White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG L0DZSBLVZ
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 Kyber Network Crystal (KNC) referred to in this white paper is a crypto-asset other than EMTs and ARTs and is issued on multiple blockchain networks, namely Ethereum, Binance Smart Chain, Polygon, Optimism, Arbitrum, as of 2026-02-23 and according to DTI FFG shown in F.14. The maximum supply of the crypto-asset is currently fixed at 252,301,550 tokens. However due to KIP-6 in 2021, KNC was upgraded to a dynamic token supply. This allows the KyberDAO to mint or burn tokens as necessary to fund new protocol developments. The first activity on Ethereum can be viewed on 2021-04-12 (transaction hash: 0xf1558fa2757fc509172aab73bfbca6231f24005dcdb5fe9105fef05b91620ffd, source: https://etherscan.io/tx/0xf1558fa2757fc509172aab73bfbca6231f24005dcdb5fe9105fef05b91620ffd, accessed 2026-02-23). The first activity on Binance Smart Chain can be viewed on 2021-08-23 (transaction hash: 0x879bb2f5a0a80a5e9977c529c7abbe8bf5a32f293e3c815f8d066477563b473b, source: https://bscscan.com/tx/0x879bb2f5a0a80a5e9977c529c7abbe8bf5a32f293e3c815f8d066477563b473b, accessed 2026-02-23). The first activity on Polygon can be viewed on 2021-06-07 (transaction hash: 0xd43da05e12d53bfcd3f31edda2cf82943c3e423ea55ed25a5ad044b5d02de2ae, source: https://polygonscan.com/tx/0xd43da05e12d53bfcd3f31edda2cf82943c3e423ea55ed25a5ad044b5d02de2ae, accessed 2026-02-23). The first activity on Optimism can be viewed on 2022-08-18 (transaction hash: 0x8bca230959ea1f22394ae1d3a9109fc7df4a57cfbee8172aab366f8cc36e8616, source: https://optimistic.etherscan.io/tx/0x8bca230959ea1f22394ae1d3a9109fc7df4a57cfbee8172aab366f8cc36e8616, accessed 2026-02-23). The first activity on Arbitrum can be viewed on 2022-08-11 (transaction hash: 0x22d0f420e518d2bc104f31d8f526ff137467e776d7d28c8ecd73552d080cffd7, source: https://arbiscan.io/tx/0x22d0f420e518d2bc104f31d8f526ff137467e776d7d28c8ecd73552d080cffd7, accessed 2026-02-23).
The Kyber Network project is a decentralised finance initiative focused on providing liquidity infrastructure for digital asset markets. It operates as a multi-chain ecosystem centred around KyberSwap, a decentralised exchange platform that aggregates liquidity across multiple blockchain networks. The protocol is designed to connect traders to various on-chain liquidity sources through automated smart contracts, enabling token swaps, liquidity provision, and related decentralised finance functionalities without reliance on centralised intermediaries. KyberSwap incorporates liquidity aggregation mechanisms, specialised liquidity protocols, and developer-facing integration tools that allow third-party applications to access routing, swapping, and liquidity services. The system supports functionalities such as trade routing optimisation, limit order execution, liquidity pool participation, and cross-chain interactions, subject to network conditions and smart contract configurations.
Within this ecosystem, the KNC crypto-asset functions as a technical governance and incentive mechanism. KNC holders may stake their tokens in the KyberDAO to participate in on-chain governance processes, including voting on Kyber Improvement Proposals that relate to protocol parameters, fee configurations, and potential upgrades. Staked KNC may entitle participants, through smart contract logic, to receive a portion of protocol-generated trading fees, typically distributed in KNC or other designated assets. The token is also used within incentive frameworks, including liquidity mining programmes designed to encourage liquidity provision across supported pools. Following the implementation of KIP-6, KNC operates under a dynamic supply model in which token minting or burning may occur based on governance decisions of the KyberDAO, including for the purpose of protocol development or ecosystem incentives. These mechanisms are implemented through smart contracts and are subject to governance outcomes and technical constraints.
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 a 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 the 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, 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 that supports regulated entities in fulfilling their regulatory requirements. Among other services, Crypto Risk Metrics GmbH acts as a data provider for ESG data under Article 66(5). In light of the requirements set out in Articles 4(7), 5(4) and 66(3) 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, Crypto Risk Metrics GmbH aims to provide central services for crypto-asset white papers.
A.14 Parent company business activity
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 on regulatory technology and risk analytics in the context of the MiCA framework – has been developed progressively and can realistically be considered fully operational since approximately 2024.
The company’s financial trajectory over the past three years reflects the transition from exploratory development towards market-ready product delivery. Profit or loss after tax for the last three financial years is as follows:
2024 (unaudited): loss of EUR 50,891.81
2023 (unaudited): loss of EUR 27,665.32
2022: profit of EUR 104,283.00
The profit in 2022 resulted primarily from legacy consulting activities, which were discontinued as part of the company’s repositioning.
The losses in 2023 and 2024 resulted from strategic investments in the development of proprietary software infrastructure, regulatory frameworks, and compliance technology for the MiCA ecosystem. During those periods, no substantial commercial revenues were expected, as resources were directed towards preparing the platform for market entry in a regulated environment.
A fundamental repositioning of the company occurred in 2023 and especially in 2024, when the focus shifted towards 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 finalised 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 materialise 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 in tokens from projects it has worked with and – due to its internal Conflicts of Interest Policy – never will.
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
| Identity | Function | Business Address |
|---|---|---|
B.11 Business activity
This Company's principal activity is development of software and applications (except games and cybersecurity) with other financial service activities, except insurance and pension funding activities n.e.c. as the secondary activity.
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 public information (source: https://docs.kyberswap.com/, accessed 2026-02-23), the Kyber Network project is a crypto-asset initiative concerned with the development and operation of an open and permissionless liquidity infrastructure designed to support decentralised trading and capital efficiency across multiple distributed-ledger networks. The project centres on KyberSwap, a multi-chain decentralised exchange aggregator and liquidity platform that connects users to numerous liquidity sources across various blockchain networks. The protocol architecture includes aggregation mechanisms for routing trades across decentralised exchanges, liquidity-management modules for yield optimisation, and developer-facing tools such as APIs and integration widgets intended to enable third-party applications to access Kyber’s trading infrastructure. The project is maintained by contributors to the Kyber Network ecosystem and is intended to provide users and developers with tools for interacting with decentralised financial systems in a multi-chain environment, subject to the availability, performance, and continued operation of the underlying technological infrastructure.
The KNC crypto-asset functions as an element within this broader technical framework. It is intended to interact with specific parts of the protocol’s internal logic, such as governance parameters, staking modules, fee-distribution mechanisms, and liquidity-incentive structures, if and when these features are implemented or activated. KNC may be staked within the KyberDAO governance system to participate in voting on protocol-related proposals, including changes to fee configurations, upgrades, or ecosystem initiatives. Certain functionalities, such as governance reward distributions, liquidity mining incentives, gas-related benefits, or supply-adjustment mechanisms, remain contingent on technical implementation, governance decisions, and operational priorities. There is no assurance that any proposed or potential functionalities will be introduced, remain active, or be accessible at all times.
The project does not involve the granting of ownership, profit-participation rights, or legal claims against the project entity or its contributors. Instead, it centres on the creation of a technical environment in which the KNC crypto-asset may serve as a governance and utility input for certain protocol processes. The long-term evolution of the Kyber Network system, including the scope of available features, the governance roadmap, validator or liquidity-participant selection mechanisms, and the operational continuity of the infrastructure, may vary based on technical, economic, and regulatory considerations. All future developments remain subject to change.
D.5 Details of all natural or legal persons involved in the implementation of the crypto-asset project
| Name of person | Type 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
D.8 Plans for the token
This section provides an overview of the historical developments related to the KNC crypto-asset and a description of planned or anticipated project milestones as publicly communicated. All forward-looking elements are subject to significant uncertainty. They do not constitute commitments, assurances, or guarantees, and may be modified, delayed, or discontinued at any time. The implementation of past milestones cannot be assumed to continue in the future, and future changes may have adverse effects for token holders.
There is a formally published roadmap for the KNC crypto-asset and/or the Kyber Network protocol. Based on the official roadmap (sources: https://docs.kyberswap.com/, https://blog.kyberswap.com/, https://blog.kyberswap.com/kyberswap-product-roadmap-updates-2025/; accessed 2026-02-23), several protocol upgrades, ecosystem initiatives, and crypto-asset-related developments have been communicated that affect the evolution of the Kyber Network protocol and the role of the KNC crypto-asset.
Past milestones:
- Initial Coin Offering (16 September 2017): The token generation event concluded, raising 200,000 ETH and minting 226,000,000 KNC tokens, thereby establishing the initial supply and distribution framework of the crypto-asset.
- Kyber 3.0 Upgrade Announcement (21 January 2021): The transition to “Kyber 3.0” was announced, restructuring the network from a single protocol into a hub of liquidity protocols, thereby affecting the technical architecture and the economic role of KNC within governance and protocol coordination.
- KNC Token Migration (20 April 2021): Following approval under KIP-6, the migration from the legacy KNC token (renamed KNCL) to a new KNC token commenced at a 1:1 ratio, introducing updated token mechanics intended to enhance flexibility in governance and fee-related parameters.
- Minting for Ecosystem Growth Fund (15 June 2021): KyberDAO approved the minting of 42,050,588 additional KNC under KIP-8 and KIP-9 to fund ecosystem growth initiatives, resulting in an increase in total token supply.
- KyberSwap Elastic Security Incident (22 November 2023): A security incident affected the KyberSwap Elastic protocol, leading to the subsequent discontinuation of the Elastic and Classic liquidity services and materially impacting certain protocol components.
- FairFlow Launch and Trading Volume Milestone (August 2025): Reported launch of FairFlow, a liquidity mechanism intended to capture arbitrage value for liquidity providers.
Future milestones:
- Biannual Roadmap Updates (2026): The project has communicated its intention to review and publish updated roadmaps twice per year to inform stakeholders of progress and adjustments to planned developments.
Note: All future milestones are subject to significant uncertainty, including but not limited to technical feasibility, regulatory developments, market adoption, and community governance decisions. The project may modify, delay, or discontinue any of these initiatives at any time. Past implementation or performance outcomes do not constitute an indication of future results, and any such changes may materially affect the characteristics, availability, or perceived value of the KNC crypto-asset for its holders.
D.9 Resource allocation
Based on information from various third-party and industry sources, it is reported that Kyber Network’s primary capital-raising event related to the KNC crypto-asset was an Initial Coin Offering (ICO) completed in 2017. The sources provided do not describe a documented sequence of traditional venture capital financing rounds (for example, Series A or Series B) directly attributable to the KNC token, and any references to external support mechanisms or institutional involvement are limited and not verifiable via regulatory filings or issuer confirmations. As a result, the information below should be considered indicative only and cannot be independently verified.
Based on the provided sources, Kyber Network is reported to have concluded its KNC token sale on or around 2017-09-16, raising approximately 200,000 ETH on Ethereum. This event is described as having involved a large number of participating addresses and is referenced as the main historical fundraising event associated with KNC. Based on publicly available third-party sources, 19.47% of the initial KNC token supply, corresponding to 44,002,200 KNC, was reportedly allocated to company operational reserves as part of the 2017 ICO distribution.
Reported Institutional Links and External Support (Non-Exhaustive)
- External grants and incentives: It is reported that the Uniswap Foundation provided incentives exceeding USD 100,000 in 2025 to support adoption of Kyber-related FairFlow hooks.
- KyberDAO Ecosystem Growth Fund minting: It is reported that KyberDAO governance approved the minting of additional KNC in 2021 (referenced as 42,050,588 KNC) for an ecosystem growth fund intended to support liquidity and adoption. This reflects a governance decision on token supply and allocation, not a third-party capital raise, and the downstream use of these resources cannot be verified from the provided information.
Overall, the only consistently referenced fundraising event in the provided materials is the 2017 ICO. Any broader conclusions about venture capital financing, investor identities, or the current availability and allocation of historical proceeds would require issuer-confirmed disclosures or verifiable primary documentation, which are not available based on the information provided.
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
MiCA-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 public information available on the official website (https://docs.kyberswap.com/, accessed 2026-02-23) and associated governance and documentation resources, the KNC token is an Ethereum ERC-20 token intended to operate as the primary on-chain coordination mechanism within the Kyber Network ecosystem. KNC was originally deployed on the Ethereum blockchain and is designed to interact with smart-contract based infrastructure supporting trading aggregation, liquidity provision, and protocol governance. In addition to its Ethereum deployment, representations or bridged versions of KNC may be available on other blockchain networks in connection with Kyber’s multi-chain expansion, subject to the technical configuration and bridge mechanisms used.
The KNC token is designed to facilitate decentralized decision-making within the Kyber protocol environment. Token holders may stake KNC in the KyberDAO and participate in governance processes, including proposing and voting on Kyber Improvement Proposals that determine protocol-level parameters such as fee structures, incentive mechanisms, treasury allocations, and technical upgrades. Voting rights relate exclusively to technical and protocol-level features and do not extend to decisions regarding the operation, management, or assets of any legal entity associated with the project.
Within the Kyber ecosystem, KNC may be used in connection with staking mechanisms that enable participation in governance and eligibility for protocol-defined incentive distributions funded by a portion of trading fees. The token may also be used in liquidity mining programs and other incentive schemes intended to promote liquidity provision and ecosystem participation. These functionalities depend on the stable operation of the underlying smart contracts, the security of validator and bridge infrastructure where applicable, the correct execution of governance-approved parameters, and the continued availability and performance of the relevant blockchain networks.
The KNC token does not confer ownership, profit participation, governance rights over the issuer or any related entity, or any form of economic entitlement. All functionalities are technical in nature and relate exclusively to interactions within the Kyber protocol environment. The actual usability of KNC depends on factors such as system stability, smart-contract execution, development progress, governance decisions, and the operational conditions of the Ethereum blockchain, which are outside the control of token holders.
F.3 Planned application of functionalities
Future milestones:
- Biannual Roadmap Updates (2026): The project has communicated its intention to review and publish updated roadmaps twice per year to inform stakeholders of progress and adjustments to planned developments.
Note: All future milestones are subject to significant uncertainty, including but not limited to technical feasibility, regulatory developments, market adoption, and community governance decisions. The project may modify, delay, or discontinue any of these initiatives at any time. Past implementation or performance outcomes do not constitute an indication of future results, and any such changes may materially affect the characteristics, availability, or perceived value of the KNC crypto-asset for its holders.
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 the Ethereum, Binance Smart Chain, Polygon, Optimism, and Arbitrum networks. The crypto-asset is fungible up to 18 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 legally enforceable claim against the issuer of the crypto-asset or any third party.
G.2 Exercise of rights and obligations
As the crypto-asset does not confer 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 project’s technical infrastructure – such as participation mechanisms or protocol-level features – serves operational purposes only and does not create, evidence, or constitute 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 for modifying such rights or obligations. 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 rights exist and no rights arise under applicable law or regulation. 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 (2026-02-23).
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
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
Not applicable.
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 by Crypto Risk Metrics GmbH, which is established in Germany. 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 be brought before 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 Ethereum Ether, Binance Smart Chain, Polygon POL, Optimism and Arbitrum 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: Ethereum Ether, Binance Smart Chain, Polygon POL, Optimism and Arbitrum. In general, when evaluating crypto-assets, all implementations across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Ethereum Ether:
The crypto-asset operates on a well-defined set of protocols and technical standards that are intended to ensure its security, decentralization, and functionality. 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 Binance Smart Chain:
Binance Smart Chain (BSC) is a Layer-1 blockchain that utilises a Proof-of-Staked-Authority (PoSA) consensus mechanism. This mechanism combines elements of Proof-of-Authority (PoA) and Delegated-Proof-of-Stake (DPoS) and is intended to secure the network and validate transactions. In PoSA, validators are selected based on their stake and authority, with the goal of providing fast transaction times and low fees while maintaining network security through staking.
The following applies to Polygon POL:
The Polygon network is built on a clear set of protocols and standards designed to ensure scalability, interoperability, and security. Polygon is built on top of Ethereum, it combines Layer-2 features with sidechain architecture. Network security is provided through Proof-of-Stake, where validators stake POL to propose and validate blocks. The consensus architecture consists of three layers: Smart Contracts on Ethereum that are used for staking POL. The Heimdall layer consisting of Heimdall nodes running in parallel to the Ethereum mainnet, monitoring the staking smart contracts deployed on the mainnet, and committing checkpoints to the mainnet. And the Bor layer, which are block producing Bor nodes. Bor clients are based on the widely used Go Ethereum client, and therefore most technical standards on Polygon are the same as for Ethereum. Furthermore full compatibility with the Ethereum Virtual Machine (EVM) allows Ethereum smart contracts to be deployed on Polygon without modification.
The following applies to Optimism:
Optimism is a Layer 2 scaling solution built on Ethereum that uses Optimistic Rollups technology. Transactions are bundled outside the Ethereum main chain and only transmitted to Layer 1 in compressed form. This significantly reduces gas fees and increases transaction speed. Optimism is fully EVM-compatible and allows developers to migrate existing Ethereum smart contracts without major adjustments. Optimism's architecture is based on a modular rollup design, with data and execution layers treated separately to ensure scalability and flexibility.
The following applies to Arbitrum:
Arbitrum commonly refers to the Arbitrum Rollup, a Layer 2 (L2) blockchain built using the Arbitrum technology suite. The Arbitrum Rollup is an optimistic rollup on top of the Ethereum blockchain. This means that the L2 transactions do not have their own consensus mechanism and are only validated by the execution clients. The so-called sequencer regularly bundles stacks of L2 transactions and publishes them on the L1 network, i.e. Ethereum. Ethereum's consensus mechanism (Proof-of-Stake) thus indirectly secures all L2 transactions as soon as they are written to L1.
H.3 Technology used
The crypto-asset that is the subject of this white paper is available on multiple DLT networks. These include: Ethereum Ether, Binance Smart Chain, Polygon POL, Optimism and Arbitrum. In general, when evaluating crypto-assets, all implementations across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Ethereum Ether:
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 Binance Smart Chain:
1. BSC-compatible wallets
Tokens on BSC are supported by wallets compatible with the Ethereum Virtual Machine (EVM), such as MetaMask. These wallets can be configured to connect to the BSC network and are designed to interact with BSC using standard Web3 interfaces.
2. Decentralised Ledger
BSC maintains its own decentralised ledger for recording token transactions. This ledger is intended to ensure transparency and security, providing a verifiable record of all activities on the network.
3. BEP-20 token standard
BSC supports tokens implemented under the BEP-20 standard, which is tailored for the BSC ecosystem. This standard is designed to facilitate the creation and management of tokens on the network.
4. Scalability and transaction efficiency
BSC is designed to handle high volumes of transactions with low fees. It leverages its PoSA consensus mechanism to achieve fast transaction times and efficient network performance, making it suitable for applications requiring high throughput.
The following applies to Polygon POL:
Polygon operates as a decentralized ledger that records all token transactions on its network, ensuring transparency and security through an immutable record of transfers and ownership. To protect their holdings, users must securely manage their private keys and recovery phrases, since access to tokens depends entirely on these credentials.
The network relies on elliptic curve cryptography for secure transaction validation and execution. Polygon uses the secp256k1 curve with ECDSA for key generation and digital signatures, while the Keccak-256 hashing algorithm underpins address derivation and transaction integrity. This combination of cryptographic standards provides the foundation for both the security and reliability of the Polygon ecosystem.
Polygon’s Bor client is based on Ethereum’s Go Ethereum Client. Polygon’s Heimdall client is built using Cosmos-SDK and CometBFT.
The following applies to Optimism:
Optimism is fully compatible with Ethereum (Layer 1) and uses the same development tools as Solidity, Vyper, and popular frameworks (Hardhat, Foundry, Truffle). This allows developers to deploy their applications on Optimism without making major changes. In addition, the bridge between Ethereum and Optimism is designed to allow assets to be easily transferred between the two networks.
The following applies to Arbitrum:
1. Arbitrum-compatible wallets: The tokens are supported by all wallets compatible with the Ethereum Virtual Machine (EVM), such as MetaMask.
2. Decentralised ledger: Arbitrum operates as a Layer-2 blockchain on Ethereum and maintains its own decentralised ledger for recording token transactions. Final transaction data is periodically posted to Ethereum Layer 1, ensuring long-term availability and resistance to tampering.
3. ERC-20 token standard: The Arbitrum network supports tokens implemented under the ERC-20 standard, the same as on Ethereum.
4. Arbitrum supports what is called "MultiVM", which is the combination of EVM support with a WASM-based virtual machine. The latter one being more efficient (lower gas costs) but specific to Arbitrum.
5. Scalability and transaction efficiency: As a rollup-based Layer-2, Arbitrum is intended to process higher volumes of transactions with lower fees compared to Ethereum Layer 1 by executing transactions off-chain and posting data on-chain using an optimistic rollup architecture.
H.4 Consensus mechanism
The crypto-asset that is the subject of this white paper is available on multiple DLT networks. These include: Ethereum Ether, Binance Smart Chain, Polygon POL, Optimism and Arbitrum. In general, when evaluating crypto-assets, all implementations across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Ethereum Ether:
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, and a validator is randomly selected to propose each new 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 Binance Smart Chain:
Binance Smart Chain (BSC) uses a hybrid consensus mechanism called Proof-of-Staked-Authority (PoSA), which combines elements of Delegated-Proof-of-Stake (DPoS) and Proof-of-Authority (PoA). This method is intended to support fast block times and low fees while maintaining a level of decentralisation and security.
Core components
1. Validators (so-called “Cabinet Members”): Validators on BSC are responsible for producing new blocks, validating transactions, and maintaining the network’s security. To become a validator, an entity must stake a significant amount of BNB (Binance Coin). Validators are selected through staking and voting by token holders. There are 21 active validators at any given time, rotating to support decentralisation and security.
2. Delegators: Token holders who do not wish to run validator nodes can delegate their BNB tokens to validators. This delegation helps validators increase their stake and improves their chances of being selected to produce blocks. Delegators earn a share of the rewards that validators receive, incentivising broad participation in network security.
3. Candidates: Candidates are nodes that have staked the required amount of BNB and are in the pool waiting to become validators. They are essentially potential validators who are not currently active but can be elected to the validator set through community voting. Candidates help ensure there is a sufficient pool of nodes ready to take on validation tasks, supporting network resilience and decentralisation.
Consensus process
4. Validator selection: Validators are chosen based on the amount of BNB staked and votes received from delegators. The more BNB staked and votes received, the higher the chance of being selected to validate transactions and produce new blocks. The selection process involves both the current validators and the pool of candidates, supporting a dynamic rotation of nodes.
5. Block production: The selected validators take turns producing blocks in a PoA-like manner, ensuring that blocks are generated quickly and efficiently. Validators validate transactions, add them to new blocks, and broadcast these blocks to the network.
6. Transaction finality: BSC achieves fast block times of around 3 seconds and quick transaction finality. This is achieved through the PoSA mechanism, which allows validators to reach consensus efficiently.
Security and economic incentives
7. Staking: Validators are required to stake a substantial amount of BNB, which acts as collateral to support honest behaviour. This staked amount can be slashed if validators act maliciously.
8. Delegation and rewards: Delegators earn rewards proportional to their stake in validators. This incentivizes them to choose reliable validators and participate in the network’s security. Validators and delegators share transaction fees as rewards, which provides economic incentives to maintain network security and performance.
9. Transaction fees: BSC employs low transaction fees, paid in BNB. These fees are collected by validators as part of their rewards, incentivising them to validate transactions accurately and efficiently.
The following applies to Polygon POL:
Polygon is a scaling solution for Ethereum that stores and process transaction data on its own separate chain and regularly submits checkpoints to Ethereum. This type of scaling solution is sometimes referred to as a plasma chain, and is distinct from sidechains, which don’t store checkpoints and Layer 2 solutions that store all transaction data on Ethereum in addition to the checkpoints. Here’s a detailed explanation of how Polygon achieves consensus:
Core Concepts
1. Proof of Stake (PoS): Validator Selection: Validators on the Polygon network are selected based on the number of POL tokens they have staked. The more tokens are staked, the higher the chance of being selected to validate transactions and produce new blocks. Delegation: Token holders who do not wish to run a validator node can delegate their POL tokens to validators. Delegated tokens also count towards the block production chance of the validator they are delegated to. Delegators receive a share of rewards earned by validators.
Consensus Process
2. Transaction Validation: Transactions are first validated by validators who have staked POL tokens. These validators confirm the validity of transactions and include them in blocks.
3. Block Production: Proposing and Voting: Validators are randomly selected to propose new blocks. Their selection chance is proportional to their staked tokens. Validators also participate in a voting process to reach consensus on the next block. The block with most votes is added to the blockchain. Checkpointing: Polygon uses periodic checkpointing, where a cryptographic summary of the transactions on the Polygon chain is submitted to the Ethereum main chain. This process ensures the security and finality of transactions on the Polygon network.
The following applies to Optimism:
Since Optimism is based on Ethereum, it ultimately inherits its security via the Ethereum blockchain and the proof-of-stake consensus. Within the rollup system, Optimism relies on a “fault proof” procedure. By default, transactions are assumed to be correct (“optimistic”). Only in the event of suspected faults is a fault proof initiated, in which incorrect transactions can be challenged by challengers. This model allows for high efficiency while ensuring correctness.
The following applies to Arbitrum:
Arbitrum is a Layer-2 (L2) solution on Ethereum that is developed using the Arbitrum technology suite. L2 transactions do not have their own consensus mechanism and are only validated by the execution clients. The so-called sequencer regularly bundles stacks of L2 transactions and publishes them on the L1 network, i.e. Ethereum. Ethereum's consensus mechanism (Proof-of-Stake) thus indirectly secures all L2 transactions as soon as they are written to L1.
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: Ethereum Ether, Binance Smart Chain, Polygon POL, Optimism and Arbitrum. In general, when evaluating crypto-assets, all implementations across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Ethereum Ether:
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 Binance Smart Chain:
Binance Smart Chain (BSC) uses the Proof of Staked Authority (PoSA) consensus mechanism to support network security and incentivise participation from validators and delegators.
Incentive mechanisms
1. Validators: Staking rewards: Validators must stake a significant amount of BNB to participate in the consensus process. They earn rewards in the form of transaction fees and block rewards. Selection process: Validators are selected based on the amount of BNB staked and the votes received from delegators. The more BNB staked and votes received, the higher the chance of being selected to validate transactions and produce new blocks.
2. Delegators: Delegated staking: Token holders can delegate their BNB to validators. This delegation increases the validator’s total stake and improves their chances of being selected to produce blocks. Shared rewards: Delegators earn a portion of the rewards that validators receive. This incentivises token holders to participate in the network’s security and decentralisation by choosing reliable validators.
3. Candidates: Pool of potential validators: Candidates are nodes that have staked the required amount of BNB and are waiting to become active validators. They help ensure there is a sufficient pool of nodes ready to take on validation tasks, supporting network resilience.
4. Economic Security: Slashing: Validators can be penalised for malicious behaviour or failure to perform their duties. Penalties can include slashing a portion of their staked tokens. Opportunity cost: Staking requires validators and delegators to lock up their BNB tokens, providing an economic incentive to act honestly to avoid losing staked assets.
Fees on the Binance Smart Chain
5. Transaction fees: Low fees: BSC is known for its low transaction fees compared to other blockchain networks. These fees are paid in BNB and are used to compensate validators. Dynamic fee structure: Transaction fees can vary based on network congestion and the complexity of transactions. However, BSC aims to keep fees significantly lower than those on the Ethereum mainnet.
6. Block rewards: Incentivising validators: Validators earn block rewards in addition to transaction fees. These rewards are distributed to validators for their role in maintaining the network and processing transactions.
7. Cross-chain fees: Interoperability costs: BSC supports cross-chain compatibility, allowing assets to be transferred between Binance Chain and Binance Smart Chain. These cross-chain operations incur minimal fees, facilitating asset transfers and improving user experience.
8. Smart contract fees: Deployment and execution costs: Deploying and interacting with smart contracts on BSC involves paying fees based on the computational resources required. These fees are also paid in BNB and are designed to be cost-effective, encouraging developers to build on the BSC platform.
The following applies to Polygon POL:
Incentive Mechanisms
1. Validators: Staking Rewards: Validators on Polygon secure the network by staking POL tokens. Validators are rewarded for block production and block validation/voting. They earn rewards in the form of newly minted POL tokens and, when they produce blocks, some transaction fees.
2. Delegators: Delegation: Token holders who do not wish to run a validator node can delegate their POL tokens to trusted validators. Delegators earn a portion of the rewards earned by the validators, incentivizing them to choose reliable and performant validators. Validators profit from delegations, because their chance of being selected for block production and therefore the associated expected rewards increase. This system encourages widespread participation and enhances the network's decentralization.
3. Economic Security: Slashing: Validators can be penalized through a process called slashing if they engage in malicious behavior or fail to perform their duties correctly. This includes double-signing or going offline for extended periods. Slashing results in the loss of a portion of the staked tokens, acting as a strong deterrent against dishonest actions. Bond Requirements: Validators are required to bond a significant amount of POL tokens to participate in the consensus process, ensuring they have a vested interest in maintaining network security and integrity.
4. Transaction Fees: Low Fees: One of Polygon's main advantages is its low transaction fees compared to the Ethereum main chain. The fees are paid in POL tokens and are designed to be affordable to encourage high transaction throughput and user adoption. Dynamic Fees: Fees on Polygon can vary depending on network congestion and transaction complexity. However, they remain significantly lower than those on Ethereum, making Polygon an attractive option for users and developers.
5. Smart Contract Fees: Deployment and Execution Costs: Deploying and interacting with smart contracts on Polygon incurs fees based on the computational resources required. These fees are also paid in POL tokens and are much lower than on Ethereum, making it cost-effective for developers to build and maintain decentralized applications (dApps) on Polygon.
The following applies to Optimism:
Optimism charges significantly lower transaction fees than Ethereum Layer 1, as transactions are bundled in the rollup and written to the Ethereum main chain in compressed form. Gas fees on Optimism continue to be paid in ETH.
The incentive model is based on increased efficiency for users (lower fees, faster confirmation) and on the role of sequencers. Sequencers are central actors who collect, organize, and include transactions in the rollup. Their revenue comes from the gas fees they charge. Fault proofs ensure that sequencers cannot permanently enforce incorrect or malicious transactions. Fault proofs and their resolution are also incentivized economically to discourage faults to begin with.
The following applies to Arbitrum:
Arbitrum is a Layer-2 (L2) solution on Ethereum that is developed using the Arbitrum technology suite. Transaction on Arbitrum are bundled by a, so called, sequencer and the result is regularly submitted as an Layer-1 (L1) transactions. This way many L2 transactions get combined into a single L1 transaction. This lowers the average transaction cost per transaction, because many L2 transactions together fund the transaction cost for the single L1 transaction. This creates incentives to use Arbitrum rather than the L1, i.e. Ethereum, itself. To get crypto-assets in and out of Arbitrum, a special smart contract on Ethereum is used. Since there is no consensus mechanism on L2, an additional mechanism ensures that only existing funds can be withdrawn from L2. When a user wants to withdraw funds, that user needs to submit a withdrawal request on L1. If this request remains undisputed for a period of time the funds can be withdrawn. During this time period Arbitrum validators can dispute the claim, which will start a dispute resolution process. This process is designed with economic incentives for correct behavior of all participants.
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
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 venues on which it is listed 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 centralised exchanges (CEXs) or decentralised 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 favourable 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 where 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 centralised or decentralised 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 listing crypto-asset 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 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 recognised in the counterparty’s jurisdiction.
5. Operational and information risks
Due to the irrevocability of blockchain transactions, incorrect transaction 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, armed conflicts). 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, reporting 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 admission to trading of the crypto-asset, the risk description below reflects general implementation risks typically associated with crypto-asset projects and relevant for the crypto-asset service provider. The party admitting the crypto-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 crypto-asset’s practical utility.
I.5 Technology-related risks
As this white paper relates to 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 the 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.
Centralisation 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: Ethereum Ether, Binance Smart Chain, Polygon POL, Optimism and Arbitrum. In general, when evaluating crypto-assets, all implementations across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Ethereum Ether:
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, and a validator is randomly selected to propose each new 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 Binance Smart Chain:
Binance Smart Chain (BSC) uses a hybrid consensus mechanism called Proof-of-Staked-Authority (PoSA), which combines elements of Delegated-Proof-of-Stake (DPoS) and Proof-of-Authority (PoA). This method is intended to support fast block times and low fees while maintaining a level of decentralisation and security.
Core components
1. Validators (so-called “Cabinet Members”): Validators on BSC are responsible for producing new blocks, validating transactions, and maintaining the network’s security. To become a validator, an entity must stake a significant amount of BNB (Binance Coin). Validators are selected through staking and voting by token holders. There are 21 active validators at any given time, rotating to support decentralisation and security.
2. Delegators: Token holders who do not wish to run validator nodes can delegate their BNB tokens to validators. This delegation helps validators increase their stake and improves their chances of being selected to produce blocks. Delegators earn a share of the rewards that validators receive, incentivising broad participation in network security.
3. Candidates: Candidates are nodes that have staked the required amount of BNB and are in the pool waiting to become validators. They are essentially potential validators who are not currently active but can be elected to the validator set through community voting. Candidates help ensure there is a sufficient pool of nodes ready to take on validation tasks, supporting network resilience and decentralisation.
Consensus process
4. Validator selection: Validators are chosen based on the amount of BNB staked and votes received from delegators. The more BNB staked and votes received, the higher the chance of being selected to validate transactions and produce new blocks. The selection process involves both the current validators and the pool of candidates, supporting a dynamic rotation of nodes.
5. Block production: The selected validators take turns producing blocks in a PoA-like manner, ensuring that blocks are generated quickly and efficiently. Validators validate transactions, add them to new blocks, and broadcast these blocks to the network.
6. Transaction finality: BSC achieves fast block times of around 3 seconds and quick transaction finality. This is achieved through the PoSA mechanism, which allows validators to reach consensus efficiently.
Security and economic incentives
7. Staking: Validators are required to stake a substantial amount of BNB, which acts as collateral to support honest behaviour. This staked amount can be slashed if validators act maliciously.
8. Delegation and rewards: Delegators earn rewards proportional to their stake in validators. This incentivizes them to choose reliable validators and participate in the network’s security. Validators and delegators share transaction fees as rewards, which provides economic incentives to maintain network security and performance.
9. Transaction fees: BSC employs low transaction fees, paid in BNB. These fees are collected by validators as part of their rewards, incentivising them to validate transactions accurately and efficiently.
The following applies to Polygon POL:
Polygon is a scaling solution for Ethereum that stores and process transaction data on its own separate chain and regularly submits checkpoints to Ethereum. This type of scaling solution is sometimes referred to as a plasma chain, and is distinct from sidechains, which don’t store checkpoints and Layer 2 solutions that store all transaction data on Ethereum in addition to the checkpoints. Here’s a detailed explanation of how Polygon achieves consensus:
Core Concepts
1. Proof of Stake (PoS): Validator Selection: Validators on the Polygon network are selected based on the number of POL tokens they have staked. The more tokens are staked, the higher the chance of being selected to validate transactions and produce new blocks. Delegation: Token holders who do not wish to run a validator node can delegate their POL tokens to validators. Delegated tokens also count towards the block production chance of the validator they are delegated to. Delegators receive a share of rewards earned by validators.
Consensus Process
2. Transaction Validation: Transactions are first validated by validators who have staked POL tokens. These validators confirm the validity of transactions and include them in blocks.
3. Block Production: Proposing and Voting: Validators are randomly selected to propose new blocks. Their selection chance is proportional to their staked tokens. Validators also participate in a voting process to reach consensus on the next block. The block with most votes is added to the blockchain. Checkpointing: Polygon uses periodic checkpointing, where a cryptographic summary of the transactions on the Polygon chain is submitted to the Ethereum main chain. This process ensures the security and finality of transactions on the Polygon network.
The following applies to Optimism:
Since Optimism is based on Ethereum, it ultimately inherits its security via the Ethereum blockchain and the proof-of-stake consensus. Within the rollup system, Optimism relies on a “fault proof” procedure. By default, transactions are assumed to be correct (“optimistic”). Only in the event of suspected faults is a fault proof initiated, in which incorrect transactions can be challenged by challengers. This model allows for high efficiency while ensuring correctness.
The following applies to Arbitrum:
Arbitrum is a Layer-2 (L2) solution on Ethereum that is developed using the Arbitrum technology suite. L2 transactions do not have their own consensus mechanism and are only validated by the execution clients. The so-called sequencer regularly bundles stacks of L2 transactions and publishes them on the L1 network, i.e. Ethereum. Ethereum's consensus mechanism (Proof-of-Stake) thus indirectly secures all L2 transactions as soon as they are written to L1.
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: Ethereum Ether, Binance Smart Chain, Polygon POL, Optimism and Arbitrum. In general, when evaluating crypto-assets, all implementations across different networks must always be taken into account, as spillover effects can be adverse for investors.
The following applies to Ethereum Ether:
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 Binance Smart Chain:
Binance Smart Chain (BSC) uses the Proof of Staked Authority (PoSA) consensus mechanism to support network security and incentivise participation from validators and delegators.
Incentive mechanisms
1. Validators: Staking rewards: Validators must stake a significant amount of BNB to participate in the consensus process. They earn rewards in the form of transaction fees and block rewards. Selection process: Validators are selected based on the amount of BNB staked and the votes received from delegators. The more BNB staked and votes received, the higher the chance of being selected to validate transactions and produce new blocks.
2. Delegators: Delegated staking: Token holders can delegate their BNB to validators. This delegation increases the validator’s total stake and improves their chances of being selected to produce blocks. Shared rewards: Delegators earn a portion of the rewards that validators receive. This incentivises token holders to participate in the network’s security and decentralisation by choosing reliable validators.
3. Candidates: Pool of potential validators: Candidates are nodes that have staked the required amount of BNB and are waiting to become active validators. They help ensure there is a sufficient pool of nodes ready to take on validation tasks, supporting network resilience.
4. Economic Security: Slashing: Validators can be penalised for malicious behaviour or failure to perform their duties. Penalties can include slashing a portion of their staked tokens. Opportunity cost: Staking requires validators and delegators to lock up their BNB tokens, providing an economic incentive to act honestly to avoid losing staked assets.
Fees on the Binance Smart Chain
5. Transaction fees: Low fees: BSC is known for its low transaction fees compared to other blockchain networks. These fees are paid in BNB and are used to compensate validators. Dynamic fee structure: Transaction fees can vary based on network congestion and the complexity of transactions. However, BSC aims to keep fees significantly lower than those on the Ethereum mainnet.
6. Block rewards: Incentivising validators: Validators earn block rewards in addition to transaction fees. These rewards are distributed to validators for their role in maintaining the network and processing transactions.
7. Cross-chain fees: Interoperability costs: BSC supports cross-chain compatibility, allowing assets to be transferred between Binance Chain and Binance Smart Chain. These cross-chain operations incur minimal fees, facilitating asset transfers and improving user experience.
8. Smart contract fees: Deployment and execution costs: Deploying and interacting with smart contracts on BSC involves paying fees based on the computational resources required. These fees are also paid in BNB and are designed to be cost-effective, encouraging developers to build on the BSC platform.
The following applies to Polygon POL:
Incentive Mechanisms
1. Validators: Staking Rewards: Validators on Polygon secure the network by staking POL tokens. Validators are rewarded for block production and block validation/voting. They earn rewards in the form of newly minted POL tokens and, when they produce blocks, some transaction fees.
2. Delegators: Delegation: Token holders who do not wish to run a validator node can delegate their POL tokens to trusted validators. Delegators earn a portion of the rewards earned by the validators, incentivizing them to choose reliable and performant validators. Validators profit from delegations, because their chance of being selected for block production and therefore the associated expected rewards increase. This system encourages widespread participation and enhances the network's decentralization.
3. Economic Security: Slashing: Validators can be penalized through a process called slashing if they engage in malicious behavior or fail to perform their duties correctly. This includes double-signing or going offline for extended periods. Slashing results in the loss of a portion of the staked tokens, acting as a strong deterrent against dishonest actions. Bond Requirements: Validators are required to bond a significant amount of POL tokens to participate in the consensus process, ensuring they have a vested interest in maintaining network security and integrity.
4. Transaction Fees: Low Fees: One of Polygon's main advantages is its low transaction fees compared to the Ethereum main chain. The fees are paid in POL tokens and are designed to be affordable to encourage high transaction throughput and user adoption. Dynamic Fees: Fees on Polygon can vary depending on network congestion and transaction complexity. However, they remain significantly lower than those on Ethereum, making Polygon an attractive option for users and developers.
5. Smart Contract Fees: Deployment and Execution Costs: Deploying and interacting with smart contracts on Polygon incurs fees based on the computational resources required. These fees are also paid in POL tokens and are much lower than on Ethereum, making it cost-effective for developers to build and maintain decentralized applications (dApps) on Polygon.
The following applies to Optimism:
Optimism charges significantly lower transaction fees than Ethereum Layer 1, as transactions are bundled in the rollup and written to the Ethereum main chain in compressed form. Gas fees on Optimism continue to be paid in ETH.
The incentive model is based on increased efficiency for users (lower fees, faster confirmation) and on the role of sequencers. Sequencers are central actors who collect, organize, and include transactions in the rollup. Their revenue comes from the gas fees they charge. Fault proofs ensure that sequencers cannot permanently enforce incorrect or malicious transactions. Fault proofs and their resolution are also incentivized economically to discourage faults to begin with.
The following applies to Arbitrum:
Arbitrum is a Layer-2 (L2) solution on Ethereum that is developed using the Arbitrum technology suite. Transaction on Arbitrum are bundled by a, so called, sequencer and the result is regularly submitted as an Layer-1 (L1) transactions. This way many L2 transactions get combined into a single L1 transaction. This lowers the average transaction cost per transaction, because many L2 transactions together fund the transaction cost for the single L1 transaction. This creates incentives to use Arbitrum rather than the L1, i.e. Ethereum, itself. To get crypto-assets in and out of Arbitrum, a special smart contract on Ethereum is used. Since there is no consensus mechanism on L2, an additional mechanism ensures that only existing funds can be withdrawn from L2. When a user wants to withdraw funds, that user needs to submit a withdrawal request on L1. If this request remains undisputed for a period of time the funds can be withdrawn. During this time period Arbitrum validators can dispute the claim, which will start a dispute resolution process. This process is designed with economic incentives for correct behavior of all participants.
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 Ethereum Ether, Binance Smart Chain, Polygon POL, Optimism and Arbitrum is calculated first. A proportionate share of that energy use is then attributed to the token based on its expected 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 that are comparable in terms of their incentivization structure and consensus mechanism. This geolocation data is merged with public information from Our World in Data (see citation). The intensity is calculated as the marginal energy cost with respect to an additional transaction. 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.