 Response time (days) | integer | ||||
| A.11 Parent company | text | ||||
| A.12 Members of the management body | |||||
| Member #1 | id | 1 | |||
| Identity | text | ||||
| Business address | text | ||||
| Function | text | ||||
| Member #2 | id | 2 | |||
| Identity | text | ||||
| Business address | text | ||||
| Function | text | ||||
| Member #3 | id | 3 | |||
| Identity | text | ||||
| Business address | text | ||||
| Function | text | ||||
| A.13 Business activity | textBlock | For the business activity as entered into the commercial register: see https://zg.chregister.ch/cr-portal/auszug/auszug.xhtml?uid=CHE-412.979.799 |
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| A.14 Parent company business activity | textBlock | ||||
| A.15 Newly established | boolean | ||||
| A.16 Financial condition for the past three years | textBlock | ||||
| A.17 Financial condition since registration | textBlock | The Association has received significant funding through fundraising activities, the funds currently available are sufficient, based on the Association's current business plan, to finance its activities over the next 2 to 3 years. Financial resources remain adequate to support both current operations and planned development activity following the successful launch of the mainnet. |
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| Part B - Information about issuer, if different from offeror or person seeking admission to trading | |||||
| B.1 Issuer different from offerror or person seeking admission to trading | boolean | ||||
| B.2 Name | N/A | . | |||
| B.3 Legal form | N/A | . | |||
| B.4 Registered address | |||||
| Registered addess | N/A | . | |||
| Country | N/A | . | |||
| Sub-division | N/A | . | |||
| B.5 Head office | |||||
| Head office | N/A | . | |||
| Country | N/A | . | |||
| Sub-division | N/A | . | |||
| B.6 Registration date | N/A | . | |||
| B.7 Legal entity identifier | N/A | . | |||
| B.8 Another identifier required pursuant to applicable national law | N/A | . | |||
| B.9 Parent company | N/A | . | |||
| B.10 Members of the management body | |||||
| Member #1 | N/A | . | |||
| Identity | N/A | . | |||
| Business address | N/A | . | |||
| Function | N/A | . | |||
| B.11 Business activity | N/A | . | |||
| B.12 Parent company business activity | N/A | . | |||
| Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114 | |||||
| C.1 Name | N/A | . | |||
| C.2 Legal form | N/A | . | |||
| C.3 Registered address | |||||
| Registered address | N/A | . | |||
| Country | N/A | . | |||
| Sub-division | N/A | . | |||
| C.4 Head office | |||||
| Head office | N/A | . | |||
| Country | N/A | . | |||
| Sub-division | N/A | . | |||
| C.5 Registration date | N/A | . | |||
| C.6 Legal entity identifier | N/A | . | |||
| C.7 Another identifier required pursuant to applicable national law | N/A | . | |||
| C.8 Parent company | N/A | . | |||
| C.9 Reason for crypto-asset white paper preparation | N/A | . | |||
| C.10 Members of the management body | |||||
| Member #1 | N/A | . | |||
| Identity | N/A | . | |||
| Business address | N/A | . | |||
| Function | N/A | . | |||
| C.11 Operator business activity | N/A | . | |||
| C.12 Parent company business activity | N/A | . | |||
| C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114 | N/A | . | |||
| C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114 | N/A | . | |||
| Part D - Information about other token project | |||||
| D.1 Crypto-asset project name | text | ||||
| D.2 Crypto-asset name | text | ||||
| D.3 Abbreviation | text | ||||
| D.4 Crypto-asset project description | textBlock | Petnet: The Petnet is Nillion's privacy-enhancing technology network and facilitates secure computation and secure storage of data. Data may be stored across multiple decentralized storage nodes ("nilDB nodes") using Multi-Party Computation ("MPC"), and computed on within compute nodes ("nilCC nodes") operating inside Trusted Execution Environments ("TEEs"). The Petnet is permissionless, meaning that, in principle, anyone may operate a compute or storage node, and users may access such services on an open basis. On-Chain Layer: The On-Chain Layer comprises the NIL token on Ethereum Layer 1 and Nillion's Layer 2 network built on top of Ethereum. . Nillion Blacklight: Nillion Blacklight is the Network's verification layer and is coordinated through the Layer 2 network. It is designed to help ensure that the Petnet operates correctly and honestly. At present, this verification functionality applies to the computation aspect of the Petnet, including verification that nilCC nodes are operating honestly and as expected. Any person may operate a Blacklight node. Once such node is configured and the minimum staking requirement is satisfied (currently 70,000 NIL), the node may receive verification tasks through a smart contract on the Layer 2 network and submit verification results back to the Layer 2 network for consensus. Blacklight nodes are rewarded for the verification work they perform. Accordingly, the Petnet provides the core technology for secure storage and computation, while the NIL token serves as the means to access Petnet services, and the Layer 2 network serves as the coordination layer for the Nillion Blacklight verification layer. The Network is operated by independent node operators ("Nodes"). Currently, anyone may operate a nilCC node, nilDB node or Blacklight node, and the setup of such nodes is permissionless. The Crypto-Asset - The NIL token is used for protocol governance and as the access mechanism for services on the Network, including secure computation and storage. |
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| D.5 Details of all natural or legal persons involved in implementation of crypto-asset project | |||||
| Person #1 | id | 1 | |||
| Type of person | enumeration | ||||
| Name of person | text | ||||
| Business address of person | text | ||||
| Domicile of company | enumeration | ||||
| Person #2 | id | 2 | |||
| Type of person | enumeration | ||||
| Name of person | text | ||||
| Business address of person | text | ||||
| Domicile of company | enumeration | ||||
| D.6 Utility token classification | boolean | ||||
| D.7 Key features of goods or services for utility token projects | text | ▪ Access the Network: The Token is required to access the decentralized compute and storage of the Network. ▪ Interact with the Network: The Token is necessary to operate a Network node and participate in the security of the Network . ▪ Interact with the Network Governance Mechanism The purpose of the Token governance is to create a stable and trustworthy ecosystem by allowing users who stake their Tokens to access and participate in the decentralized, balanced ecosystem consensus mechanism. Token holders only participate in technical and/or operational decision-making. They have no influence over the corporate governance/policy of the Association or any other party of the Nillion ecosystem. |
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| D.8 Plans for the token | |||||
| Description of past milestones | textBlock | ▪ Public Testnet of the Network: May 17, 2024 ▪ Community Sale on Coinlist: June 19 to June 26, 2024 ▪ Token Generation Event (expected date): February 19, 2025. ▪ Public Mainnet: March 24, 2025 ▪ Admission on Trading Platforms operating within the EU / EEA: March 24, 2025 ▪ Network Launch on Ethereum L2: December 16, 2025, ▪ Cosmos Chain Discontinuation (incl. ensuing NIL Cosmos Version Discontinuation): March 23, 2026. |
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| Description of future milestones | textBlock | ||||
| D.9 Resource allocation | text | The financial resources are and will be primarily allocated to human and technical resources for the development, operation, and expansion of the Network. This includes financing core engineering, infrastructure provisioning, and ongoing security audits along with marketing services. Additional funds may be directed towards ecosystem growth initiatives, such as supporting developers and educational efforts to expand community participation. |
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| D.10 Planned use of collected funds or other tokens | text | ||||
| Part E - Information about offer to public of other tokens or their admission to trading | |||||
| E.1 Public offering or admission to trading | enumeration | ||||
| E.2 Reasons for public offer or admission to trading | textBlock | ||||
| E.3 Fundraising target | |||||
| Target expressed in currency | monetary | EUR | |||
| Target expressed in units | decimal | ||||
| Target expressed in digital token identifier | text | ||||
| E.4 Minimum subscription goals | |||||
| Goals expressed in currency | monetary | EUR | |||
| Goals expressed in units | decimal | ||||
| Goals expressed in digital token identifier | text | ||||
| E.5 Maximum subscription goals | |||||
| Goasl expressed in currency | monetary | EUR | |||
| Goals expressed in units | decimal | ||||
| Goals expressed in digital token identifier | text | ||||
| E.6 Oversubscription acceptance | boolean | ||||
| E.7 Oversubscription allocation | text | ||||
| Issue price details | |||||
| E.8 Issue price | decimal | ||||
| E.9 Official currency determining issue price | enumeration | ||||
| E.9 Any other tokens determining issue price | text | ||||
| E.10 Subscription fee | |||||
| Fee expressed in currency | monetary | EUR | |||
| Fee expressed in units | decimal | ||||
| Fee expressed in digital token identifier | text | ||||
| E.11 Offer price determination method | text | ||||
| E.12 Total number of offered or traded other tokens | integer | ||||
| E.13 Targeted holders | enumeration | ||||
| E.14 Holder restrictions | text | In addition, the Association imposes its own restrictions in agreements it enters into with Exchanges, requesting the Exchanges to exclude persons or entities located in the United States, Russia, China, or any other jurisdiction subject to comprehensive sanctions, as well as anyone listed on sanctions lists maintained by the EU, UN, UK, or US ("Prohibited Persons"). |
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| E.15 Reimbursement notice | boolean true | ||||
| E.16 Refund mechanism | textBlock | ||||
| E.17 Refund timeline | text | ||||
| E.18 Offer phases | textBlock | ||||
| E.19 Early purchase discount | textBlock | ||||
| E.20 Time-limited offer | boolean | ||||
| E.21 Subscription period beginning | date | ||||
| E.22 Subscription period end | date | ||||
| E.23 Safeguarding arrangements for offered funds or other tokens | textBlock | ||||
| E.24 Payment methods for other token purchase | textBlock | ||||
| E.25 Value transfer methods for reimbursement | textBlock | ||||
| E.26 Right of withdrawal | textBlock | ||||
| E.27 Transfer of purchased other tokens | textBlock | ||||
| E.28 Transfer time schedule | text | ||||
| E.29 Purchaser's technical requirements | textBlock | ▪ A compatible digital wallet or account on supported Trading Platforms; and ▪ Internet access; ▪ A device (computer or mobile) to manage digital wallet/private key and/or account on exchange to carry out transaction. |
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| Other token services provider characteristics | |||||
| E.30 Other token service provider (CASP) name | text | ||||
| E.31 CASP identifier | LEI | ||||
| E.32 Placement form | enumeration | ||||
| Trading platforms characteristics | |||||
| E.33 Trading platforms name | text | ||||
| E.34 Trading platforms market identifier code (MIC) | text | Bitvavo: VAVO |
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| E.35 Trading platforms access | text | ||||
| E.36 Involved costs | textBlock | ||||
| E.37 Offer expenses | textBlock | ||||
| E.38 Conflicts of interest | textBlock | ||||
| E.39 Applicable law | textBlock | Once the Tokens are trading, the legal relationship and applicable law between the Trading Platforms and their users shall be determined on the basis of the law governing the contract between them and the applicable mandatory provisions of EU law. Nothing in this whitepaper shall deprive any consumer located in the EU or EEA of the mandatory rights conferred on that consumer by the consumer-protection legislation of his or her country of habitual residence. |
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| E.40 Competent court | textBlock | Any disputes arising in connection with the seeking of admission to trading of the Token that are between the Association and the respective Trading Platform for crypto-assets shall be determined by the respective competent court depending on the contractual arrangement (if any) between the parties and the mandatory provisions of applicable law. The competent court for any disputes between Trading Platforms and their users shall be determined on the basis of the contract between them and the applicable EU law. If you are an EU or EEA consumer, you may bring any judicial proceedings before the competent court of your place of residence. |
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| Part F - Information about other tokens | |||||
| F.1 Crypto-asset type | text | ||||
| F.2 Other token functionality | textBlock | ▪ Access the Network: The Token is required to access the decentralized compute and storage of the Network. ▪ Interact with the Network: The Token is necessary to operate a Network node and participate in the security of the Network . ▪ Interact with the Network Governance Mechanism The purpose of the Token governance is to create a stable and trustworthy ecosystem by allowing users who stake their Tokens to access and participate in the decentralized, balanced ecosystem consensus mechanism). Token holders only participate in technical and/or operational decision-making. They have no influence over the corporate governance/policy of the Association or any other party of the Nillion ecosystem. |
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| F.3 Planned application of functionalities | textBlock | ||||
| A description of the characteristics of the other token, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article | |||||
| F.4 Type of crypto-asset white paper | enumeration | ||||
| F.5 Type of submission | enumeration | ||||
| F.6 Other token characteristics | textBlock | ||||
| F.7 Commercial name or trading name | text | ||||
| F.8 Website of the issuer | text | ||||
| F.9 Starting date of offer to the public or admission to trading | date | ||||
| F.10 Publication date | date | ||||
| F.11 Any other services provided by the issuer | textBlock | ||||
| F.12 Language or languages of white paper | text | ||||
| F.13 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available | text | ||||
| F.14 Functionally fungible group digital token identifier, where available | text | ||||
| F.15 Voluntary data flag | boolean | ||||
| F.16 Personal data flag | boolean | ||||
| F.17 LEI eligibility | boolean | ||||
| F.18 Home member state | enumeration | ||||
| F.19 Host member states #1 | enumerationSet | ||||
| F.19 Host member states #2 | enumerationSet | ||||
| F.19 Host member states #3 | enumerationSet | ||||
| F.19 Host member states #4 | enumerationSet | ||||
| F.19 Host member states #5 | enumerationSet | ||||
| F.19 Host member states #6 | enumerationSet | ||||
| F.19 Host member states #7 | enumerationSet | ||||
| F.19 Host member states #8 | enumerationSet | ||||
| F.19 Host member states #9 | enumerationSet | ||||
| F.19 Host member states #10 | enumerationSet | ||||
| F.19 Host member states #11 | enumerationSet | ||||
| F.19 Host member states #12 | enumerationSet | ||||
| F.19 Host member states #13 | enumerationSet | ||||
| F.19 Host member states #14 | enumerationSet | ||||
| F.19 Host member states #15 | enumerationSet | ||||
| F.19 Host member states #16 | enumerationSet | ||||
| F.19 Host member states #17 | enumerationSet | ||||
| F.19 Host member states #18 | enumerationSet | ||||
| F.19 Host member states #19 | enumerationSet | ||||
| F.19 Host member states #20 | enumerationSet | ||||
| F.19 Host member states #21 | enumerationSet | ||||
| F.19 Host member states #22 | enumerationSet | ||||
| F.19 Host member states #23 | enumerationSet | ||||
| F.19 Host member states #24 | enumerationSet | ||||
| F.19 Host member states #25 | enumerationSet | ||||
| F.19 Host member states #26 | enumerationSet | ||||
| F.19 Host member states #27 | enumerationSet | ||||
| F.19 Host member states #28 | enumerationSet | ||||
| F.19 Host member states #29 | enumerationSet | ||||
| F.19 Host member states #30 | enumerationSet | ||||
| Part G - Information on rights and obligations attached to other tokens | |||||
| G.1 Purchaser rights and obligations | textBlock | ||||
| G.2 Exercise of rights and obligations | textBlock | ||||
| G.3 Conditions for modifications of rights and obligations | textBlock | ||||
| G.4 Future public offers | textBlock | ||||
| G.5 Issuer retained other token | integer | ||||
| G.6 Utility token classification | boolean | ||||
| G.7 Key features of goods or services utility tokens | text | ▪ Access the Network: The Token is required to access the decentralized compute and storage of the Network. ▪ Interact with the Network: The Token is necessary to operate a Network node and participate in the security of the Network ▪ Interact with the Network Governance Mechanism The purpose of the Token governance is to create a stable and trustworthy ecosystem by allowing users who stake their Tokens to access and participate in the decentralized, balanced ecosystem consensus mechanism). Token holders only participate in technical and/or operational decision-making. They have no influence over the corporate governance/policy of the Association or any other party of the Nillion ecosystem. |
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| G.8 Utility tokens redemption | text | ||||
| G.9 Non-trading request | boolean | ||||
| G.10 Other tokens purchase or sale modalities | text | ||||
| G.11 Other tokens transfer restrictions | text | The Trading Platforms in accordance with applicable laws and internal policies and terms may impose restrictions to buyers and sellers of Tokens on the Trading Platforms themselves. |
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| G.12 Supply adjustment protocols | boolean | ||||
| G.13 Supply adjustment mechanisms | text | ||||
| Other token schemes details | |||||
| G.14 Token value protection schemes | boolean | ||||
| G.15 Token value protection schemes description | textBlock | ||||
| G.16 Compensation schemes | boolean | ||||
| G.17 Compensation schemes description | textBlock | ||||
| G.18 Applicable law | textBlock | The creation of the Tokens is governed by the applicable laws in Switzerland where the issuer entity is incorporated. Nothing in this white paper shall deprive any consumer located in the European Union or European Economic Area of the mandatory rights conferred on that consumer by the consumer-protection legislation of his or her country of habitual residence. |
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| G.19 Competent court | textBlock | If you are an EU or EEA consumer, you may be able to bring any judicial proceedings before the competent court of your place of residence. |
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| Part H – Information on underlying technology | |||||
| H.1 Distributed ledger technology (DTL) | text | The Nillion Network is a decentralized platform for secure, high-value data storage and computation. It uses clustering for scalable performance without relying on a global shared state. Its Blind Compute technology ensures data remains encrypted during transfer, storage, and computation, enabling private AI, LLM inference, and other secure applications. Employing Privacy-Enhancing Technologies like MultiParty Computation (MPC), Fully Homomorphic Encryption (FHE), and Trusted Execution Environments (TEEs), the network guarantees data privacy throughout its lifecycle. It comprises two layers: the nilChain, the DLT component, and the Petnet. |
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| H.2 Protocols and technical standards | text | The Cosmos NILchain has been permanently halted and a final snapshot of all Token balances on the NILchain was taken on 23 March 2026 at 14:00 UTC ( "Snapshot"). Following the halt of the NILchain, the existing Token Bridge that enabled users to migrate their Tokens from the Cosmos NILchain to the Ethereum NIL token is no longer operational. Accordingly, Token holders who did not transfer their Tokens to Ethereum before the Snapshot must claim their corresponding allocation through a Merkle-based distribution mechanism. For more information about the Merkle-based distribution mechanism ("Merkle Mechanism"), please refer to this article on the issuer's website: https://nillion.com/news/nil-token-migration-guide/ |
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| H.3 Technology used | textBlock | ||||
| H.4 Consensus mechanism | text | ||||
| H.5 Incentive mechanisms and applicable fees | text | ||||
| H.6 Use of distributed ledger technology | boolean | ||||
| H.7 DLT functionality description | textBlock | ||||
| Other token audit details | |||||
| H.8 Audit | boolean | ||||
| H.9 Audit outcome | textBlock | ||||
| Part I - Information on risks | |||||
| I.1 Offer-related risks | textBlock | ▪ Multiple White Paper Risk: Token holders understand that any third party can decide to draft and publish a MiCA white paper about the Token ("Spontaneous White Paper"). The publication of these Spontaneous White Papers does not imply any endorsement by the Association that the Spontaneous White Papers are complete, correct, fair, clear and not misleading. ▪ Spontaneous Admission to Trading Risk by Trading Platform: Third parties can elect to admit the Token on their Trading Platforms without any request, authorization or approval by the Association or anyone else. Pursuant to article 5 (2) of MiCA, Trading Platforms are responsible for ensuring compliance with all applicable laws, especially MiCA requirements with respect to the spontaneous admission of the Token to trading. The Association, its affiliates, directors, and officers shall not be held liable for these spontaneous admissions to trading. ▪ Exchanges Risk: When Token holders buy or sell Token on the Exchanges, the Association does not serve as a contractual party or counterparty to the transaction. Consequently, any legal relationship concerning these Exchanges is subject to their own terms and conditions. The Association, and its service providers, assume no responsibility for the operations, services, or outcomes associated with any transactions or activity on the Exchanges. The Association provides no assurances regarding any Exchange itself and assumes no responsibility or liability for any regulatory, compliance, operational, financial, technical, or reputational failure that may adversely affects its activities. ▪ Pausing and Delisting Risk: The Association cannot guarantee that the Token will remain listed or tradeable on any of the Exchanges. Delisting (or the temporary pausing of such listing) on any of the Exchanges could significantly hinder the ability of Token holders to buy, sell, or otherwise transact in Token. In the event of delisting, Token holders may face challenges in finding alternative markets or counterparties willing to trade or transact in the Token, which could impact the liquidity and market value of Token. ▪ Trading Risk: The Association does not control the secondary markets. There can be no assurance as to the secondary market (if any) in Token. It cannot guarantee the depth, stability, or sustainability of any secondary market for Token. Limited market depth or trading activity may result in reduced liquidity, increased price volatility, and challenges in buying or selling the Token at desired prices. The Association also cannot guarantee the healthy and consistent availability of buying or selling opportunities for the Token or the integrity of the market price. Trading activity may be affected by manipulative practices such as wash trading, front-running, and similar schemes. While Exchanges and other Trading Platforms may be subject to varying regulatory frameworks that may or may not prohibit such practices and impose oversight to detect and deter them, the Association assumes no responsibility or liability for their effective prevention or enforcement. ▪ Operational and Technical Risk: The Exchanges operate interfaces that allow users to trade crypto-assets for or other crypto-assets. The reliance on any Exchanges' internal system for asset storage and transfer adds an additional layer of counterparty risk, as users are exposed to potential operational, technical, or human errors during these processes, including the following: ▪ Trades on an Exchange may be executed based on a centralized matching algorithm and are often recorded off-chain, meaning they are not directly related to transparent on-chain transfers of crypto-assets, and could dissimulate detrimental trade matching or rogue practices. The traded assets are recorded solely on the Exchange's internal ledger, with each internal ledger entry corresponding to an offsetting trade involving either government currency or another crypto asset. ▪ Funds deposited by users for trading may be co-mingled by the Exchanges, rather than stored in unique wallet addresses for each user. This practice results in the centralization of a large volume of assets in a single location, which in turn increases the potential risk of damage or theft, particularly in the event of a hack or security breach. ▪ Furthermore, users who wish to trade or withdraw their Token may be required to deposit them into the Exchange, increasing the risk of loss in the event of a failure of the deposit or withdrawal Token processes set up by an Exchange. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05. |
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| I.2 Issuer-related risks | textBlock | ▪ Abandonment/Lack of Success Risk: The Network and the activities of the Association may be partially or totally abandoned for several reasons including, but not limited to, the lack of interest from the public, incapacitation or withdrawal of Token key developers and project supporters, force majeure (including pandemics and wars) or lack of commercial success or prospects. ▪ Change Risk: The Network may evolve over time. This could involve pivoting from the original vision of the Network or modifying how the vision and objectives of the project are executed. Such changes may be driven by market conditions, regulatory development, technological advancements, or strategic decisions by Network contributors. While adaptation and change can foster innovation, it also introduces risks, including shifts in value proposition and potential misalignment with prior expectations. ▪ Decentralization Risk: The Network is neither operated nor controlled by the Association or any of its affiliates. Should Token holders interact with the Network, they are engaging directly with the Network and potentially with third parties that might have no affiliation or relationship with the Issuer. This means that the Association does oversee or manage these interactions, and neither of them does assume responsibility for any outcomes that may arise. ▪ Partner Risk: The implementation of the Network depends strongly on the collaboration and functioning of services provided by several third parties, core contributors, activities of the legal entities associated with the project and other crucial ecosystem partners. Loss or changes in the project's leadership, key partners, and other service providers can lead to disruptions, loss of trust, reputational damage, or even complete project failure. The Association cannot guarantee that the Network will be successfully developed, deployed and remain operational in perpetuity. ▪ Legal and Regulatory Compliance Risk: Crypto-assets and blockchain technologies are subject to an evolving regulatory landscape worldwide. Regulations vary widely across jurisdiction and may be subject to significant changes, which would lead to changes with respect to the trading of the Token. Changes in laws or regulations may negatively impact the value, legality, or functionality of the Token. Non-compliance with changing or newly formed regulations can result in investigations, enforcement actions, penalties, fines, sanctions, or the prohibition of trading of Token, impacting the Network's viability and market acceptance. The Association, core contributors, or other ecosystem partners could be subject to private litigation. Additionally, any legal uncertainties, potential lawsuits, or adverse legal rulings can pose significant risks to the project. Legal challenges may ultimately affect the legality, usability, or value of the Token. ▪ Reputational Risk: There could be a risk of negative publicity related to the Network and its affiliated legal entities, whether due, without limitation to operational failures, security breaches, or association with illicit activities, all of which can damage the Network ecosystem reputation and, by extension, the value and usability of the Token. ▪ Operational Risk: Any failure to develop or maintain effective internal control or any difficulties encountered in the implementation of such controls could harm the operations of the Association, causing disruptions, financial losses, or reputational damage. ▪ Competition Risk: There are other crypto-assets and projects in the decentralized storage space, and new competitors may enter the market at any time. The effect of existing, new or additional competition on the Token or its market price cannot be predicted or quantified. Competitors may have significantly greater financial, legal, and technical resources than the Association and there is no guarantee that the project will be able to compete successfully, or at all, with such competitors. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05. |
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| I.3 Other tokens-related risks | textBlock | ▪ Potential fluctuations in value, driven by various factors such as supply and demand dynamics, Token purchasers' and holders' sentiment, and broader market trends, including changes in interest rates, general movements in local and international markets, technological advancements, regulatory changes, and media coverage. Notably, momentum pricing of crypto-assets has previously resulted, and may continue to result, in speculation regarding future appreciation or depreciation in the value of such assets, further contributing to volatility and potentially inflating prices at any given time. ▪ Liquidity risk, where a lack of depth in secondary markets – if any – or limited trading volumes can hinder the ability to execute trades at favorable prices, which could lead to significant losses, especially in fast-moving market conditions. As a result, Token holders may experience challenges in managing their holdings, with the value of the asset subject to unpredictable fluctuations and potential depreciation. ▪ Solvency and collateral risk, if the Token is used to finance further activities, especially in leveraged positions or as collateral for loans. Significant fluctuations in the value of the Token could adversely affect the solvency of its holder, particularly if the Token is pledged as collateral. A drastic decline may trigger margin calls or automatic liquidations, which could further depress Token's price creating a negative feedback loop. This volatility poses the risk of forced asset sales, potentially resulting in substantial losses for the holder and amplifying downward pressure on the market price of the Token. ▪ Custodial Risk: The method chosen to store the Token, like any crypto-asset, carries inherent risks related to the security and management of the storage solution. The chosen storage method – whether hot or cold wallets, or centralized custody – can significantly impact the safety, liquidity, and accessibility of the Token, with direct consequences for the holder's ability to access, trade, or retain their assets. ▪ Scam Risk. Token holders may be subject to the risk of loss resulting from a scam or fraudulent schemes perpetrated by malicious actors targeting Token holders. These scams include, but are not limited to, phishing or social engineering on social Networks or by email, fake giveaways, identity theft or impersonation of key contributors to the Network, creation of fake Tokens, offering fake Token airdrops, among others. Token holders, recipients and purchasers should always verify and confirm that they are interfacing with legitimate websites, personnel, and other assets associated with the Network. ▪ Anti-Money Laundering/Counter-Terrorism Financing (AML/CTF) Risk: Crypto-asset wallets holding Token or transactions in Token may be used for money laundering or terrorist financing purposes or attributed to a person or entity known to have committed or is associated with such offenses. Consequently, there is a risk that a public wallet address holding Token could be flagged in relation to AML/CTF efforts. In such cases, receiving Tokens could result in a holder's address being flagged by relevant authorities, Exchanges, or other service providers, which may lead to restrictions on transaction or the freezing of a holder's assets. Token holders may thus face legal or regulatory challenges if their address becomes associated with illicit activities, impacting their ability to freely access, trade, or transfer their tokens. ▪ Taxation Risk: The taxation regime that applies to the trading of Tokens by either individual holders or legal entities will depend on each Token holder's jurisdiction. The Association cannot guarantee that the holding of the Token, the receipt of the Token, conversion of fiat currency against the Token, or other conversion of other crypto assets against the Token, will not incur tax consequences. It is the Token holder's sole responsibility to comply with all applicable tax laws, including, but not limited to, the reporting and payment of income tax, wealth tax, capital gains tax, or other similar taxes arising in connection with the appreciation and depreciation of the Token. ▪ Market Abuse Risk: The market for crypto-assets is rapidly evolving, spanning local, national, and international Networks with an expanding range of assets and participants. Any market abuse, along with a potential loss of confidence among holders, could adversely impact the value and stability of the Token. Notably: ▪ Significant trading activity may take place on systems and Networks with limited oversight and predictability. Sudden and rapid changes in the supply or demand of a crypto-asset, particularly those with low market capitalization or low unit prices, can result in extreme price volatility. ▪ Additionally, the inherent characteristics of crypto-assets and their underlying infrastructure may be exploited by certain market participants to engage in abusive trading practices such as front-running, spoofing, pump-and-dump schemes, and fraud across different Networks, systems, or jurisdictions. ▪ Legal and Regulatory Risk: There is a lack of regulatory harmonization globally, which results in diverging regulatory frameworks. Regulations related to crypto-assets remain in flux globally with possible further regulatory evolution in the future. Divergent and shifting regulation could negatively impact the value, utility and overall viability of the Token. Specifically: ▪ While Token is characterized as a token used to access and interact with the Network, certain non-EU regulators may nevertheless classify the Token as a security, financial instrument, or payment instrument under their respective legal frameworks. Such classifications could impose specific regulatory constraints, leading to significant changes in how the Token is structured, purchased, or traded. ▪ Evolving regulations could substantially increase compliance costs and operational burdens relating to facilitating transactions in the Token. ▪ New or restrictive regulations could result in Token losing functionality, depreciating in value, or even becoming illegal or impossible to use, buy or sell in certain jurisdictions. ▪ Regulators could take enforcement action against the Association, if they determine that the Token constitutes a regulated instrument that has been issued in a non-compliant manner or that the activities of the project, its core contributors or other ecosystem partners violate existing laws. Such actions could expose such parties to legal and financial penalties, including civil and criminal liability. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05 |
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| I.4 Project implementation-related risks | textBlock | ▪ Dependency Risk: The Network relies on third-party technologies, infrastructures, and Networks, which could impact its functionality, security, and long-term sustainability. Any disruptions, vulnerabilities, regulatory scrutiny or changes in the Network may result in a negative effect on the Token. This reliance on external infrastructure increases systemic risk, as unforeseen issues in third-party infrastructure could cascade into disruptions in the ecosystem. ▪ Decentralized Governance Risk: Participation in the Network's decentralized governance may involve various risks and uncertainties. The Token holders understand and acknowledge that changes and/or updates to the Network and the Network's key parameters, smart contracts and software code may be subject to the Network's decentralized decision-making process. This may result in adverse changes to the Network. The Association cannot predict the proposals and decisions of the Network's decentralized governance and assumes no responsibility or liability for them. Governance decisions are made collectively by the community of Token holders, who can propose, vote on, and implement changes. This decentralization promotes transparency and inclusivity, it also introduces significant risks. Since the Association has no direct authority over governance decisions, it cannot unilaterally intervene or override changes, even if they are detrimental to the ecosystem. The community may reject crucial decisions, potentially leaving fundamental issues pertaining to its scope of power unaddressed. Conversely, Token holders could propose and approve amendments that introduce unforeseen technical, economic, or security risks, negatively impacting the usability, value, or regulatory standing of Tokens. This decentralized decision-making process may lead to fragmentation, conflicts of interest, governance deadlocks, and alike, all of which could undermine the sustainability and security of the Network and/or the ecosystem. ▪ Reliability Risk: There is a risk that that the key features and services of the Network may not always function properly, negatively affecting the community's perception of the Network and its underlying technology and in turn, affecting the value of the Token. The Network will be deployed on an "as is" and "as available" basis without warranties of any kind. The Association cannot and do not warrant that the Token, the software code of the Token, or the Network, including the Token Bridge are reliable current or error-free, free of viruses or other harmful components. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05. |
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| I.5 Technology-related risks | textBlock | ▪ Cybersecurity Risk: The Token - including the Network infrastructure, underlying technology such as smart contracts, Merkle Mechanism, wallets and other components - may be vulnerable to cyberattacks. Malicious actors may exploit software vulnerabilities, attack consensus mechanisms, or compromise private keys to gain unauthorized access to the Token. Risks include hacking attempts on the Network, smart contract exploits, phishing attacks, malware infections, and other forms of cybercrime that could result in the theft, loss, or unauthorized transfer of the Token. Since digital assets exist entirely in a technological environment, they are inherently exposed to evolving cyber threats, some of which may be undetectable or irreparable until after significant damage has occurred. ▪ Layer 2 Risk: The Network operates on a Ethereum Layer 2 architecture. Running the Network on a L2 introduces specific risks including sequencer downtime or centralization, delayed final settlement on the base layer, smart contract vulnerabilities in the underlying L2 infrastructure, and dependency on the continued availability of transaction data. Token holders are solely responsible for assessing these risks before interacting with the Network. ▪ Blockchain Risk: The Network could be susceptible to consensus-related attacks, including but not limited to double-spend attacks, majority validation power attacks, censorship attacks, and sybil attacks. Any successful attack presents a risk to execution of transaction associated with the Token. ▪ Smart Contract Risk: Transactions associated with the Token rely on smart contracts deployed on a blockchain network, including Merkle Mechanism n . are susceptible, including but not limited to, to coding vulnerabilities, bugs, cyber attacks, centralized management of private keys or security flaws that could be exploited by malicious actors. A breach in the smart contract could result in unauthorized transactions, token loss, or manipulation of the staking, governance and Token minting mechanisms, negatively impacting the Token's security and trust among Token holders. Even though independent security audits are routinely conducted, unforeseen vulnerabilities may still pose a risk. ▪ Private Key Management Risk and Loss of Access to Crypto-Assets: The security of the Token holding heavily relies on the management of private keys, which are used to access and control crypto-assets. The Token holders are responsible for the custody of their Tokens in a compatible cryptographic wallet and for the security of their private keys. Poor management practices, loss, or theft of private keys, or respective credential, can lead to irreversible loss of access to the Tokens. If a Token holder connects their wallet to malicious applications or Networks, they also risk unauthorized access to their assets and their Token holdings. ▪ Network-Level Risk: It cannot be excluded that any technical failure, malfunction, or vulnerability within the Network could directly or indirectly impact the value of the Token. ▪ The Network could be subject to critical exploits, such as reentrancy attacks, logic errors, or oracle manipulation, which could lead to unintended token transfers, assets being drained from the system, or tokens being irretrievably lost. Fixing such issues may require significant coordination, governance approval, or even disruptive measures such as Network migrations or forks, none of which are guaranteed to be successful. ▪ Any security breach, or governance deadlock affecting the Network or the decentralized governance system could have cascading effects, including depreciation of the Token's value, reduced market confidence, and potential loss of funds for Token holders. ▪ Settlement Finality and Irrevocability of Transactions: Transactions in Token may be irreversible. Holders sending Tokens to nonexistent or incorrect addresses may irrevocably lose their Tokens and be unable to reverse the transaction or recover their Tokens. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.0 |
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| I.6 Mitigation measures | textBlock | To further reduce exposure to these risks, prospective Token holders should adopt appropriate safeguards based on their chosen custody method and remain vigilant by actively monitoring publicly available news and market signals, enabling them to respond swiftly to significant developments which may result in the materialization of specific risks. |
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| Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts | |||||
| J.1 Adverse impacts on climate and other environment-related adverse impacts | textBlock | The energy consumption for the validation and finality of transactions and the maintenance of the integrity of the distributed ledger of transactions for the period is estimated to be lower than 500'000 kWh. (see S.08). |
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| Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism | |||||
| General information about adverse impacts | |||||
| S.1 Name | text | ||||
| S.2 Relevant legal entity identifier | text | ||||
| S.3 Name of the crypto-asset | text | ||||
| S.4 Consensus mechanism | text | ||||
| S.5 Incentive mechanisms and applicable fees | text | ||||
| S.6 Beginning of period to which disclosed information relates | date | ||||
| S.7 End of period to which disclosed information relates | date | ||||
| Mandatory key indicator | |||||
| S.8 Energy consumption | energy (kWh) | ||||
| Sources and methodologies | |||||
| S.9 Energy consumption sources and methodologies | textBlock | ||||
| Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of consensus mechanism | |||||
| Supplementary key indicators | |||||
| S.10 Renewable energy consumption | percent | ||||
| S.11 Energy intensity | energy (kWh) | ||||
| S.12 Scope 1 DLT GHG emissions - controlled | GHG emissions (tCO2e) | ||||
| S.13 Scope 2 DLT GHG emissions - purchased | GHG emissions (tCO2e) | ||||
| S.14 GHG intensity | GHG emissions (tCO2e) | ||||
| Sources and methodologies | |||||
| S.15 Key energy sources and methodologies | textBlock | ||||
| S.16 Key GHG sources and methodologies | textBlock | ||||
| Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism | |||||
| Optional indicators | |||||
| S. 17 Energy mix | percent | ||||
| S.18 Energy use reduction | |||||
| Energy use reduction target (absolute value) | energy (kWh) | ||||
| Energy use reduction target (percentage) | percent | ||||
| S.19 Carbon intensity (kgCO2e/kWh) | decimal | ||||
| S.20 Scope 3 DLT GHG emissions - value chain | GHG emissions (tCO2e) | ||||
| S.21 GHG emissions reduction targets or commitments | textBlock | ||||
| S.22 Generation of waste electrical and electronic equipment (WEEE) | mass (tonnes) | ||||
| S.23 Non-recycled WEEE ratio | percent | ||||
| S.24 Generation of hazardous waste | mass (tonnes) | ||||
| S.25 Generation of waste (all types) | mass (tonnes) | ||||
| S.26 Non-recycled waste ratio (all types) | percent | ||||
| S.27 Waste intensity (all types) | mass (tonnes) | ||||
| S.28 Waste reduction targets or commitments (all types) | textBlock | ||||
| S.29 Impact of use of equipment on natural resources | textBlock | ||||
| S.30 Natural resources use reduction targets or commitments | textBlock | ||||
| S.31 Water use | volume (m3) | ||||
| S.32 Non recycled water ratio | percent | ||||
| Sources and methodologies | |||||
| S.33 Other energy sources and methodologies | textBlock | ||||
| S.34 Other GHG sources and methodologies | textBlock | ||||
| S.35 Waste sources and methodologies | textBlock | ||||
| S.36 Natural resources sources and methodologies | textBlock | ||||