White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG GWM30MLW3
Preamble
00. Table of Content
- Preamble
- 01. Date of notification
- 02. Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114
- 03. Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114
- 04. Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114
- 05. Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114
- 06. Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114
- Summary
- 07. Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114
- 08. Characteristics of the crypto-asset
- 09. Information about the quality and quantity of goods or services to which the utility tokens give access and restrictions on the transferability
- 10. Key information about the offer to the public or admission to trading
- Part A – Information about the offeror or the person seeking admission to trading
- A.1 Name
- A.2 Legal form
- A.3 Registered address
- A.4 Head office
- A.5 Registration date
- A.6 Legal entity identifier
- A.7 Another identifier required pursuant to applicable national law
- A.8 Contact telephone number
- A.9 E-mail address
- A.10 Response time (Days)
- A.11 Parent company
- A.12 Members of the management body
- A.13 Business activity
- A.14 Parent company business activity
- A.15 Newly established
- A.16 Financial condition for the past three years
- A.17 Financial condition since registration
- Part B – Information about the issuer, if different from the offeror or person seeking admission to trading
- B.1 Issuer different from offeror or person seeking admission to trading
- B.2 Name
- B.3 Legal form
- B.4 Registered address
- B.5 Head office
- B.6 Registration date
- B.7 Legal entity identifier
- B.8 Another identifier required pursuant to applicable national law
- B.9 Parent company
- B.10 Members of the management body
- B.11 Business activity
- B.12 Parent company business activity
- 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
- C.2 Legal form
- C.3 Registered address
- C.4 Head office
- C.5 Registration date
- C.6 Legal entity identifier
- C.7 Another identifier required pursuant to applicable national law
- C.8 Parent company
- C.9 Reason for crypto-Asset white paper Preparation
- C.10 Members of the Management body
- C.11 Operator business activity
- C.12 Parent company business activity
- C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
- C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
- Part D – Information about the crypto-asset project
- D.1 Crypto-asset project name
- D.2 Crypto-assets name
- D.3 Abbreviation
- D.4 Crypto-asset project description
- D.5 Details of all natural or legal persons involved in the implementation of the crypto-asset project
- D.6 Utility Token Classification
- D.7 Key Features of Goods/Services for Utility Token Projects
- D.8 Plans for the token
- D.9 Resource allocation
- D.10 Planned use of Collected funds or crypto-Assets
- Part E – Information about the offer to the public of crypto-assets or their admission to trading
- E.1 Public offering or admission to trading
- E.2 Reasons for public offer or admission to trading
- E.3 Fundraising target
- E.4 Minimum subscription goals
- E.5 Maximum subscription goals
- E.6 Oversubscription acceptance
- E.7 Oversubscription allocation
- E.8 Issue price
- E.9 Official currency or any other crypto-assets determining the issue price
- E.10 Subscription fee
- E.11 Offer price determination method
- E.12 Total number of offered/traded crypto-assets
- E.13 Targeted holders
- E.14 Holder restrictions
- E.15 Reimbursement notice
- E.16 Refund mechanism
- E.17 Refund timeline
- E.18 Offer phases
- E.19 Early purchase discount
- E.20 Time-limited offer
- E.21 Subscription period beginning
- E.22 Subscription period end
- E.23 Safeguarding arrangements for offered funds/crypto- Assets
- E.24 Payment methods for crypto-asset purchase
- E.25 Value transfer methods for reimbursement
- E.26 Right of withdrawal
- E.27 Transfer of purchased crypto-assets
- E.28 Transfer time schedule
- E.29 Purchaser's technical requirements
- E.30 Crypto-asset service provider (CASP) name
- E.31 CASP identifier
- E.32 Placement form
- E.33 Trading platforms name
- E.34 Trading platforms Market identifier code (MIC)
- E.35 Trading platforms access
- E.36 Involved costs
- E.37 Offer expenses
- E.38 Conflicts of interest
- E.39 Applicable law
- E.40 Competent court
- Part F – Information about the crypto-assets
- F.1 Crypto-asset type
- F.2 Crypto-asset functionality
- F.3 Planned application of functionalities
- A description of the characteristics of the crypto asset, 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
- F.5 The type of submission
- F.6 Crypto-asset characteristics
- F.7 Commercial name or trading name
- F.8 Website of the issuer
- F.9 Starting date of offer to the public or admission to trading
- F.10 Publication date
- F.11 Any other services provided by the issuer
- F.12 Language or languages of the crypto-asset white paper
- 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
- F.14 Functionally fungible group digital token identifier
- F.15 Voluntary data flag
- F.16 Personal data flag
- F.17 LEI eligibility
- F.18 Home Member State
- F.19 Host Member States
- Part G – Information on the rights and obligations attached to the crypto-assets
- G.1 Purchaser rights and obligations
- G.2 Exercise of rights and obligations
- G.3 Conditions for modifications of rights and obligations
- G.4 Future public offers
- G.5 Issuer retained crypto-assets
- G.6 Utility token classification
- G.7 Key features of goods/services of utility tokens
- G.8 Utility tokens redemption
- G.9 Non-trading request
- G.10 Crypto-assets purchase or sale modalities
- G.11 Crypto-assets transfer restrictions
- G.12 Supply adjustment protocols
- G.13 Supply adjustment mechanisms
- G.14 Token value protection schemes
- G.15 Token value protection schemes description
- G.16 Compensation schemes
- G.17 Compensation schemes description
- G.18 Applicable law
- G.19 Competent court
- Part H – information on the underlying technology
- H.1 Distributed ledger technology (DTL)
- H.2 Protocols and technical standards
- H.3 Technology used
- H.4 Consensus mechanism
- H.5 Incentive mechanisms and applicable fees
- H.6 Use of distributed ledger technology
- H.7 DLT functionality description
- H.8 Audit
- H.9 Audit outcome
- Part I – Information on risks
- I.1 Offer-related risks
- I.2 Issuer-related risks
- I.3 Crypto-assets-related risks
- I.4 Project implementation-related risks
- I.5 Technology-related risks
- I.6 Mitigation measures
- 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
- S.1 Name
- S.2 Relevant legal entity identifier
- S.3 Name of the cryptoasset
- S.4 Consensus Mechanism
- S.5 Incentive Mechanisms and Applicable Fees
- S.6 Beginning of the period to which the disclosure relates
- S.7 End of the period to which the disclosure relates
- S.8 Energy consumption
- S.9 Energy consumption sources and methodologies
- S.10 Renewable energy consumption
- S.11 Energy intensity
- S.12 Scope 1 DLT GHG emissions – Controlled
- S.13 Scope 2 DLT GHG emissions – Purchased
- S.14 GHG intensity
- S.15 Key energy sources and methodologies
- S.16 Key GHG sources and methodologies
01. Date of notification
02. Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114
03. Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114
04. Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114
05. Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114
06. Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114
Summary
07. Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114
08. Characteristics of the crypto-asset
The crypto-asset Cronos (CRO) referred to in this white paper is a crypto-asset other than e-money tokens (EMTs) or asset-referenced tokens (ARTs). The supply of the crypto-asset is limited to 100,000,000,000 units. The first on-chain activity of the crypto-asset occurred on 2018-11-14 on Ethereum (transaction hash: 0xbd29dfc2cfc9b2e2170d6a564903c3e32e713b61c01e31ff8664cca24736b431, source: https://etherscan.io/tx/0xbd29dfc2cfc9b2e2170d6a564903c3e32e713b61c01e31ff8664cca24736b431, accessed on 2025-12-02). The first activity of the crypto-asset on the Cronos PoS chain occurred on 2021-03-25 (block hash: 5BADB996831CE0C37BA3ED50C03E12400B97D6B8DA19E932FADCD62E91A97FEA, source: https://cronos-pos.org/explorer/block/1, accessed on 2025-12-02). The first activity of the crypto-asset on the Cronos EVM chain occurred on 2021–11-08 (block hash: 0xa7f4e603aa51239a15e0a3fafb15c6e4c6d6f2c39c55770330efd2fa5afc12a9, source: https://explorer.cronos.org/block/1, accessed on 2025-12-02).
The CRO crypto-asset (formerly known as Crypto.org Coin) is the decentralised token underpinning the Cronos ecosystem. On the Cronos POS Chain, CRO is natively issued and used to secure the network through a Proof-of-Stake consensus mechanism. Validators stake CRO to participate in block production and transaction validation, while delegators may bond CRO to validators to contribute to network security and receive protocol-level staking rewards. New CRO tokens are minted and distributed as staking incentives in accordance with on-chain parameters designed to maintain a target proportion of bonded tokens relative to the circulating supply.
The crypto-asset does not grant any legally enforceable or contractual rights or obligations to its holders or purchasers. Any functionalities accessible through the underlying technology are purely technical or operational in nature and do not confer rights comparable to ownership, profit participation, governance, or similar entitlements known from traditional financial instruments.
09. Information about the quality and quantity of goods or services to which the utility tokens give access and restrictions on the transferability
As defined in Article 3(9) of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets – amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 – a utility token is “a type of crypto-asset that is only intended to provide access to a good or a service supplied by its issuer”. This crypto-asset does not qualify as a utility token, as its intended use goes beyond providing access to a good or service supplied solely by the issuer.
10. Key information about the offer to the public or admission to trading
Crypto Risk Metrics GmbH is seeking admission to trading on Payward Global Solutions LTD ("Kraken") platform in the European Union in accordance with Article 5 of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937. The admission to trading is not accompanied by a public offer of the crypto-asset.
Part A – Information about the offeror or the person seeking admission to trading
A.1 Name
A.2 Legal form
A.3 Registered address
A.4 Head office
A.5 Registration date
A.6 Legal entity identifier
A.7 Another identifier required pursuant to applicable national law
A.8 Contact telephone number
A.9 E-mail address
A.10 Response time (Days)
A.11 Parent company
A.12 Members of the management body
| Identity | Function | Business Address |
|---|---|---|
A.13 Business activity
Crypto Risk Metrics GmbH is a technical service provider, which supports regulated entities in the fulfilment of their regulatory requirements. In this regard, Crypto Risk Metrics GmbH, among other services, acts as a data-provider for ESG data according to article 66 (5). Due to the regulations laid out in article 4 (7), 5 (4) and 66 (3) of the Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937, Crypto Risk Metrics GmbH aims to provide central services for crypto-asset white papers.
A.14 Parent company business activity
Crypto Risk Metrics GmbH does not have a parent company. Accordingly, no business activity of a parent company is to be reported in this section.
A.15 Newly established
A.16 Financial condition for the past three years
Crypto Risk Metrics GmbH, founded in 2018 and based in Hamburg (HRB 154488), has undergone several strategic shifts in its business focus since incorporation. Due to these changes in business model and operational direction over time, the financial figures from earlier years are only comparable to a limited extent with the company’s current commercial activities. The present business model – centred around regulatory technology and risk analytics in the context of the MiCAR framework – has been established progressively and can be realistically considered fully operational since approximately 2024.
The company’s financial trajectory over the past three years reflects the transition from exploratory development toward market-ready product delivery. The profit and loss after tax for the last three financial years is as follows:
2024 (unaudited): negative EUR 50.891,81
2023 (unaudited): negative EUR 27.665,32
2022: EUR 104.283,00.
The profit in 2022 resulted primarily from legacy consulting activities, which were discontinued in the course of the company’s repositioning.
The losses in 2023 and 2024 result from strategic investments in the development of proprietary software infrastructure, regulatory frameworks, and compliance technology for the MiCAR ecosystem. During those periods, no substantial commercial revenues were expected, as resources were directed toward preparing the platform for regulated market entry.
A fundamental repositioning of the company occurred in 2023 and especially in 2024, when the focus shifted toward providing risk management, regulatory reporting, and supervisory compliance solutions for financial institutions and crypto-asset service providers. This marked a material shift in business operations and monetisation strategy.
Based on the current business development in Q4 2025, revenues exceeding EUR 550,000 are expected for the fiscal year 2025, with an anticipated net profit of approximately EUR 100,000. These figures are neither audited nor based on a finalized annual financial statement; they are derived from the company’s current pipeline, client development, and active commercial engagements. Accordingly, they are subject to future risks and market fluctuations.
With the regulatory environment now taking shape and the platform commercially validated, it is assumed that the effects of the strategic developments will continue to materialize in 2026. The company foresees further scalability of its technology and growing market demand for regulatory compliance tools in the European crypto-asset sector.
No public subsidies or governmental grants have been received to date; all operations have been financed through shareholder contributions and internally generated resources. Crypto Risk Metrics has never accepted any payments via Tokens from projects it has worked for and – due to the internal Conflicts of Interest Policy – never will.
A.17 Financial condition since registration
Not applicable. The company has been established for more than three years and its financial condition over the past three years is provided in Part A.16 above.
Part B – Information about the issuer, if different from the offeror or person seeking admission to trading
B.1 Issuer different from offeror or person seeking admission to trading
B.2 Name
B.3 Legal form
B.4 Registered address
B.5 Head office
B.6 Registration date
B.7 Legal entity identifier
B.8 Another identifier required pursuant to applicable national law
B.9 Parent company
B.10 Members of the management body
| Name | Position | Business address |
|---|---|---|
B.11 Business activity
FORIS DAX, INC. (Crypto.com) operates as a global provider of cryptocurrency exchange, wallet, payment, and financial service products. Its activities broadly include offering trading services for digital assets, developing custodial and non-custodial wallet solutions, and supporting payment use cases through its mobile application, card programs, and related infrastructure. The group operates through multiple licensed subsidiaries across various jurisdictions. The CRO token (formerly known as Crypto.org Coin) functions as the central utility token of the Crypto.com ecosystem. It is designed to support technical, economic, and coordination mechanisms across three primary blockchain networks:
- Cronos PoS Chain (proof-of-stake settlement and governance layer),
- Cronos EVM Layer-1 (smart-contract execution compatible with Ethereum tooling),
- Cronos zkEVM Layer-2 (scalability layer leveraging zero-knowledge proofs).
B.12 Parent company business activity
Not applicable.
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
C.2 Legal form
C.3 Registered address
C.4 Head office
C.5 Registration date
C.6 Legal entity identifier
C.7 Another identifier required pursuant to applicable national law
C.8 Parent company
C.9 Reason for crypto-Asset white paper Preparation
C.10 Members of the Management body
C.11 Operator business activity
C.12 Parent company business activity
C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
Part D – Information about the crypto-asset project
D.1 Crypto-asset project name
D.2 Crypto-assets name
D.3 Abbreviation
D.4 Crypto-asset project description
According to publicly available information (sources: https://docs.cronos-pos.org/, https://docs.cronos.org/, accessed 2025-12-01), the Cronos project is a multi-chain blockchain ecosystem designed to support payment, staking, governance, and decentralised application use cases across interoperable distributed-ledger networks. The ecosystem follows a layered, multi-chain architecture in which each network serves a distinct role with respect to security, execution, and specialised application environments.
The Cronos ecosystem is primarily structured around two production networks that are directly relevant to the CRO crypto-asset: (i) the Cronos POS Chain, which functions as the ecosystem’s layer-zero network for native issuance, security, and governance, and (ii) the Cronos EVM, a permissionless, Ethereum Virtual Machine-compatible Layer-1 network designed for smart contracts and decentralised applications. These networks are built using the Cosmos SDK and Tendermint-based consensus technology and are interconnected through native interoperability mechanisms, including the Inter-Blockchain Communication (IBC) protocol.
The CRO crypto-asset (formerly known as Crypto.org Coin) is the decentralised utility token underpinning the Cronos ecosystem. On the Cronos POS Chain, CRO is natively issued and used to secure the network through a Proof-of-Stake consensus mechanism. Validators stake CRO to participate in block production and transaction validation, while delegators may bond CRO to validators to contribute to network security and receive protocol-level staking rewards. New CRO tokens are minted and distributed as staking incentives in accordance with on-chain parameters designed to maintain a target proportion of bonded tokens relative to the circulating supply. Staked CRO also enables participation in on-chain governance, allowing token holders to vote on protocol proposals submitted via the Cosmos SDK governance framework. Transaction fees on the Cronos POS Chain are designed to be minimal, supporting low-cost transfers and operational use cases.
On the Cronos EVM Layer-1, CRO functions primarily as the transaction-fee (gas) asset required for smart-contract execution and state transitions. The Cronos EVM is EVM-compatible and implemented using Ethermint on top of the Cosmos SDK, allowing developers to deploy Ethereum-based applications with minimal modification. Within this environment, CRO is typically represented in a wrapped, CRC-20-compatible form to enable interaction with smart contracts. The network employs a dynamic fee-market mechanism comparable in structure to Ethereum’s EIP-1559 model, under which users may specify priority fees to influence transaction processing by validators.
The Cronos ecosystem also includes a zkEVM-based Layer-2 network that utilises a separate derivative gas asset and is secured via Ethereum. This environment serves specialised scalability and liquidity-oriented use cases and does not rely on CRO as its primary transactional unit. As such, CRO’s core functional relevance remains concentrated within the Cronos POS Chain and the Cronos EVM Layer-1.
Ecosystem development and adoption are supported by organisations such as Crypto.com and Cronos Labs, which contribute through funding initiatives, accelerator programmes, infrastructure support, and ecosystem coordination (source: https://whitepaper.cronos.org/#ecosystem-support, accessed 2025-12-01). These activities aim to encourage developer participation and network usage but do not constitute any assurance regarding adoption levels, performance, or long-term sustainability.
The CRO crypto-asset does not grant ownership rights, profit-participation claims, or legal entitlements in relation to any issuing or supporting entity. Its role is limited to technical and functional use within the Cronos protocol environments, including transaction execution, staking-based security participation, and governance processes. The availability and scope of these functionalities may evolve over time and remain subject to protocol upgrades, governance decisions, validator participation, and broader technical, economic, and regulatory considerations.
D.5 Details of all natural or legal persons involved in the implementation of the crypto-asset project
| Type of person | Name of person | Business address of person | Domicile of company |
|---|---|---|---|
D.6 Utility Token Classification
D.7 Key Features of Goods/Services for Utility Token Projects
As defined in Article 3(9) of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets – amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 – a utility token is “a type of crypto-asset that is only intended to provide access to a good or a service supplied by its issuer”. This crypto-asset does not qualify as a utility token, as its intended use goes beyond providing access to a good or service supplied solely by the issuer.
D.8 Plans for the token
This section summarizes historical developments related to the Cronos ecosystem and describes planned or anticipated milestones as publicly communicated by the project. All forward-looking elements are subject to significant uncertainty and do not constitute commitments, assurances, or guarantees; they may be modified, delayed, or discontinued at any time. The information below is based on public roadmap materials published by Cronos (source: https://docs.cronos-pos.org/ and Cronos roadmap materials referenced therein; accessed 2025-12-01).
Past milestones:
- Project foundation (Monaco) (June 2021):
The project was initially founded under the Monaco brand, with an early focus on crypto-based payment solutions and consumer-facing financial infrastructure. This entity later became the basis for the broader Crypto.com and Cronos ecosystem.
- Rebranding to Crypto.com (July 2018):
Monaco rebranded to Crypto.com, expanding its scope toward a global crypto platform encompassing payments, exchange services, and supporting blockchain infrastructure.
- CRO supply reduction event (February 2021):
Crypto.com publicly announced a large-scale CRO token burn (destruction of 70 billion CRO tokens) as part of a supply restructuring initiative communicated ahead of the launch of its public blockchain infrastructure. Burned tokens were transferred to a publicly verifiable burn address and removed from circulation, as described in contemporaneous disclosures.
- Crypto.org Chain mainnet launch (now Cronos POS Chain) (march 2021):
The Crypto.org Chain launched on mainnet as a Cosmos SDK–based blockchain with CRO as its native token. The chain was designed to support payments, staking, and governance, and later became known as the Cronos POS Chain.
- Cronos EVM exits beta (December 2022):
The Galileo upgrade was announced as a major network milestone, introducing performance optimizations and expanded Cosmos interoperability features, reinforcing Cronos EVM’s positioning as a production-ready Layer-1 network.
- Cronos zkEVM alpha mainnet (December 2024):
The Cronos zkEVM alpha mainnet was launched, enabling early production use and supporting features such as account abstraction and yield-bearing representations of CRO (e.g., zkCRO).
- “Pallene” (v1.4) upgrade (December 2024):
The Pallene upgrade was communicated as introducing architectural and performance-related enhancements aimed at improving throughput and execution efficiency on Cronos EVM.
- Governance Approval of CRO Re-Minting and Strategic Reserve Creation (March 2025):
Following an on-chain governance vote on the Cronos POS Chain, a proposal was approved to re-mint 70 billion CRO tokens, corresponding to the amount previously burned in February 2021. The newly issued tokens were allocated to a Cronos Strategic Reserve escrow wallet and placed under a five-year lock-up with linear monthly vesting, implemented through a native Cosmos SDK vesting account mechanism. As a result of this action, the total CRO supply was restored to 100 billion tokens, while the originally burned tokens remained permanently out of circulation. The re-minting was implemented as part of a Cronos POS chain upgrade following the conclusion of the governance voting period.
- Announcement of CRO Treasury Strategy Involving Trump Media (August 2025):
Trump Media & Technology Group and Crypto.com publicly announced a proposed strategic arrangement involving the planned establishment of Trump Media Group CRO Strategy Inc., described as a digital asset treasury vehicle focused on the CRO crypto-asset. Public disclosures associated with the announcement indicated an intention for Trump Media to acquire approximately USD 105 million worth of CRO, corresponding to approximately 2% of the circulating CRO supply at the time of announcement, and for Crypto.com to acquire approximately USD 50 million in equity of Trump Media & Technology Group. The announcement further referenced an intended CRO holding of approximately 6.3 billion CRO tokens within the proposed treasury structure. The implementation of the announced arrangement remains subject to completion of the proposed transactions, regulatory processes, and other conditions.
- Launch of Cronos One (December 2025)
Cronos announced the launch of Cronos One, a unified onboarding interface consolidating cross-chain bridging, wallet top-up functionality, and on-chain wallet verification. A core component, Cronos Verify, links a non-custodial wallet to a verified Crypto.com account through a gasless process, publishing only a verifiable status rather than personal data. Cronos One was positioned as an identity and access layer for future identity-aware and agent-driven applications.
Future milestones:
- AI-agend-enabled user interfaces (2026):
Expansion of AI-agent-enabled user interfaces and identity-aware applications across the Cronos ecosystem. Continued development of agent-to-agent interaction and commerce primitives, particularly in enterprise- and coordination-oriented use cases.
- Governance decentralisation (2027):
Potential further evolution of governance, staking, and ecosystem incentive mechanisms, subject to Cronos POS governance processes.
All plans and milestones described above reflect public communications and stated intentions at the time of writing. They are subject to technological constraints, governance decisions, regulatory developments, and market conditions. No assurance can be given regarding timing, implementation, or effectiveness, and actual outcomes may differ materially from those described.
D.9 Resource allocation
Not applicable – no specific project-level resources beyond the issuer’s general operations as described under D.4 have been identified or disclosed. This limits investors’ ability to assess the funding and staffing dedicated specifically to this project.
As the primary activity of the imitating company and operator lies in operating an exchange, it can be assumed that a wide range of external investors and other resources are available to the company. However, it remains entirely unclear to what extent these resources are actually attributable or allocated to the crypto-asset project.
D.10 Planned use of Collected funds or crypto-Assets
Not applicable, as this white paper serves the purpose of admission to trading and is not associated with any fundraising activity for the crypto-asset project.
Part E – Information about the offer to the public of crypto-assets or their admission to trading
E.1 Public offering or admission to trading
E.2 Reasons for public offer or admission to trading
The purpose of seeking admission to trading is to enable the crypto-asset to be listed on a regulated platform in accordance with the applicable provisions of Regulation (EU) 2023/1114 and Commission Implementing Regulation (EU) 2024/2984. The white paper has been drawn up to comply with the transparency requirements applicable to trading venues.
E.3 Fundraising target
E.4 Minimum subscription goals
E.5 Maximum subscription goals
E.6 Oversubscription acceptance
E.7 Oversubscription allocation
E.8 Issue price
E.9 Official currency or any other crypto-assets determining the issue price
E.10 Subscription fee
E.11 Offer price determination method
E.12 Total number of offered/traded crypto-assets
E.13 Targeted holders
E.14 Holder restrictions
Holder restrictions are subject to the rules applicable to the crypto-asset service provider, as well as to any additional restrictions such provider may impose.
E.15 Reimbursement notice
E.16 Refund mechanism
E.17 Refund timeline
E.18 Offer phases
E.19 Early purchase discount
E.20 Time-limited offer
E.21 Subscription period beginning
E.22 Subscription period end
E.23 Safeguarding arrangements for offered funds/crypto- Assets
E.24 Payment methods for crypto-asset purchase
E.25 Value transfer methods for reimbursement
E.26 Right of withdrawal
E.27 Transfer of purchased crypto-assets
E.28 Transfer time schedule
E.29 Purchaser's technical requirements
E.30 Crypto-asset service provider (CASP) name
E.31 CASP identifier
E.32 Placement form
E.33 Trading platforms name
E.34 Trading platforms Market identifier code (MIC)
E.35 Trading platforms access
The token is intended to be listed on the trading platform operated by Payward Global Solutions LTD ("Kraken"). Access to this platform depends on regional availability and user eligibility under Kraken’s terms and conditions. Investors should consult Kraken’s official documentation to determine whether they meet the requirements for account creation and token trading.
E.36 Involved costs
The costs involved in accessing the trading platform depend on the specific fee structure and terms of the respective crypto-asset service provider. These may include trading fees, deposit or withdrawal charges, and network-related gas fees. Investors are advised to consult the applicable fee schedule of the chosen platform before engaging in trading activities.
E.37 Offer expenses
Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.
E.38 Conflicts of interest
MiCAR-compliant crypto-asset service providers shall have strong measures in place in order to manage conflicts of interests. Due to the broad audience this white paper is addressing, potential investors should always check the conflicts-of-interest policy of their respective counterparty.
Crypto Risk Metrics GmbH has established, implemented, and documented comprehensive internal policies and procedures for the identification, prevention, management, and documentation of conflicts of interest in accordance with applicable regulatory requirements. These internal measures are actively applied within the organisation. For the purposes of this specific assessment and the crypto-asset covered by this white paper, a token-specific review has been conducted by Crypto Risk Metrics GmbH. Based on this individual review, no conflicts of interest relevant to this crypto-asset have been identified at the time of preparation of this white paper.
E.39 Applicable law
Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.
E.40 Competent court
Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.
Part F – Information about the crypto-assets
F.1 Crypto-asset type
F.2 Crypto-asset functionality
According to publicly available information from official Cronos documentation and technical resources (source: https://cronos.org, https://whitepaper.cronos.org, accessed 2025-12-02), CRO is the native crypto-asset of the Cronos ecosystem, which comprises multiple interoperable blockchain networks, including the Cronos PoS Chain, Cronos EVM, and Cronos zkEVM. CRO exists natively within the Cronos infrastructure and is also issued in bridged form on other blockchain networks for compatibility and liquidity purposes.
Transaction execution and fee settlement:
CRO functions as the native transaction fee (gas) token across the Cronos ecosystem. On the Cronos PoS Chain, CRO is used to pay transaction fees associated with base-layer operations secured by Proof-of-Stake consensus. On the Cronos EVM Layer-1, CRO is likewise used to pay gas fees for smart-contract execution and transaction processing within the Ethereum-compatible environment. Transaction fees are dynamically calculated and collected by validators according to protocol rules and network conditions.
On the Cronos zkEVM Layer-2, transaction fees are paid using zkCRO, a liquid-staked derivative of CRO that is backed by CRO staked on the Cronos PoS Chain. This design links Layer-2 transaction activity economically to the security of the underlying PoS network.
Network security, staking, and reward distribution:
Within the Cronos PoS Chain, CRO is used as the asset through which economic participation in network security is facilitated. Validators and delegators participate in the Proof-of-Stake process by bonding CRO, thereby contributing to block production, transaction validation, and finality. In return, newly issued CRO is distributed as block rewards through a protocol-defined minting mechanism that operates at each block. This issuance mechanism constitutes an ongoing inflation component designed to incentivize participation and maintain network security.
It should be noted that while CRO is the economic unit used by delegators, the Cronos PoS Chain also employs a dedicated, non-transferable staking and governance token among permissioned validators for consensus coordination. This internal token is not publicly traded and does not represent an economic asset.
On the Cronos EVM, which operates under a Proof-of-Authority–based validator model closely related to Proof-of-Stake, CRO is not used for validator staking or governance, as explicitly stated in the Cronos EVM white paper. CRO’s role on this network is limited to transaction fee payment and application-level utility.
Governance-related coordination:
Governance participation using CRO is limited to protocol-level decision-making on the Cronos PoS Chain, where CRO holders who stake or delegate their tokens may participate indirectly in governance processes such as parameter changes and network upgrades, subject to validator mediation. Governance rights relate exclusively to technical and protocol-level matters and do not extend to decision-making authority over any legal entity associated with the Cronos ecosystem or its contributors.
CRO does not confer governance rights on the Cronos EVM or zkEVM networks beyond their respective protocol rules.
Ecosystem and application-level utility
CRO serves as a medium of exchange and liquidity asset within decentralized applications deployed across the Cronos ecosystem, including DeFi protocols, NFT marketplaces, and liquidity pools. It is commonly used as a base asset for trading pairs, incentive mechanisms, and collateral configurations, depending on the design of individual applications.
Beyond on-chain usage, CRO is integrated into the broader Crypto.com ecosystem, where it is used in centralized products such as payment services, reward programs, and card-based incentive structures. These uses are application-level and contractual in nature and are distinct from CRO’s protocol-level functions within the Cronos blockchains.
Legal and Economic Characterization:
The CRO crypto-asset does not confer ownership, profit participation, or claim rights over the Cronos protocol, Crypto.com, or any affiliated foundation or operating entity. All functionalities of CRO are technical and operational, relating exclusively to transaction processing, network security incentives, governance coordination, and application-level interactions within the Cronos ecosystem.
The actual usability and value of CRO depend on factors such as network stability, validator participation, smart-contract execution, protocol upgrades, interoperability mechanisms, and broader market conditions, all of which are outside the control of individual token holders.
F.3 Planned application of functionalities
Future milestones:
- AI-agend-enabled user interfaces (2026):
Expansion of AI-agent-enabled user interfaces and identity-aware applications across the Cronos ecosystem. Continued development of agent-to-agent interaction and commerce primitives, particularly in enterprise- and coordination-oriented use cases.
- Governance decentralisation (2027):
Potential further evolution of governance, staking, and ecosystem incentive mechanisms, subject to Cronos POS governance processes.
All plans and milestones described above reflect public communications and stated intentions at the time of writing. They are subject to technological constraints, governance decisions, regulatory developments, and market conditions. No assurance can be given regarding timing, implementation, or effectiveness, and actual outcomes may differ materially from those described.
A description of the characteristics of the crypto asset, 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
F.5 The type of submission
F.6 Crypto-asset characteristics
The crypto-asset referred to herein is a crypto-asset other than EMTs and ARTs, and is available on multiple networks. The crypto-asset is fungible up to 8 digits after the decimal point. The crypto-asset constitutes a digital representation recorded on distributed-ledger technology and does not confer ownership, governance, profit participation, or any other legally enforceable rights. Any functionalities associated with the token are limited to potential technical features within the relevant platform environment. These functionalities do not represent contractual entitlements and may depend on future development decisions, technical design choices, and operational conditions. The crypto-asset does not embody intrinsic economic value; instead, its value, if any, is determined exclusively by market dynamics such as supply, demand, and liquidity in secondary markets.
F.7 Commercial name or trading name
F.8 Website of the issuer
F.9 Starting date of offer to the public or admission to trading
F.10 Publication date
F.11 Any other services provided by the issuer
No such services are currently known to be provided by the issuer. However, it cannot be excluded that additional services exist or may be offered in the future outside the scope of Regulation (EU) 2023/1114.
F.12 Language or languages of the crypto-asset white paper
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
F.14 Functionally fungible group digital token identifier
F.15 Voluntary data flag
F.16 Personal data flag
F.17 LEI eligibility
F.18 Home Member State
F.19 Host Member States
Part G – Information on the rights and obligations attached to the crypto-assets
G.1 Purchaser rights and obligations
The crypto-asset does not grant any legally enforceable or contractual rights or obligations to its holders or purchasers.
Any functionalities accessible through the underlying technology are of a purely technical or operational nature and do not constitute rights comparable to ownership, profit participation, governance, or similar entitlements known from traditional financial instruments.
Accordingly, holders do not acquire any claim capable of legal enforcement against the issuer or any third party.
G.2 Exercise of rights and obligations
As the crypto-asset does not establish any legally enforceable rights or obligations, there are no applicable procedures or conditions for their exercise.
Any interaction or functionality that may be available within the technical infrastructure of the project – such as participation mechanisms or protocol-level features – serves operational purposes only and does not create or constitute evidence of any contractual or statutory entitlement.
G.3 Conditions for modifications of rights and obligations
As the crypto-asset does not confer any legally enforceable rights or obligations, there are no conditions or mechanisms under which such rights could be modified.
Adjustments to the technical protocol, smart contract logic, or related systems may occur in the ordinary course of development or maintenance.
Such changes do not alter the legal position of holders, as no contractual or regulatory rights exist. Holders should not interpret technical updates or governance-related changes as amendments to legally binding entitlements.
G.4 Future public offers
Information on the future offers to the public of crypto-assets were not available at the time of writing this white paper (2025-12-01).
G.5 Issuer retained crypto-assets
G.6 Utility token classification
G.7 Key features of goods/services of utility tokens
G.8 Utility tokens redemption
G.9 Non-trading request
G.10 Crypto-assets purchase or sale modalities
Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.
G.11 Crypto-assets transfer restrictions
The crypto-assets themselves are not subject to any technical or contractual transfer restrictions and are generally freely transferable. However, Crypto-Asset Service Providers may impose restrictions on buyers or sellers in accordance with applicable laws, internal policies or contractual terms agreed with their clients.
G.12 Supply adjustment protocols
G.13 Supply adjustment mechanisms
For the crypto-asset in scope, the maximum potential supply is defined as 100,000,000,000 CRO; however, investors should note that the total supply is not fixed, as CRO is subject to an ongoing inflationary issuance mechanism on the Cronos PoS chain, with newly minted CRO distributed as block rewards at a dynamically adjusted annual inflation rate currently bounded between 0.85% and 1.0% under the proposed V5 parameters, which may negatively affect value, dilution, and market expectations. The applicable inflation rate is dynamically adjusted based on the proportion of CRO staked on the network relative to the target staking ratio, such that lower staking participation may result in higher inflation and higher staking participation may result in lower inflation.
G.14 Token value protection schemes
G.15 Token value protection schemes description
G.16 Compensation schemes
G.17 Compensation schemes description
G.18 Applicable law
This white paper is submitted in the context of an application for admission to trading on a trading platform established in the European Union. Accordingly, this white paper shall be governed by the laws of the Federal Republic of Germany.
G.19 Competent court
Any disputes arising in relation to this white paper or the admission to trading may fall under the jurisdiction of the competent courts in Hamburg, Germany.
Part H – information on the underlying technology
H.1 Distributed ledger technology (DTL)
The crypto-asset in scope is implemented on the Cronos PoS Chain, Cronos EVM Chain, Ethereum, Cosmos, Osmosis and Solana networks following the standards described below.
H.2 Protocols and technical standards
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Cronos PoS Chain, Cronos EVM Chain, Ethereum, Cosmos, Solana and Osmosis. In general, when evaluating crypto assets, the total number of tokens issued across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Cronos PoS Chain:
1. Network Protocols
Cronos POS Chain uses a Proof-of-Stake consensus mechanism built on Tendermint (CometBFT). Validators propose and commit blocks, while token holders may delegate their CRO to validators to participate indirectly. Validators run a Byzantine Fault Tolerant protocol to finalize blocks, and full nodes store blockchain data and respond to client requests.
2. Transaction and Address Standards
Cronos POS accounts use Cosmos-style bech32 addresses (prefix “cro”), derived from public keys through SHA-256 and RIPEMD-160 hashing. Transactions consume gas (execution cost × gas price). All transaction fees are collected by validators; there is no EIP-1559 fee mechanism and no fee burning.
3. Blockchain Data Structure & Block Standards
The blockchain state is maintained through the Cosmos SDK, which provides modular state machines and secure module interactions. Each block contains validator signatures, transaction data, and state roots. Tendermint ensures instant finality once a block is committed.
Interoperability Protocols
Cronos POS Chain supports the Inter-Blockchain Communication (IBC) protocol, enabling cross-chain token transfers and interactions with other IBC-enabled Cosmos SDK chains.
4. Upgrade & Improvement Standards
Protocol upgrades are managed through validator and delegator governance. The underlying Tendermint/CometBFT consensus engine is backed by formal research, robust testing, and adoption across multiple blockchain networks since 2014.
The following applies to Ethereum:
The crypto-asset operates on a well-defined set of protocols and technical standards that are intended to ensure its security, decentralization, and functionality. It is running on the Ethereum blockchain. Below are some of the key ones:
1. Network Protocols
The crypto-asset follows a decentralized, peer-to-peer (P2P) protocol where nodes communicate over the crypto-asset's DevP2P protocol using RLPx for data encoding.
- Transactions and smart contract execution are secured through Proof-of-Stake (PoS) consensus.
- Validators propose and attest blocks in Ethereum’s Beacon Chain, finalized through Casper FFG.
- The Ethereum Virtual Machine (EVM) executes smart contracts using Turing-complete bytecode.
2. Transaction and Address Standards
crypto-asset Address Format: 20-byte addresses derived from Keccak-256 hashing of public keys.
Transaction Types:
- Legacy Transactions (pre-EIP-1559)
- Type 0 (Pre-EIP-1559 transactions)
- Type 1 (EIP-2930: Access list transactions)
- Type 2 (EIP-1559: Dynamic fee transactions with base fee burning)
The Pectra upgrade introduces EIP-7702, a transformative improvement to account abstraction. This allows externally owned accounts (EOAs) to temporarily act as smart contract wallets during a transaction. It provides significant flexibility, enabling functionality such as sponsored gas payments and batched operations without changing the underlying account model permanently.
3. Blockchain Data Structure & Block Standards
- the crypto-asset's blockchain consists of accounts, smart contracts, and storage states, maintained through Merkle Patricia Trees for efficient verification.
Each block contains:
- Block Header: Parent hash, state root, transactions root, receipts root, timestamp, gas limit, gas used, proposer signature.
- Transactions: Smart contract executions and token transfers.
- Block Size: No fixed limit; constrained by the gas limit per block (variable over time). In line with Ethereum’s scalability roadmap, Pectra includes EIP-7691, which increases the maximum number of "blobs" (data chunks introduced with EIP-4844) per block. This change significantly boosts the data availability layer used by rollups, supporting cheaper and more efficient Layer 2 scalability.
4. Upgrade & Improvement Standards
Ethereum follows the Ethereum Improvement Proposal (EIP) process for upgrades.
The following applies to Cronos EVM Chain:
Network Protocols
Cronos EVM Chain is a public, EVM-compatible Layer-1 built with the Cosmos SDK and Ethermint (porting go-ethereum/EVM execution to Cosmos). Consensus runs on CometBFT (Tendermint-class BFT). The validator set is permissioned under network governance (commonly described as a PoA-style variant of Proof-of-Stake): designated validators propose and commit blocks; token holders may participate indirectly via delegation where enabled by protocol/governance. Finality occurs on block commit subject to consensus parameters and validator participation. The protocol is open-source and maintained in public repositories.
Transaction and Address Standards
Accounts use 20-byte 0x-prefixed EVM addresses (Keccak-derived). Transactions consume gas (gas used × gas price) paid in CRO and follow standard Ethereum formats supported by Ethermint (e.g., legacy/type-0 and, if enabled by chain parameters, access-list/type-1 and dynamic-fee/type-2). Fee mechanics are chain-parameterized; no representation is made that Ethereum’s base-fee burning rules apply on Cronos EVM Chain.
Blockchain Data Structure & Block Standards
State is managed via Cosmos SDK modules with EVM execution by Ethermint. Each block contains proposer/validator commits, transactions, and state commitments. State storage and proofs follow the Ethereum account/state-trie model as implemented in Ethermint. Effective block capacity is bounded by gas limits and consensus parameters rather than a fixed byte size.
Interoperability Protocols
Cronos EVM Chain is designed for Ethereum-tooling compatibility (Solidity/Vyper, JSON-RPC) and for inter-chain connectivity within the Cosmos stack via IBC where channels are established. Third-party bridges may provide additional connectivity, each with its own trust and operational assumptions.
Upgrade & Improvement Standards
Upgrades and parameter changes are governed on-chain via Cosmos SDK governance (proposal, voting, coordinated releases). The client software and EVM compatibility evolve through scheduled open-source releases; operators are expected to maintain version parity with governance decisions.
The following applies to Cosmos (ATOM):
Network Protocols
The Cosmos ecosystem operates on a modular and decentralised architecture designed to ensure deterministic consensus and interoperability. Consensus and peer-to-peer networking are provided by CometBFT (formerly Tendermint Core), which implements a Byzantine Fault Tolerant Proof-of-Stake consensus mechanism under which validators propose and vote on blocks to achieve finality. Communication between the consensus layer and the application layer is handled through the Application BlockChain Interface (ABCI). Cross-chain interoperability is enabled through the Inter-Blockchain Communication (IBC) protocol, which allows independent blockchains to exchange messages and transfer crypto-assets using cryptographic proofs.
Transaction and Address Standards
Transactions are defined at the application level and validated through a standardised processing pipeline that includes signature verification, nonce checks, gas accounting, and fee deduction. Accounts store authentication information such as public keys, addresses, and sequence numbers, with addresses commonly represented using Bech32 encoding. Standard transaction types support asset transfers, staking, and governance actions, while IBC introduces packet-based transactions that enable verified cross-chain communication. Transaction fees are determined by chain-specific fee markets and are typically paid using the network’s native staking crypto-asset.
Blockchain Data Structure & Block Standards
The blockchain architecture separates consensus from state execution, with CometBFT responsible for block ordering and the application layer responsible for deterministic state transitions. Application state is maintained using Merkle-based data structures, including Simple Merkle Trees and IAVL+ trees, producing a cryptographic state root (AppHash) that is committed to each block header via the ABCI Commit process and signed by a supermajority of validators.
Upgrade & Improvement Standards
Protocol changes and network upgrades are coordinated through on-chain governance and scheduled upgrade mechanisms that activate protocol changes at predefined block heights. Validators are required to run updated software at the scheduled upgrade point, enabling coordinated upgrades without unsynchronised network halts.
The following applies to Solana:
The tokens were created with Solana’s Token Program, a smart contract that is part of the Solana Program Library (SPL). Such tokens are commonly referred to as SPL-token. The token itself is not an additional smart contract, but what is called a data account on Solana. As the name suggests data accounts store data on the blockchain. However, unlike smart contracts, they cannot be executed and cannot perform any operations. Since one cannot interact with data accounts directly, any interaction with an SPL-token is done via Solana’s Token Program. The source code of this smart contract can be found here https://github.com/solana-program/token.
The Token Program is developed in Rust, a memory-safe, high-performance programming language designed for secure and efficient development. On Solana, Rust is said to be the primary language used for developing on-chain programs (smart contracts), intended to ensure safety and reliability in decentralized applications (dApps).
Core functions of the Token Program:
initialize_mint() → Create a new type of token, called a mint
mint_to() → Mints new tokens of a specific type to a specified account
burn() → Burns tokens from a specified account, reducing total supply
transfer() → Transfers tokens between accounts
approve() → Approves a delegate to spend tokens on behalf of the owner
set_authority() → Updates authorities (mint, freeze, or transfer authority)
These functions ensure basic operations like transfers, and minting/burning can be performed within the Solana ecosystem.
In addition to the Token Program, another smart contract, the Metaplex Token Metadata Program is commonly used to store name, symbol, and URI information for better ecosystem compatibility. This additional metadata has no effect on the token’s functionality.
The following applies to Osmosis:
Osmosis is built on the Cosmos SDK and uses the Inter-Blockchain Communication (IBC) protocol for interoperability. These standards enable cross-chain interaction within the Cosmos ecosystem but remain dependent on the adoption and stability of the Cosmos framework. Reliance on a still-developing interoperability standard may introduce integration and security risks.
H.3 Technology used
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Cronos PoS Chain, Cronos EVM Chain, Ethereum, Cosmos, Solana and Osmosis. In general, when evaluating crypto assets, the total number of tokens issued across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Cronos PoS Chain:
1. Decentralized Ledger
The Cronos POS Chain is a public blockchain built on the Cosmos SDK and secured by Tendermint Core (CometBFT). It operates as a decentralized ledger where all CRO token transactions are recorded, providing transparency and immutability. Blocks achieve instant finality once committed under the Byzantine Fault Tolerant (BFT) protocol.
2. Private Key Management
Users manage their CRO holdings via wallets that support Cosmos-based chains (e.g., Crypto.com DeFi Wallet, Keplr, Ledger). Accounts and addresses on Cronos POS use the bech32 format (prefix "cro…"), ensuring compatibility with Cosmos ecosystem standards. Users are responsible for safeguarding private keys and recovery phrases.
3. Cryptographic Integrity
The network applies elliptic curve cryptography for account keys and validator operations. End-user transactions are signed with ECDSA over secp256k1, while validator consensus in Tendermint uses ed25519 keys. Address generation follows Cosmos SDK conventions, deriving a 20-byte identifier from the public key, encoded in bech32. This design aims to ensure integrity, resistance to tampering, and predictable verification.
4. Consensus and Security
Cronos POS relies on Tendermint’s BFT consensus, enabling high throughput and immediate block finality. Security assumptions tolerate up to one-third of validators being faulty or malicious without compromising consensus. Validators are permissioned and expected to comply with technical and security best practices (e.g., high-availability infrastructure, redundancy, and DDoS mitigation).
The following applies to Cronos EVM Chain:
Decentralized Ledger
Cronos EVM Chain is a public, EVM-compatible Layer-1 built with the Cosmos SDK and Ethermint, with consensus provided by CometBFT (Tendermint-class BFT). It records transactions in CRO on a transparent, append-only ledger. Blocks are finalized upon commit under the BFT protocol, subject to network parameters and validator participation.
Private Key Management
Users interact via EVM-compatible wallets (e.g., MetaMask, Ledger, Crypto.com DeFi Wallet in EVM mode). Accounts follow the Ethereum model with 0x-prefixed, 20-byte addresses derived from public keys (Keccak-256). Users are responsible for safeguarding private keys and recovery phrases; the network does not custody user keys.
Cryptographic Integrity
End-user transactions are signed using ECDSA over secp256k1 (Ethereum signature scheme). Validator consensus keys follow CometBFT conventions (ed25519 for commits). State and execution follow the EVM account/storage trie model as implemented by Ethermint, enabling standard Ethereum proofs and verification semantics.
Consensus and Security
Cronos EVM Chain runs a BFT consensus with a permissioned validator set (commonly described as a PoA-style variant of Proof-of-Stake). Security assumptions tolerate up to one-third faulty or malicious voting power without breaking safety. Validators are expected to operate with high-availability infrastructure, redundancy, and standard network protections (e.g., DDoS mitigation). Gas fees are paid in CRO; finality and throughput depend on consensus parameters, validator performance, and network conditions.
The following applies to Ethereum:
1. Decentralized Ledger: The Ethereum blockchain acts as a decentralized ledger for all token transactions, with the intention to preserving an unalterable record of token transfers and ownership to ensure both transparency and security.
2. Private Key Management: To safeguard their token holdings, users must securely store their wallet’s private keys and recovery phrases.
3. Cryptographic Integrity: Ethereum employs elliptic curve cryptography to validate and execute transactions securely, intended to ensure the integrity of all transfers. The Keccak-256 (SHA-3 variant) Hashing Algorithm is used for hashing and address generation. The crypto-asset uses ECDSA with secp256k1 curve for key generation and digital signatures. Next to that, BLS (Boneh-Lynn-Shacham) signatures are used for validator aggregation in PoS.
The following applies to Cosmos (ATOM):
Decentralised Ledger
The Cosmos Hub operates as a decentralised ledger that records all transactions in an append-only blockchain structure. Blocks are validated and finalised through a Byzantine Fault Tolerant consensus mechanism, with the intention of preserving an unalterable and transparent record of token transfers and balances.
Private Key Management
To safeguard their ATOM holdings, users must securely store their wallet private keys and recovery phrases. The Cosmos Hub protocol does not define standards for private key storage; key management is handled at the wallet or client level, including software and hardware wallets compatible with the Cosmos SDK.
Modular Design and Smart Contracting
The Cosmos Hub follows a modular architecture based on the Cosmos SDK. While the Hub itself focuses on native asset transfers and staking, smart-contract functionality may be provided through CosmWasm-based modules or connected application chains, where token logic and application-level rules are implemented outside the core ledger.
The following applies to Solana:
1. Solana-Compatible Wallets: The tokens are supported by all wallets compatible with Solana’s Token Program
2. Decentralized Ledger: The Solana blockchain acts as a decentralized ledger for all token transactions, with the intention to preserving an unalterable record of token transfers and ownership to ensure both transparency and security.
3. SPL Token Program: The SPL (Solana Program Library) Token Program is an inherent Solana smart contract built to create and manage new types of tokens (so called mints). This is significantly different from ERC-20 on Ethereum, because a single smart contract that is part of Solana’s core functionality and as such is open source, is responsible for all the tokens. This ensures a high uniformity across tokens at the cost of flexibility.
4. Blockchain Scalability: With its intended capacity for processing a lot of transactions per second and in most cases low fees, Solana is intended to enable efficient token transactions, maintaining high performance even during peak network usage.
Security Protocols for Asset Custody and Transactions:
1. Private Key Management: To safeguard their token holdings, users must securely store their wallet’s private keys and recovery phrases.
2. Cryptographic Integrity: Solana employs elliptic curve cryptography to validate and execute transactions securely, intended to ensure the integrity of all transfers.
The following applies to Osmosis:
The platform functions as an automated market maker (AMM) with customizable liquidity pools. Osmosis leverages the Tendermint Core consensus engine and Cosmos SDK modules, which provide modularity and extensibility. While this design supports innovation, it also increases the attack surface, and the AMM model itself remains sensitive to issues such as front-running, slippage, and smart contract vulnerabilities.
H.4 Consensus mechanism
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Cronos PoS Chain, Cronos EVM Chain, Ethereum, Cosmos, Solana and Osmosis. In general, when evaluating crypto assets, the total number of tokens issued across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Cronos POS:
Cronos POS uses a Tendermint/CometBFT Proof-of-Stake consensus in which a validator set proposes and finalizes blocks through a Byzantine Fault Tolerant protocol. CRO holders may delegate stake to validators; voting power is proportional to bonded CRO. For each height, a proposer (weighted by voting power) assembles a block; validators then run the standard Tendermint rounds (proposal → prevote → precommit). A block is committed—and thus final—once ≥2/3 of voting power precommits, so reorgs are not expected under normal conditions. Full nodes relay and serve state and do not participate in block production. Rewards (e.g., block provisions/inflation and transaction fees) are distributed to validators and their delegators according to protocol rules. Misbehavior (e.g., double-signing) or extended downtime can result in penalties, including slashing and jailing/tombstoning, as defined by on-chain parameters. This PoS design aims to provide immediate finality, energy efficiency, and predictable security without probabilistic confirmations.
The following applies to Cronos EVM Chain:
Cronos EVM secures its network with CometBFT (Tendermint-class) Byzantine Fault Tolerant consensus and a permissioned validator set commonly described as a PoA-style variant of Proof-of-Stake. Designated validators propose and commit blocks in BFT rounds; where enabled by governance, CRO holders may participate indirectly via delegation to validators and share in fee- or reward-based distributions as defined by on-chain parameters. Rewards, if configured, derive from protocol emissions and transaction fees paid in CRO; fees are gas-based (gas used × gas price) and their mechanics (e.g., dynamic-fee support, any base-fee logic) are chain-parameterized rather than guaranteed to mirror Ethereum’s EIP-1559/burning model. Misbehavior or insufficient liveness can be penalized per protocol rules (e.g., slashing for double-signing, jailing/tombstoning per consensus parameters). The incentive design targets rapid finality and predictable execution costs, with security aligned to validator performance, governance settings, and stake configuration.
The following applies to Ethereum:
The crypto-asset's Proof-of-Stake (PoS) consensus mechanism, introduced with The Merge in 2022, replaces mining with validator staking. Validators must stake at least 32 ETH every block a validator is randomly chosen to propose the next block. Once proposed the other validators verify the blocks integrity. The network operates on a slot and epoch system, where a new block is proposed every 12 seconds, and finalization occurs after two epochs (~12.8 minutes) using Casper-FFG. The Beacon Chain coordinates validators, while the fork-choice rule (LMD-GHOST) ensures the chain follows the heaviest accumulated validator votes. Validators earn rewards for proposing and verifying blocks, but face slashing for malicious behavior or inactivity. PoS aims to improve energy efficiency, security, and scalability, with future upgrades like Proto-Danksharding enhancing transaction efficiency.
The following applies to Cosmos (ATOM):
The Cosmos Hub operates a Proof-of-Stake (PoS) consensus mechanism based on CometBFT (formerly Tendermint consensus), a Byzantine Fault Tolerant (BFT) algorithm designed to provide fast finality and deterministic state replication.
Consensus participants are validators who bond the native crypto-asset ATOM as collateral and obtain voting power proportional to their bonded stake, including delegated ATOM from third parties. Validators participate in block production and consensus by proposing blocks and broadcasting cryptographic votes.
Consensus proceeds in rounds, each consisting of a block proposal, followed by two voting phases (pre-vote and pre-commit). A block is finalized and irreversibly committed once more than two-thirds of the total validator voting power pre-commits to the same block in the same round. This mechanism provides immediate finality and prevents probabilistic forks.
CometBFT ensures Byzantine Fault Tolerance, meaning the network remains safe and consistent as long as less than one-third of total voting power behaves maliciously or fails. The Cosmos Hub maintains a bounded validator set, initially capped at 100 validators and designed to increase gradually over time to balance decentralization and performance.
The following applies to Solana:
Solana uses a combination of Proof of History (PoH) and Proof of Stake (PoS). The core concepts of the mechanism are intended to work as follows:
Core Concepts
1. Proof of History (PoH):
Time-Stamped Transactions: PoH is a cryptographic technique that timestamps transactions, intended to creating a historical record that proves that an event has occurred at a specific moment in time.
Verifiable Delay Function: PoH uses a Verifiable Delay Function (VDF) to generate a unique hash that includes the transaction and the time it was processed. This sequence of hashes provides a verifiable order of events, intended to enabling the network to efficiently agree on the sequence of transactions.
2. Proof of Stake (PoS):
Validator Selection: Validators are chosen to produce new blocks based on the number of SOL tokens they have staked. The more tokens staked, the higher the chance of being
selected to validate transactions and produce new blocks.
Delegation: Token holders can delegate their SOL tokens to validators, earning rewards proportional to their stake while intended to enhancing the network's security.
Consensus Process
1. Transaction Validation:
Transactions are broadcasted to the network and collected by validators. Each transaction is validated to ensure it meets the network’s criteria, such as having correct signatures and sufficient funds.
2. PoH Sequence Generation:
A validator generates a sequence of hashes using PoH, each containing a timestamp and the previous hash. This process creates a historical record of transactions, establishing a
cryptographic clock for the network.
3. Block Production:
The network uses PoS to select a leader validator based on their stake. The leader is responsible for bundling the validated transactions into a block. The leader validator uses the PoH sequence to order transactions within the block, ensuring that all transactions are processed in the correct order.
4. Consensus and Finalization:
Other validators verify the block produced by the leader validator. They check the correctness of the PoH sequence and validate the transactions within the block. Once the block is verified, it is added to the blockchain. Validators sign off on the block, and it is considered finalized.
Security and Economic Incentives
1. Incentives for Validators:
Block Rewards: Validators earn rewards for producing and validating blocks. These rewards are distributed in SOL tokens and are proportional to the validator’s stake and performance.
Transaction Fees: Validators also earn transaction fees from the transactions included in the blocks they produce. These fees provide an additional incentive for validators to process transactions efficiently.
2. Security:
Staking: Validators must stake SOL tokens to participate in the consensus process. This staking acts as collateral, incentivizing validators to act honestly. If a validator behaves maliciously or fails to perform, they risk losing their staked tokens.
Delegated Staking: Token holders can delegate their SOL tokens to validators, intended to enhance network security and decentralization. Delegators share in the rewards and are incentivized to choose reliable validators.
3. Economic Penalties:
Slashing: Validators can be penalized for malicious behavior, such as double-signing or producing invalid blocks. This penalty, known as slashing, results in the loss of a portion of the staked tokens, discouraging dishonest actions.
The following applies to Osmosis:
Osmosis applies a Proof-of-Stake consensus through the Tendermint BFT engine. Validator nodes secure the network by staking OSMO tokens, and consensus is reached with fast finality. While PoS ensures efficiency, the validator set is comparatively small, creating concentration risks and dependence on correct governance behavior. The system may be exposed to validator collusion or governance capture.
H.5 Incentive mechanisms and applicable fees
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Cronos PoS Chain, Cronos EVM Chain, Ethereum, Cosmos, Solana and Osmosis. In general, when evaluating crypto assets, the total number of tokens issued across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Cronos PoS Chain:
Cronos POS secures its network with Tendermint/CometBFT Proof-of-Stake. Validators are elected by bonded stake (CRO) and propose/commit blocks via BFT rounds; CRO holders may delegate to validators and share in rewards. Rewards consist of protocol emissions (inflation, if enabled by parameters) and transaction fees paid in CRO; fees are gas-based (gas used × gas price) and are distributed to validators (and, via commission, to delegators). There is no EIP-1559 fee mechanism and no base-fee burning on Cronos POS. Misbehavior or insufficient liveness can trigger penalties, including slashing for double-signing and jailing/tombstoning per on-chain parameters. This incentive design targets immediate finality, predictable costs, and security aligned with validator performance and stake.
The following applies to Cronos EVM Chain:
Cronos EVM secures its network with CometBFT (Tendermint-class) Byzantine Fault Tolerant consensus and a permissioned validator set commonly described as a PoA-style variant of Proof-of-Stake. Designated validators propose and commit blocks in BFT rounds; where enabled by governance, CRO holders may participate indirectly via delegation to validators and share in fee- or reward-based distributions as defined by on-chain parameters. Rewards, if configured, derive from protocol emissions and transaction fees paid in CRO; fees are gas-based (gas used × gas price) and their mechanics (e.g., dynamic-fee support, any base-fee logic) are chain-parameterized rather than guaranteed to mirror Ethereum’s EIP-1559/burning model. Misbehavior or insufficient liveness can be penalized per protocol rules (e.g., slashing for double-signing, jailing/tombstoning per consensus parameters). The incentive design targets rapid finality and predictable execution costs, with security aligned to validator performance, governance settings, and stake configuration.
The following applies to Ethereum:
The crypto-asset's PoS system secures transactions through validator incentives and economic penalties. Validators stake at least 32 ETH and earn rewards for proposing blocks, attesting to valid ones, and participating in sync committees. Rewards are paid in newly issued ETH and transaction fees. Under EIP-1559, transaction fees consist of a base fee, which is burned to reduce supply, and an optional priority fee (tip) paid to validators. Validators face slashing if they act maliciously and incur penalties for inactivity. This system aims to increase security by aligning incentives while making the crypto-asset's fee structure more predictable and deflationary during high network activity.
The following applies to Cosmos (ATOM):
The Cosmos Hub secures its Proof-of-Stake consensus mechanism through an integrated system of economic incentives and penalties. This framework is designed to encourage honest participation by validators and delegators, deter malicious or negligent behavior, and ensure the long-term security and sustainability of the network.
Incentive Mechanisms (Rewards).
Validators and delegators are rewarded for participating in block production and consensus through a combination of inflationary issuance and transaction fees. The native staking crypto-asset ATOM is issued as an inflationary reward and distributed to bonded validators and delegators in proportion to their bonded stake. In addition, users pay transaction fees, which are collected by validators and periodically redistributed to bonded participants, subject to validator-defined commission rates.
Transaction Fees.
The Cosmos Hub applies a gas-based fee model to limit network spam and compensate network operators. Fees are calculated based on transaction complexity and size using a gas limit and a gas price, and are deducted from the transaction signer prior to execution. Validators may set their own minimum gas prices and may accept multiple token denominations as fees, selecting which transactions to include within block gas limits.
Fee Distribution and Reserve Pool.
Collected transaction fees are redistributed at regular intervals to bonded validators and delegators in proportion to their bonded ATOM. A predefined portion of these fees (by default 2%) is allocated to a reserve pool, which is intended to support network security and sustainability and may be distributed through on-chain governance decisions.
Penalties and Slashing.
Bonded ATOM functions as economic collateral and is subject to slashing in the event of protocol violations. Validators that commit safety faults, such as double-signing conflicting blocks at the same height, are subject to significant slashing and are typically permanently removed from the validator set.
The following applies to Solana:
1. Validators:
Staking Rewards: Validators are chosen based on the number of SOL tokens they have staked. They earn rewards for producing and validating blocks, which are distributed in SOL. The more tokens staked, the higher the chances of being selected to validate transactions and produce new blocks.
Transaction Fees: Validators earn a portion of the transaction fees paid by users for the transactions they include in the blocks. This is intended to provide an additional financial incentive for validators to process transactions efficiently and maintain the network's integrity.
2. Delegators:
Delegated Staking: Token holders who do not wish to run a validator node can delegate their SOL tokens to a validator. In return, delegators share the rewards earned by the validators. This is intended to encourage widespread participation in securing the network and ensures decentralization.
3. Economic Security:
Slashing: Validators can be penalized for malicious behavior, such as producing invalid blocks or being frequently offline. This penalty, known as slashing, involves the loss of a portion of their staked tokens. Slashing is intended to deter dishonest actions and ensures that validators act in the best interest of the network.
Opportunity Cost: By staking SOL tokens, validators and delegators lock up their tokens, which could otherwise be used or sold. This opportunity cost is intended to incentivize participants to act honestly to earn rewards and avoid penalties.
Fees Applicable on the Solana Blockchain
1. Transaction Fees:
Solana is designed to handle a high throughput of transactions, which is intended to keep the fees low and predictable.
Fee Structure: Fees are paid in SOL and are used to compensate validators for the resources they expend to process transactions. This includes computational power and network bandwidth.
2. Rent Fees:
State Storage: Solana charges so called ""rent fees"" for storing data on the blockchain. These fees are designed to discourage inefficient use of state storage and encourage developers to clean up unused state. Rent fees are intended to help maintain the efficiency and performance of the network.
3. Smart Contract Fees:
Execution Costs: Similar to transaction fees, fees for deploying and interacting with smart contracts on Solana are based on the computational resources required. This is intended to ensure that users are charged proportionally for the resources they consume.
The following applies to Osmosis:
The network incentivizes liquidity providers and validators through block rewards and transaction fees paid in OSMO. Liquidity mining programs and governance-driven reward distribution may influence participation but can also result in centralization of liquidity or speculative behavior. Fees are variable, and long-term sustainability depends on balancing incentives with network security and cost efficiency.
H.6 Use of distributed ledger technology
H.7 DLT functionality description
Not applicable.
H.8 Audit
H.9 Audit outcome
Not applicable, as no comprehensive audit of the technology used has been conducted or can be confirmed.
Part I – Information on risks
I.1 Offer-related risks
1. Regulatory and Compliance
Regulatory frameworks applicable to crypto-asset services in the European Union and in third countries are evolving. Supervisory authorities may introduce, interpret, or enforce rules that affect (i) the eligibility of this crypto-asset for admission to trading, (ii) the conditions under which a crypto-asset service provider may offer trading, custody, or transfer services for it, or (iii) the persons or jurisdictions to which such services may be provided. As a result, the crypto-asset service provider admitting this crypto-asset to trading may be required to suspend, restrict, or terminate trading or withdrawals for regulatory reasons, even if the crypto-asset itself continues to function on its underlying network.
2. Trading venue and connection risk
Trading in the crypto-asset depends on the uninterrupted operation of the trading platform admitting it and, where applicable, on its technical connections to external liquidity sources or venues. Interruptions such as system downtime, maintenance, faulty integrations, API changes, or failures at an external venue can temporarily prevent order placement, execution, deposits, or withdrawals, even when the underlying blockchain is functioning. In addition, trading platforms in emerging markets may operate under differing governance, compliance, and oversight standards, which can increase the risk of operational failures or disorderly market conditions.
3. Market formation and liquidity conditions
The price and tradability of the crypto-asset depend on actual trading activity on the venues to which the service provider is connected, whether centralized exchanges (CEXs) or decentralized exchanges (DEXs). Trading volumes may at times be low, order books thin, or liquidity concentrated on a single venue. In such conditions, buy or sell orders may not be executed in full or may be executed only at a less favorable price, resulting in slippage.
Volatility: The market price of the crypto-asset may fluctuate significantly over short periods, including for reasons that are not linked to changes in the underlying project or protocol. Periods of limited liquidity, shifts in overall market sentiment, or trading on only a small number of CEXs or DEXs can amplify these movements and lead to higher slippage when orders are executed. As a result, investors may be unable to sell the crypto-asset at or close to a previously observed price, even though no negative project-specific event has occurred.
4. Counterparty and service-provider dependence
The admission of the crypto-asset to trading may rely on several external parties, such as connected centralized or decentralized trading venues, liquidity providers, brokers, custodians, or technical integrators. If any of these counterparties fail to perform, suspend their services, or apply internal restrictions, the trading, deposit, or withdrawal of the crypto-asset on the admitting service provider can be interrupted or halted.
Quality of counterparties: Trading venues and service providers in certain jurisdictions may operate under regulatory or supervisory standards that are lower or differently enforced than those applicable in the European Union. In such environments, deficiencies in governance, risk management, or compliance may remain undetected, which increases the probability of abrupt service interruptions, investigations, or forced wind-downs.
Delisting and service suspension: The crypto-asset’s availability may depend on the internal listing decisions of these counterparties. A delisting or suspension on a key connected venue can materially reduce liquidity or make trading temporarily impossible on the admitting service provider, even if the underlying crypto-asset continues to function.
Insolvency of counterparties: If a counterparty involved in holding, routing, or settling the crypto-asset becomes insolvent, enters restructuring, or is otherwise subject to resolution-type measures, assets held or processed by that counterparty may be frozen, become temporarily unavailable, or be recoverable only in part or not at all, which can result in losses for clients whose positions were maintained through that counterparty. This risk applies in particular where client assets are held on an omnibus basis or where segregation is not fully recognized in the counterparty’s jurisdiction.
5. Operational and information risks
Due to the irrevocability of blockchain transactions, incorrect approvals or the use of wrong networks or addresses will typically make the transferred funds irrecoverable. Because trading may also rely on technical connections to other venues or service providers, downtime or faulty code in these connections can temporarily block trading, deposits, or withdrawals even when the underlying blockchain is functioning. In addition, different groups of market participants may have unequal access to technical, governance, or project-related information, which can lead to information asymmetry and place less informed investors at a disadvantage when making trading decisions.
6. Market access and liquidity concentration risk
If the crypto-asset is only available on a limited number of trading platforms or through a single market-making entity, this may result in reduced liquidity, greater price volatility, or periods of inaccessibility for retail holders.
I.2 Issuer-related risks
1. Insolvency of the issuer
As with any commercial entity, the issuer may face insolvency risks. These may result from insufficient funding, low market interest, mismanagement, or external shocks (e.g. pandemics, wars). In such a case, ongoing development, support, and governance of the project may cease, potentially affecting the viability and tradability of the crypto-asset.
2. Legal and regulatory risks
The issuer operates in a dynamic and evolving regulatory environment. Failure to comply with applicable laws or regulations in relevant jurisdictions may result in enforcement actions, penalties, or restrictions on the project’s operations. These may negatively impact the crypto-asset’s availability, market acceptance, or legal status.
3. Operational risks
The issuer may fail to implement adequate internal controls, risk management, or governance processes. This can result in operational disruptions, financial losses, delays in updating the white paper, or reputational damage.
4. Governance and decision-making
The issuer’s management body is responsible for key strategic, operational, and disclosure decisions. Ineffective governance, delays in decision-making, or lack of resources may compromise the stability of the project and its compliance with MiCA requirements. High concentration of decision-making authority or changes in ownership/control can amplify these risks.
5. Reputational risks
The issuer’s reputation may be harmed by internal failures, external accusations, or association with illicit activity. Negative publicity can reduce trust in the issuer and impact the perceived legitimacy or value of the crypto-asset.
6. Counterparty dependence
The issuer may depend on third-party providers for certain core functions, such as technology development, marketing, legal advice, or infrastructure. If these partners discontinue their services, change ownership, or underperform, the issuer’s ability to operate the project or maintain investor communication may be impaired. This could disrupt project continuity or undermine market confidence, ultimately affecting the crypto-asset’s value.
I.3 Crypto-assets-related risks
1. Valuation risk
The crypto-asset does not represent a claim, nor is it backed by physical assets or legal entitlements. Its market value is driven solely by supply and demand dynamics and may fluctuate significantly. In the absence of fundamental value anchors, such assets can lose their entire market value within a very short time. Historical market behaviour has shown that some types of crypto-assets – such as meme coins or purely speculative tokens – have become worthless. Investors should be aware that this crypto-asset may lose all of its value.
2. Market volatility risk
Crypto-asset prices can fluctuate sharply due to changes in market sentiment, macroeconomic conditions, regulatory developments, or technology trends. Such volatility may result in rapid and significant losses. Holders should be prepared for the possibility of losing the full amount invested.
3. Liquidity and price-determination risk
Low trading volumes, fragmented trading across venues, or the absence of active market makers can restrict the ability to buy or sell the crypto-asset. In such situations, it is not guaranteed that an observable market price will exist at all times. Spreads may widen materially, and orders may only be executable under unfavourable conditions, which can make liquidation costly or temporarily impossible.
4. Asset security risk
Loss or theft of private keys, unauthorised access to wallets, or failures of custodial or exchange service providers can result in the irreversible loss of assets. Because blockchain transactions are final, recovery of funds after a compromise is generally impossible.
5. Fraud and scam risk
The pseudonymous and irreversible nature of blockchain transactions can attract fraudulent schemes. Typical forms include fake or unauthorised crypto-assets imitating established ones, phishing attempts, deceptive airdrops, or social-engineering attacks. Investors should exercise caution and verify the authenticity of counterparties and information sources.
6. Legal and regulatory reclassification risk
Legislative or regulatory changes in the European Union or in the Member State where the crypto-asset is admitted to trading may alter its legal classification, permitted uses, or tradability. In third countries, the crypto-asset may be treated as a financial instrument or security, which can restrict its offering, trading, or custody.
7. Absence of investor protection
The crypto-asset is not covered by investor-compensation or deposit-guarantee schemes. In the event of loss, fraud, or insolvency of a service provider, holders may have no access to recourse mechanisms typically available in regulated financial markets.
8. Counterparty risk
Reliance on third-party exchanges, custodians, or intermediaries exposes holders to operational failures, insolvency, or fraud of these parties. Investors should conduct due diligence on service providers, as their failure may lead to the partial or total loss of held assets.
9. Reputational risk
Negative publicity related to security incidents, misuse of blockchain technology, or associations with illicit activity can damage public confidence and reduce the crypto-asset’s market value.
10. Community and sentiment risk
Because the crypto-asset’s perceived relevance and expected future use depend largely on community engagement and the prevailing sentiment, a loss of public interest, negative coverage or reduced activity of key contributors can materially reduce market demand.
11. Macroeconomic and interest-rate risk
Fluctuations in interest rates, exchange rates, general market conditions, or overall market volatility can influence investor sentiment towards digital assets and affect the crypto-asset’s market value.
12. Taxation risk
Tax treatment varies across jurisdictions. Holders are individually responsible for complying with all applicable tax laws, including the reporting and payment of taxes arising from the acquisition, holding, or disposal of the crypto-asset.
13. Anti-money-laundering and counter-terrorist-financing risk
Wallet addresses or transactions connected to the crypto-asset may be linked to sanctioned or illicit activity. Regulatory responses to such findings may include transfer restrictions, report obligations, or the freezing of assets on certain venues.
14. Market-abuse risk
Due to limited oversight and transparency, crypto-assets may be vulnerable to market-abuse practices such as spoofing, pump-and-dump schemes, or insider trading. Such activities can distort prices and expose holders to sudden losses.
15. Legal ownership and jurisdictional risk
Depending on the applicable law, holders of the crypto-asset may not have enforceable ownership rights or effective legal remedies in cases of disputes, fraud, or service failure. In certain jurisdictions, access to exchanges or interfaces may be restricted by regulatory measures, even if on-chain transfer remains technically possible.
16. Concentration risk
A large proportion of the total supply may be held by a small number of holders. This can enable market manipulation, governance dominance, or sudden large-scale liquidations that adversely affect market stability, price levels, and investor confidence.
I.4 Project implementation-related risks
As this white paper relates to the admission to trading of the crypto-asset, the following risk description reflects general implementation risks on the crypto-asset service provider's side typically associated with crypto-asset projects. The party admitting the asset to trading is not involved in the project’s implementation and does not assume responsibility for its governance, funding, or execution.
Delays, failures, or changes in the implementation of the project as outlined in its public roadmap or technical documentation may negatively impact the perceived credibility or usability of the crypto-asset. This includes risks related to project governance, resource allocation, technical delivery, and team continuity.
Key-person risk: The project may rely on a limited number of individuals for development, maintenance, or strategic direction. The departure, incapacity, or misalignment of these individuals may delay or derail the implementation.
Timeline and milestone risk: Project milestones may not be met as announced. Delays in feature releases, protocol upgrades, or external integrations can undermine market confidence and affect the adoption, use, or value of the crypto-asset.
Delivery risk: Even if implemented on time, certain functionalities or integrations may not perform as intended or may be scaled back during execution, limiting the token’s practical utility.
I.5 Technology-related risks
As this white paper relates to the admission to trading of the crypto-asset, the following risks concern the underlying distributed ledger technology (DLT), its supporting infrastructure, and related technical dependencies. Failures or vulnerabilities in these systems may affect the availability, integrity, or transferability of the crypto-asset.
1. Blockchain dependency risk
The functionality of the crypto-asset depends on the continuous and stable operation of the blockchain(s) on which it is issued. Network congestion, outages, or protocol errors may temporarily or permanently disrupt on-chain transactions. Extended downtime or degradation in network performance can affect trading, settlement, or usability of the crypto-asset.
2. Smart contract vulnerability risk
The smart contract that defines the crypto-asset’s parameters or governs its transfers may contain coding errors or security vulnerabilities. Exploitation of such weaknesses can result in unintended token minting, permanent loss of funds, or disruption of token functionality. Even after external audits, undetected vulnerabilities may persist due to the immutable nature of deployed code.
3. Wallet and key-management risk
The custody of crypto-assets relies on secure private key management. Loss, theft, or compromise of private keys results in irreversible loss of access. Custodians, trading venues, or wallet providers may be targeted by cyberattacks. Compatibility issues between wallet software and changes to the blockchain protocol (e.g. network upgrades) can further limit user access or the ability to transfer the crypto-asset.
Outdated or vulnerable wallet software:
Users relying on outdated, unaudited, or unsupported wallet software may face compatibility issues, security vulnerabilities, or failures when interacting with the blockchain. Failure to update wallet software in line with protocol developments can result in transaction errors, loss of access, or exposure to known exploits.
4. Network security risks
Attack Risks: Blockchains may be subject to denial-of-service (DoS) attacks, 51% attacks, or other exploits targeting the consensus mechanism. These can delay transactions, compromise finality, or disrupt the accurate recording of transfers.
Centralization Concerns: Despite claims of decentralisation, a relatively small number of validators or a high concentration of stake may increase the risk of collusion, censorship, or coordinated network downtime, which can affect the resilience and operational reliability of the crypto-asset.
5. Bridge and interoperability risk
Where tokens can be bridged or wrapped across multiple blockchains, vulnerabilities in bridge protocols, validator sets, or locking mechanisms may result in loss, duplication, or misrepresentation of assets. Exploits or technical failures in these systems can instantly impact circulating supply, ownership claims, or token fungibility across chains.
6. Forking and protocol-upgrade risk
Network upgrades or disagreements among node operators or validators can result in blockchain “forks”, where the blockchain splits into two or more incompatible versions that continue separately from a shared past. This may lead to duplicate token representations or incompatibilities between exchanges and wallets. Until consensus stabilises, trading or transfers may be disrupted or misaligned. Such situations may be difficult for retail holders to navigate, particularly when trading platforms or wallets display inconsistent token information.
7. Economic-layer and abstraction risk
Mechanisms such as gas relayers, wrapped tokens, or synthetic representations may alter the transaction economics of the underlying token. Changes in transaction costs, token demand, or utility may reduce its usage and weaken both its economic function and perceived value within its ecosystem.
8. Spam and network-efficiency risk
High volumes of low-value (“dust”) or automated transactions may congest the network, slow validation times, inflate ledger size, and raise transaction costs. This can impair performance, reduce throughput, and expose address patterns to analysis, thereby reducing network efficiency and privacy.
9. Front-end and access-interface risk
If users rely on centralised web interfaces or hosted wallets to interact with the blockchain, service outages, malicious compromises, or domain expiries affecting these interfaces may block access to the crypto-asset, even while the blockchain itself remains fully functional. Dependence on single web portals introduces a critical point of failure outside the DLT layer.
10. Decentralisation claim risk
While the technical infrastructure may appear distributed, the actual governance or economic control of the project may lie with a small set of actors. This disconnect between marketing claims and structural reality can lead to regulatory scrutiny, reputational damage, or legal uncertainty – especially if the project is presented as ‘community-governed’ without substantiation.
I.6 Mitigation measures
None.
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
S.1 Name
S.2 Relevant legal entity identifier
S.3 Name of the cryptoasset
S.4 Consensus Mechanism
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Cronos PoS Chain, Cronos EVM Chain, Ethereum, Cosmos and Solana. In general, when evaluating crypto assets, the total number of tokens issued across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Cronos POS:
Cronos POS uses a Tendermint/CometBFT Proof-of-Stake consensus in which a validator set proposes and finalizes blocks through a Byzantine Fault Tolerant protocol. CRO holders may delegate stake to validators; voting power is proportional to bonded CRO. For each height, a proposer (weighted by voting power) assembles a block; validators then run the standard Tendermint rounds (proposal → prevote → precommit). A block is committed—and thus final—once ≥2/3 of voting power precommits, so reorgs are not expected under normal conditions. Full nodes relay and serve state and do not participate in block production. Rewards (e.g., block provisions/inflation and transaction fees) are distributed to validators and their delegators according to protocol rules. Misbehavior (e.g., double-signing) or extended downtime can result in penalties, including slashing and jailing/tombstoning, as defined by on-chain parameters. This PoS design aims to provide immediate finality, energy efficiency, and predictable security without probabilistic confirmations.
The following applies to Cronos EVM Chain:
Cronos EVM secures its network with CometBFT (Tendermint-class) Byzantine Fault Tolerant consensus and a permissioned validator set commonly described as a PoA-style variant of Proof-of-Stake. Designated validators propose and commit blocks in BFT rounds; where enabled by governance, CRO holders may participate indirectly via delegation to validators and share in fee- or reward-based distributions as defined by on-chain parameters. Rewards, if configured, derive from protocol emissions and transaction fees paid in CRO; fees are gas-based (gas used × gas price) and their mechanics (e.g., dynamic-fee support, any base-fee logic) are chain-parameterized rather than guaranteed to mirror Ethereum’s EIP-1559/burning model. Misbehavior or insufficient liveness can be penalized per protocol rules (e.g., slashing for double-signing, jailing/tombstoning per consensus parameters). The incentive design targets rapid finality and predictable execution costs, with security aligned to validator performance, governance settings, and stake configuration.
The following applies to Ethereum:
The crypto-asset's Proof-of-Stake (PoS) consensus mechanism, introduced with The Merge in 2022, replaces mining with validator staking. Validators must stake at least 32 ETH every block a validator is randomly chosen to propose the next block. Once proposed the other validators verify the blocks integrity. The network operates on a slot and epoch system, where a new block is proposed every 12 seconds, and finalization occurs after two epochs (~12.8 minutes) using Casper-FFG. The Beacon Chain coordinates validators, while the fork-choice rule (LMD-GHOST) ensures the chain follows the heaviest accumulated validator votes. Validators earn rewards for proposing and verifying blocks, but face slashing for malicious behavior or inactivity. PoS aims to improve energy efficiency, security, and scalability, with future upgrades like Proto-Danksharding enhancing transaction efficiency.
The following applies to Cosmos (ATOM):
The Cosmos Hub operates a Proof-of-Stake (PoS) consensus mechanism based on CometBFT (formerly Tendermint consensus), a Byzantine Fault Tolerant (BFT) algorithm designed to provide fast finality and deterministic state replication.
Consensus participants are validators who bond the native crypto-asset ATOM as collateral and obtain voting power proportional to their bonded stake, including delegated ATOM from third parties. Validators participate in block production and consensus by proposing blocks and broadcasting cryptographic votes.
Consensus proceeds in rounds, each consisting of a block proposal, followed by two voting phases (pre-vote and pre-commit). A block is finalized and irreversibly committed once more than two-thirds of the total validator voting power pre-commits to the same block in the same round. This mechanism provides immediate finality and prevents probabilistic forks.
CometBFT ensures Byzantine Fault Tolerance, meaning the network remains safe and consistent as long as less than one-third of total voting power behaves maliciously or fails. The Cosmos Hub maintains a bounded validator set, initially capped at 100 validators and designed to increase gradually over time to balance decentralization and performance._x000B_
The following applies to Solana:_x000B_Solana uses a combination of Proof of History (PoH) and Proof of Stake (PoS). The core concepts of the mechanism are intended to work as follows:
Core Concepts
1. Proof of History (PoH):
Time-Stamped Transactions: PoH is a cryptographic technique that timestamps transactions, intended to creating a historical record that proves that an event has occurred at a specific moment in time.
Verifiable Delay Function: PoH uses a Verifiable Delay Function (VDF) to generate a unique hash that includes the transaction and the time it was processed. This sequence of hashes provides a verifiable order of events, intended to enabling the network to efficiently agree on the sequence of transactions.
2. Proof of Stake (PoS):
Validator Selection: Validators are chosen to produce new blocks based on the number of SOL tokens they have staked. The more tokens staked, the higher the chance of being
selected to validate transactions and produce new blocks.
Delegation: Token holders can delegate their SOL tokens to validators, earning rewards proportional to their stake while intended to enhancing the network's security.
Consensus Process
1. Transaction Validation:
Transactions are broadcasted to the network and collected by validators. Each transaction is validated to ensure it meets the network’s criteria, such as having correct signatures and sufficient funds.
2. PoH Sequence Generation:
A validator generates a sequence of hashes using PoH, each containing a timestamp and the previous hash. This process creates a historical record of transactions, establishing a
cryptographic clock for the network.
3. Block Production:
The network uses PoS to select a leader validator based on their stake. The leader is responsible for bundling the validated transactions into a block. The leader validator uses the PoH sequence to order transactions within the block, ensuring that all transactions are processed in the correct order.
4. Consensus and Finalization:
Other validators verify the block produced by the leader validator. They check the correctness of the PoH sequence and validate the transactions within the block. Once the block is verified, it is added to the blockchain. Validators sign off on the block, and it is considered finalized.
Security and Economic Incentives
1. Incentives for Validators:
Block Rewards: Validators earn rewards for producing and validating blocks. These rewards are distributed in SOL tokens and are proportional to the validator’s stake and performance.
Transaction Fees: Validators also earn transaction fees from the transactions included in the blocks they produce. These fees provide an additional incentive for validators to process transactions efficiently.
2. Security:
Staking: Validators must stake SOL tokens to participate in the consensus process. This staking acts as collateral, incentivizing validators to act honestly. If a validator behaves maliciously or fails to perform, they risk losing their staked tokens.
Delegated Staking: Token holders can delegate their SOL tokens to validators, intended to enhance network security and decentralization. Delegators share in the rewards and are incentivized to choose reliable validators.
3. Economic Penalties:
Slashing: Validators can be penalized for malicious behavior, such as double-signing or producing invalid blocks. This penalty, known as slashing, results in the loss of a portion of the staked tokens, discouraging dishonest actions.
S.5 Incentive Mechanisms and Applicable Fees
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Cronos PoS Chain, Cronos EVM Chain, Ethereum, Cosmos and Solana. In general, when evaluating crypto assets, the total number of tokens issued across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Cronos PoS Chain:
Cronos POS secures its network with Tendermint/CometBFT Proof-of-Stake. Validators are elected by bonded stake (CRO) and propose/commit blocks via BFT rounds; CRO holders may delegate to validators and share in rewards. Rewards consist of protocol emissions (inflation, if enabled by parameters) and transaction fees paid in CRO; fees are gas-based (gas used × gas price) and are distributed to validators (and, via commission, to delegators). There is no EIP-1559 fee mechanism and no base-fee burning on Cronos POS. Misbehavior or insufficient liveness can trigger penalties, including slashing for double-signing and jailing/tombstoning per on-chain parameters. This incentive design targets immediate finality, predictable costs, and security aligned with validator performance and stake.
The following applies to Cronos EVM Chain:
Cronos EVM secures its network with CometBFT (Tendermint-class) Byzantine Fault Tolerant consensus and a permissioned validator set commonly described as a PoA-style variant of Proof-of-Stake. Designated validators propose and commit blocks in BFT rounds; where enabled by governance, CRO holders may participate indirectly via delegation to validators and share in fee- or reward-based distributions as defined by on-chain parameters. Rewards, if configured, derive from protocol emissions and transaction fees paid in CRO; fees are gas-based (gas used × gas price) and their mechanics (e.g., dynamic-fee support, any base-fee logic) are chain-parameterized rather than guaranteed to mirror Ethereum’s EIP-1559/burning model. Misbehavior or insufficient liveness can be penalized per protocol rules (e.g., slashing for double-signing, jailing/tombstoning per consensus parameters). The incentive design targets rapid finality and predictable execution costs, with security aligned to validator performance, governance settings, and stake configuration.
The following applies to Ethereum:
The crypto-asset's PoS system secures transactions through validator incentives and economic penalties. Validators stake at least 32 ETH and earn rewards for proposing blocks, attesting to valid ones, and participating in sync committees. Rewards are paid in newly issued ETH and transaction fees. Under EIP-1559, transaction fees consist of a base fee, which is burned to reduce supply, and an optional priority fee (tip) paid to validators. Validators face slashing if they act maliciously and incur penalties for inactivity. This system aims to increase security by aligning incentives while making the crypto-asset's fee structure more predictable and deflationary during high network activity.
The following applies to Cosmos (ATOM):
The Cosmos Hub secures its Proof-of-Stake consensus mechanism through an integrated system of economic incentives and penalties. This framework is designed to encourage honest participation by validators and delegators, deter malicious or negligent behavior, and ensure the long-term security and sustainability of the network.
Incentive Mechanisms (Rewards).
Validators and delegators are rewarded for participating in block production and consensus through a combination of inflationary issuance and transaction fees. The native staking crypto-asset ATOM is issued as an inflationary reward and distributed to bonded validators and delegators in proportion to their bonded stake. In addition, users pay transaction fees, which are collected by validators and periodically redistributed to bonded participants, subject to validator-defined commission rates.
Transaction Fees.
The Cosmos Hub applies a gas-based fee model to limit network spam and compensate network operators. Fees are calculated based on transaction complexity and size using a gas limit and a gas price, and are deducted from the transaction signer prior to execution. Validators may set their own minimum gas prices and may accept multiple token denominations as fees, selecting which transactions to include within block gas limits.
Fee Distribution and Reserve Pool.
Collected transaction fees are redistributed at regular intervals to bonded validators and delegators in proportion to their bonded ATOM. A predefined portion of these fees (by default 2%) is allocated to a reserve pool, which is intended to support network security and sustainability and may be distributed through on-chain governance decisions.
Penalties and Slashing.
Bonded ATOM functions as economic collateral and is subject to slashing in the event of protocol violations. Validators that commit safety faults, such as double-signing conflicting blocks at the same height, are subject to significant slashing and are typically permanently removed from the validator set.
The following applies to Solana:
1. Validators:
Staking Rewards: Validators are chosen based on the number of SOL tokens they have staked. They earn rewards for producing and validating blocks, which are distributed in SOL. The more tokens staked, the higher the chances of being selected to validate transactions and produce new blocks.
Transaction Fees: Validators earn a portion of the transaction fees paid by users for the transactions they include in the blocks. This is intended to provide an additional financial incentive for validators to process transactions efficiently and maintain the network's integrity.
2. Delegators:
Delegated Staking: Token holders who do not wish to run a validator node can delegate their SOL tokens to a validator. In return, delegators share the rewards earned by the validators. This is intended to encourage widespread participation in securing the network and ensures decentralization.
3. Economic Security:
Slashing: Validators can be penalized for malicious behavior, such as producing invalid blocks or being frequently offline. This penalty, known as slashing, involves the loss of a portion of their staked tokens. Slashing is intended to deter dishonest actions and ensures that validators act in the best interest of the network.
Opportunity Cost: By staking SOL tokens, validators and delegators lock up their tokens, which could otherwise be used or sold. This opportunity cost is intended to incentivize participants to act honestly to earn rewards and avoid penalties.
Fees Applicable on the Solana Blockchain
1. Transaction Fees:
Solana is designed to handle a high throughput of transactions, which is intended to keep the fees low and predictable.
Fee Structure: Fees are paid in SOL and are used to compensate validators for the resources they expend to process transactions. This includes computational power and network bandwidth.
2. Rent Fees:
State Storage: Solana charges so called "rent fees" for storing data on the blockchain. These fees are designed to discourage inefficient use of state storage and encourage developers to clean up unused state. Rent fees are intended to help maintain the efficiency and performance of the network.
3. Smart Contract Fees:
Execution Costs: Similar to transaction fees, fees for deploying and interacting with smart contracts on Solana are based on the computational resources required. This is intended to ensure that users are charged proportionally for the resources they consume.
S.6 Beginning of the period to which the disclosure relates
S.7 End of the period to which the disclosure relates
S.8 Energy consumption
S.9 Energy consumption sources and methodologies
The energy consumption associated with this crypto-asset is aggregated of multiple contributing components, primarily the underlying blockchain network and the execution of token-specific operations. To determine the energy consumption of a token, the energy consumption of the underlying blockchain network Cronos PoS Chain, Cronos EVM Chain, Ethereum, Cosmos, Osmosis and Solana is calculated first. A proportionate share of that energy use is then attributed to the token based on its activity level within the network (e.g. transaction volume, contract execution).
The Functionally Fungible Group Digital Token Identifier (FFG DTI) is used to determine all technically equivalent implementations of the crypto-asset in scope.
Estimates regarding hardware types, node distribution, and the number of network participants are based on informed assumptions, supported by best-effort verification against available empirical data. Unless robust evidence suggests otherwise, participants are assumed to act in an economically rational manner. In line with the precautionary principle, conservative estimates are applied where uncertainty exists – that is, estimates tend towards the higher end of potential environmental impact.
S.10 Renewable energy consumption
S.11 Energy intensity
S.12 Scope 1 DLT GHG emissions – Controlled
S.13 Scope 2 DLT GHG emissions – Purchased
S.14 GHG intensity
S.15 Key energy sources and methodologies
To determine the proportion of renewable energy usage, the locations of the nodes are to be determined using public information sites, open-source crawlers and crawlers developed in-house. If no information is available on the geographic distribution of the nodes, reference networks are used which are comparable in terms of their incentivization structure and consensus mechanism. This geo-information is merged with public information from Our World in Data, see citation. The intensity is calculated as the marginal energy cost wrt. one more transaction. Ember (2025); Energy Institute - Statistical Review of World Energy (2024) - with major processing by Our World in Data. “Share of electricity generated by renewables - Ember and Energy Institute” [dataset]. Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy” [original data]. Retrieved from https://ourworldindata.org/grapher/share-electricity-renewables.
S.16 Key GHG sources and methodologies
To determine the GHG Emissions, the locations of the nodes are to be determined using public information sites, open-source crawlers and crawlers developed in-house. If no information is available on the geographic distribution of the nodes, reference networks are used which are comparable in terms of their incentivization structure and consensus mechanism. This geo-information is merged with public information from Our World in Data, see citation. The intensity is calculated as the marginal emission wrt. one more transaction. Ember (2025); Energy Institute - Statistical Review of World Energy (2024) - with major processing by Our World in Data. “Carbon intensity of electricity generation - Ember and Energy Institute” [dataset]. Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy” [original data]. Retrieved from https://ourworldindata.org/grapher/carbon-intensity-electricity Licenced under CC BY 4.0.