White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG HLTPNVXN0
Preamble
00. Table of Contents
- 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 (DLT)
- 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 crypto-asset
- 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 Hyperliquid (HYPE) referred to in this white paper is a crypto-asset other than EMTs and ARTs and is the native asset of the Hyperliquid blockchain, according to the DTI FFG shown in section F.14, as of 2026-09-04. The supply of the crypto-asset is limited to 1,000,000,000 units. The first activity of the crypto-asset can be viewed on 2024-11-29 (token address: 0x0d01dc56dcaaca66ad901c959b4011ec, source: https://app.hyperliquid.xyz/explorer/token/0x0d01dc56dcaaca66ad901c959b4011ec, accessed 2026-09-04).
According to publicly available information, Hyperliquid is a layer-1 blockchain built with the objective of a fully on-chain open financial system. The network combines fully on-chain perpetual futures and spot order books with a general-purpose smart contract environment and is secured by a delegated proof-of-stake consensus mechanism in which validators participate by staking HYPE. HYPE is used to pay transaction fees on the network, to stake to validators, and in connection with staking-linked trading fee discounts and asset deployment fees. A portion of protocol revenue is directed to an on-chain mechanism that purchases HYPE and permanently removes it from circulation.
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, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937. The admission to trading is not accompanied by a public offer of the crypto-asset.
Part A – Information about the offeror or the person seeking admission to trading
A.1 Name
A.2 Legal form
A.3 Registered address
A.4 Head office
A.5 Registration date
A.6 Legal entity identifier
A.7 Another identifier required pursuant to applicable national law
A.8 Contact telephone number
A.9 E-mail address
A.10 Response time (Days)
A.11 Parent company
A.12 Members of the management body
| Identity | Function | Business Address |
|---|---|---|
A.13 Business activity
Crypto Risk Metrics GmbH is a technical service provider 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 preliminary unaudited management information for the financial year 2025, revenues are expected to have exceeded EUR 800,000, while preliminary net profit is expected to exceed EUR 100,000.
These figures are not audited and are not based on a finalised annual financial statement. Accordingly, they remain subject to finalisation and may differ from the figures ultimately reported in the annual financial statements.
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 GmbH 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
Hyper Foundation was established to support the growth of the Hyperliquid network and its ecosystem, and it organised the genesis distribution of the crypto-asset, setting the eligibility criteria and the amounts distributed. It supports the development of the network's open-source layer-1 protocol, applies an allocation of the crypto-asset to grants, educational initiatives and partnerships, and participates in the network's on-chain governance.
B.12 Parent company business activity
Not applicable.
Part C – Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
C.1 Name
C.2 Legal form
C.3 Registered address
C.4 Head office
C.5 Registration date
C.6 Legal entity identifier
C.7 Another identifier required pursuant to applicable national law
C.8 Parent company
C.9 Reason for crypto-asset white paper preparation
C.10 Members of the management body
C.11 Operator business activity
C.12 Parent company business activity
C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
Part D – Information about the crypto-asset project
D.1 Crypto-asset project name
D.2 Crypto-assets name
D.3 Abbreviation
D.4 Crypto-asset project description
According to publicly available information, Hyperliquid is a layer-1 blockchain designed to run financial applications on-chain (sources: https://hyperliquid.gitbook.io/hyperliquid-docs/about-hyperliquid and https://hyperfoundation.org, accessed 2026-09-04). Its stated objective is to provide infrastructure on which trading, lending and the issuance of assets take place on a single network rather than across separate systems.
The network has two execution environments sharing one state. HyperCore runs order books for perpetual futures and spot trading, with orders, funding and liquidations recorded on-chain. HyperEVM is compatible with the Ethereum Virtual Machine and runs applications built by third parties, which can interact with the order books on HyperCore. The network operates the HyperBFT consensus mechanism and, as at 2026-09-04, a set of 27 active validators. Assets from other networks are brought onto Hyperliquid through bridging protocols operated by third parties, which are not operated by the persons named in this white paper.
HYPE is the native asset of the network and is used to pay transaction fees on HyperEVM, to stake to validators and to vote in on-chain governance. It does not represent a claim against Hyper Foundation or any other person, and confers no ownership or profit participation.
The long-term evolution of the project depends on governance outcomes and technical, economic and regulatory considerations, and 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 HYPE 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.
There is no single formally published roadmap for the HYPE crypto-asset; project plans and historical developments are communicated through the project's technical documentation, its improvement proposals and its public announcements (sources: https://hyperliquid.gitbook.io/hyperliquid-docs/about-hyperliquid, https://hyperliquid.gitbook.io/hyperliquid-docs/hyperliquid-improvement-proposals-hips and https://x.com/HyperliquidX, accessed 2026-09-04).
Past milestones:
- Launch of the Hyperliquidity Provider vault (2023-05-17): an on-chain vault running market-making strategies on the exchange, in which any person may provide liquidity and share in the results, and which charges no fees.
- Permissionless spot deployment (2024-05-24): the HIP-1 and HIP-2 mechanisms went live on mainnet, enabling any person to deploy a spot token on the network with an integrated on-chain liquidity mechanism.
- Genesis event of HYPE (2024-11-29): announced by the issuer on 28 November 2024 and conducted at 07:30 UTC on 29 November 2024. The maximum supply was set at 1,000,000,000 units, of which 310,000,000 were distributed fully unlocked to eligible participants; the genesis distribution strictly excluded core contributors.
- Launch of native staking (2024-12-30): delegated proof-of-stake staking of HYPE went live on the network, with 16 validators available at launch.
- Native multi-signature transactions (2025-02-12): the network began to support transactions signed collectively by several wallets for a single address.
- Initial mainnet release of the HyperEVM (2025-02-18): general-purpose smart contract functionality compatible with the Ethereum Virtual Machine was enabled on the network.
- Permissionless validator set (2025-04-21): the validator set became permissionless, so that any person may register a validator, with the active set determined by the amount of HYPE staked. Validators must self-delegate 10,000 HYPE, locked for one year.
- Delegation programme of the issuer (2025-04): the issuer began staking HYPE from its own budget to selected validators, with the initial delegations rolled out in April and May 2025.
- New fee system and staking tiers (2025-05-05): trading fee discounts tied to the amount of HYPE staked were introduced.
- Builder-deployed perpetual markets under HIP-3 (2025-10-13): any person staking 500,000 HYPE became able to deploy an independent perpetual futures market on the network, choosing its oracle, contract specifications and fee share, with that stake subject to reduction by validator vote in the event of malicious market operation.
- Outcome markets under HIP-4 (2026-05-02): fully collateralised contracts settling within a fixed range were added to the network's order books, beginning with a recurring binary contract on the price of Bitcoin.
Future milestones:
- Fees on outcome markets, which are currently zero, are to be enabled.
- Support for multi-outcome markets, which did not form part of the initial release of HIP-4, and the staged addition of further features and markets.
- Improvements to the handling of the linked order books used by outcome markets, stated to be intended for a future network upgrade.
- A reduction over time of the amount of HYPE that a person must stake in order to deploy a perpetual futures market, as the supporting infrastructure matures.
- An increase over time in the number of validators in the active set, following testing.
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 HYPE crypto-asset for its holders.
D.9 Resource allocation
The crypto-asset project has not raised capital from external investors. The project states that its development has been funded entirely from its own resources, without venture capital or other external capital, and that no allocation of the crypto-asset was made to private investors, to centralised exchanges or to market makers. No seed round, private placement, public sale or comparable fundraising has been identified (source: https://hyperliquid.gitbook.io/hyperliquid-docs/about-hyperliquid/hyperliquid-101-for-non-crypto-audiences, accessed 2026-09-04).
The project is instead funded from the fees generated by its own operation. Fees are charged on trading and on certain protocol actions and are not retained by any company: 99% of the fees generated by the protocol are applied to the automatic acquisition of the crypto-asset on the open market, and the crypto-assets so acquired are held at a system address that cannot be accessed without a change to the protocol. As at 2026-09-04 that address held 47,008,505 units acquired at a cumulative cost reported by the protocol of approximately USD 1,276,000,000, which indicates the scale of the fee revenue applied in this way since the network began operating (sources: https://hyperliquid.gitbook.io/hyperliquid-docs/trading/fees and https://app.hyperliquid.xyz/explorer/address/0xfefefefefefefefefefefefefefefefefefefefe, accessed 2026-09-04).
Public sources indicate that cumulative protocol revenue passed USD 1,000,000,000 on 30 June 2026, in the period of approximately nineteen months after the crypto-asset was created, and that revenue for the twelve months to September 2026 was of the order of USD 700,000,000. Those figures are compiled by third parties on differing definitions of revenue and are indicative only.
The persons named in this white paper have not independently confirmed the occurrence, precise amounts or current status of these reported figures. As a result they cannot be independently verified and should be considered indicative only. Changes in the resources available to the project can negatively impact the investor.
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
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
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 crypto-asset 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 transaction 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 interest. Due to the broad audience this white paper addresses, 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
HYPE is the native asset of the Hyperliquid layer-1 blockchain and has three protocol-level functions: paying transaction fees on the network's EVM-compatible execution environment, staking, and voting in on-chain governance (sources: https://hyperliquid.gitbook.io/hyperliquid-docs/trading/fees and https://hyperliquid.gitbook.io/hyperliquid-docs/hypercore/staking, accessed 2026-09-04).
HYPE is the gas asset of HyperEVM, and both the base fee and any priority fee paid for a transaction there are burned. Trading on the network's native order books is charged as a percentage of the volume traded and is not paid in HYPE.
Holders may stake HYPE by delegating it to a validator under a delegated proof-of-stake model, for which the protocol pays rewards in HYPE at a rate that falls as the total amount staked rises. Staked HYPE is subject to a queue of seven days on unstaking, and it may be reduced by penalties imposed on a validator for conduct such as double-signing. Staking also entitles the staker to a discount on trading fees, on a scale set by the protocol.
Staked HYPE carries voting rights in the network's improvement proposal process, in which proposals are decided by stake-weighted vote. Holders who do not stake do not vote. These technical possibilities do not constitute enforceable rights.
The HYPE token does not confer ownership, profit participation, governance rights over the issuer or any related entity in a corporate-law sense, or any form of legally enforceable economic entitlement. All functionalities are technical in nature and relate exclusively to interactions within the Hyperliquid protocol environment. The actual usability of HYPE depends on factors such as system stability, governance decisions, development progress and the operational conditions of the Hyperliquid blockchain, which are outside the control of token holders.
F.3 Planned application of functionalities
Future milestones:
- Fees on outcome markets, which are currently zero, are to be enabled.
- Support for multi-outcome markets, which did not form part of the initial release of HIP-4, and the staged addition of further features and markets.
- Improvements to the handling of the linked order books used by outcome markets, stated to be intended for a future network upgrade.
- A reduction over time of the amount of HYPE that a person must stake in order to deploy a perpetual futures market, as the supporting infrastructure matures.
- An increase over time in the number of validators in the active set, following testing.
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 HYPE 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 is a crypto-asset other than an EMT or an ART and is issued on the Hyperliquid network, where it is divisible to eight decimal places. The crypto-asset is fungible, so each unit is interchangeable with every other unit. It is a digital representation of value recorded by means of distributed ledger technology and confers no ownership rights, governance rights, profit participation or any other legally enforceable rights against any person. Any functionalities associated with the crypto-asset are technical or operational in nature, relate to interactions within the Hyperliquid protocol environment, and may be changed by future development or governance decisions. The crypto-asset represents no claim against any person and is not backed by any asset, so its value is determined by supply and demand in the market.
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 future offers to the public of crypto-assets was not available at the time of writing this white paper (2026-09-04).
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 in the context of an application for admission to trading on a trading platform established in the European Union. Accordingly, this white paper shall be governed by the laws of the Federal Republic of Germany.
G.19 Competent court
Any disputes arising in relation to this white paper or the admission to trading may be brought before the competent courts in Hamburg, Germany.
Part H – information on the underlying technology
H.1 Distributed ledger technology (DLT)
The crypto-asset in scope is implemented on the Hyperliquid network 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 the Hyperliquid network.
The following applies to Hyperliquid:
1. Network and token standard
Hyperliquid is a layer-one blockchain built for the purpose of operating financial markets on the network itself. Its native crypto-asset is HYPE. Tokens issued natively on Hyperliquid follow the network's own token standard, under which the name of a token, the number of decimal places it can be divided into, its maximum supply and any balances created at launch are fixed when the token is created and cannot be changed afterwards. Tokens may also be recorded on the network as representations of assets issued on other networks, in which case they reach Hyperliquid through a bridge operated by a third party rather than through the network's own token standard.
2. The two parts of the network
The network has two parts, which share one record of transactions and one set of validators. The first, HyperCore, holds the order books on which the network's spot and derivatives markets trade. The second, HyperEVM, is a general-purpose environment in which third parties can deploy their own applications, and in which HYPE is used to pay transaction fees. HyperEVM is not a separate blockchain, and moving a token between the two parts is a transfer within the same network rather than a transfer across a bridge to another network.
3. Changes to the network
Changes and additions to the functionality of the network are published as Hyperliquid Improvement Proposals by the network's core contributors.
H.3 Technology used
The crypto-asset that is the subject of this white paper is available on the Hyperliquid network.
The following applies to Hyperliquid:
1. Record of transactions
The network keeps a single record of transactions which every participant can read and which all validators agree on. Balances are held against addresses on that record. Trading takes place on the network itself: the placing, amendment, cancellation and execution of orders, and the closing of positions, are all recorded on the network rather than on a separate system operated off it. Once recorded, a transaction is final and cannot be reversed.
2. Speed and capacity
The network is built for the speed that trading requires. According to the project's documentation, a user who submits an order typically receives confirmation within a fraction of a second, and the network can process in the order of 200,000 orders per second.
3. Control of holdings
A transaction is authorised by a signature made with the private key that controls the address concerned. Users are responsible for keeping control of the private keys and recovery material of their wallets. If a private key is lost, stolen or otherwise compromised, access to the crypto-assets held at that address may be lost permanently, and the network provides no means of reversing this.
4. Operating the network
The software needed to operate a node on the network is published, and anyone may run one.
H.4 Consensus mechanism
The crypto-asset that is the subject of this white paper is available on the Hyperliquid network.
The following applies to Hyperliquid:
The network is secured by a consensus mechanism called HyperBFT. It belongs to the family of mechanisms designed to keep a network in agreement even where some of the participants in that agreement fail or act dishonestly, and it is built for speed.
The mechanism is a form of proof of stake with delegation. Holders of HYPE, the network's native crypto-asset, commit it to a validator of their choice, which is known as staking or delegating. Validators propose and confirm the transactions to be added to the record, and the more HYPE that is staked to a validator, the more of that work it performs. The validators that carry out this work at any time are the twenty-seven with the largest amount staked to them. A transaction becomes final once validators representing more than two thirds of all staked HYPE have agreed on it, so the mechanism is secure for as long as validators holding more than two thirds of the total amount staked act honestly. The choice of validator made by a person staking HYPE therefore bears directly on the security of the network.
Validators are subject to two forms of discipline. A validator that becomes slow or unresponsive can be suspended from the mechanism by a vote of the other validators, in which case it earns nothing for itself or for those who have staked to it until the problem is resolved. Separately, the mechanism provides for a validator to lose part of the HYPE staked to it where it can be proved to have acted dishonestly, although the project's documentation states that this is not currently applied automatically. Validators also vote on certain operational matters, including the removal of a derivatives market from the network.
H.5 Incentive mechanisms and applicable fees
The crypto-asset that is the subject of this white paper is available on the Hyperliquid network.
The following applies to Hyperliquid:
1. Rewards for securing the network
Validators receive HYPE rewards for confirming transactions. Rewards are based on the amount staked to each validator and are shared with holders who stake their HYPE to that validator. Rewards accumulate continuously, are paid out daily and are automatically added to the amount staked. The rate of reward falls as the total amount staked across the network rises: at a total of 400,000,000 units staked it is approximately 2.37% per year. These rewards are paid out of a reserve of HYPE set aside for future distribution, and not out of the fees described below. A validator may keep a share of the rewards of those who stake to it as a commission, and is limited in its ability to increase that share afterwards.
Staking is subject to holding periods. A validator must itself stake 10,000 units to become active, and that amount is locked for one year. An amount staked to a validator is locked for one day. Withdrawing an amount from staking takes seven days.
2. Fees
Three kinds of fee apply on the network. Trading on the network's markets is charged as a percentage of the value traded. The rate depends on whether the user places an order that waits on the order book or one that executes against orders already there, and it falls as the user's trading volume rises and as the amount of HYPE the user has staked rises. The rates themselves are set by a schedule published by the project and are subject to change. Transactions in the part of the network in which third parties deploy their own applications are charged a fee payable in HYPE. Creating a new token on the network carries a one-off charge, also payable in HYPE, set by an auction that runs for a limited period.
Fees are not used to remunerate validators. Trading fees are applied to the pool of crypto-assets that provides liquidity to the network's markets, to an address controlled by the protocol itself, and to the operators of the markets on which the fees arise, who may keep up to half of the fees generated by their own markets. The fees paid in HYPE for transactions in the applications environment are destroyed.
H.6 Use of distributed ledger technology
H.7 DLT functionality description
Not applicable, as the DLT is not operated by the issuer, the offeror, the person seeking admission to trading, or any third party acting on their behalf.
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 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. Crypto-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
The network on which the crypto-asset is recorded is permissionless. Any person able to transact on it may do so without the involvement, consent or knowledge of the persons named in this white paper, none of whom is able to prevent a third party from transferring crypto-assets across the network. Public reporting of 1 September 2026, resting on the analysis of a blockchain analytics provider, attributed transfers of approximately USD 30,000,000 in crypto-assets routed through the network and through an associated third-party bridging protocol between July and August 2026 to wallet addresses linked to a threat actor (publicly reported as linked to North Korea’s Lazarus Group) designated under the sanctions programme of a third country. The transfers reported concerned crypto-assets other than the crypto-asset described in this white paper, and no enforcement action, supervisory measure or investigation in relation to the network, the bridging protocol or any person named in this white paper has been reported. Attributions of this kind are inferences drawn from publicly available on-chain data by third parties and have not been independently verified. Where a network is used, or is reported to be used, to transfer the proceeds of crime or to circumvent sanctions, this may result in adverse publicity, in a reduced willingness of crypto-asset service providers and credit institutions to support the network or the crypto-asset, in the crypto-asset being restricted, suspended or removed from trading on the platforms on which it is traded, and in regulatory or supervisory attention, including measures addressed to the network or to the services built on it rather than to individual wallet addresses. Any of those consequences may reduce demand for the crypto-asset and affect its market value.
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
The regulatory standing of the interfaces through which the crypto-asset is principally traded has been the subject of a public statement by an authority outside the Union. On 21 May 2026, and as last updated on 7 June 2026, the Financial Conduct Authority of the United Kingdom published an entry under the name "Hyperliquid" on its public list of firms operating without authorisation, identifying the project's principal website and its trading application as the websites concerned. The entry states that the firm may be providing or promoting financial services or products without that authority's permission, that it is not authorised by that authority and may be targeting persons in the United Kingdom, and that persons dealing with it would have no access to the Financial Ombudsman Service and no protection under the Financial Services Compensation Scheme. The entry identifies no legal entity and records neither a finding of fraud or other misconduct nor the imposition of any penalty or restriction; it is a warning to consumers about the absence of authorisation in that jurisdiction. It concerns the position under the law of the United Kingdom only and neither states nor implies anything about the position under the law of the European Union or of any Member State.
Prospective holders should nonetheless take account of the possibility that authorities in other jurisdictions, including in the Union and in the Member State in which the crypto-asset is admitted to trading, may take a comparable view of the services offered through those websites, and that public warnings, orders or other administrative measures may follow. What matters for a holder of the crypto-asset is less the availability of any particular website than the effect of such measures on the channels through which the crypto-asset may be acquired, held and disposed of. A crypto-asset service provider authorised in the Union operates an approval process for the crypto-assets it admits to trading and applies rules for the suspension and removal of a crypto-asset from trading, and a public warning by a competent authority concerning the project or the services associated with it is a factor capable of being taken into account in either. Such a provider may therefore decline to admit the crypto-asset to trading, restrict or suspend trading in it, or remove it from trading, and custodians, credit institutions and other counterparties may decline to provide services in relation to it. The number of regulated venues on which the crypto-asset can be bought or sold may fall, spreads may widen, and holders may be unable to dispose of their holdings at an observable price, or at all, through providers authorised in the Union. Restrictions of that kind are addressed to the persons providing crypto-asset services and not to the holder, and neither they nor Regulation (EU) 2023/1114 prohibit a holder from acquiring, holding or transferring the crypto-asset. A holder who trades outside the providers authorised in the Union, whether with a provider established in a third country or through an arrangement that operates without an intermediary, is nonetheless outside the safeguards of that Regulation: the requirements on the safekeeping of clients' crypto-assets and funds, on complaints handling and on conflicts of interest do not apply, no investor-compensation or deposit-guarantee scheme is available, and the counterparty may itself be subject to supervisory measures which may affect the holder's ability to reach its holdings. Holders remain responsible for compliance with the law applicable to them, which in some jurisdictions restricts dealings in crypto-assets. Any of those consequences may reduce demand for the crypto-asset and affect its market value.
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 crypto-asset
S.4 Consensus Mechanism
The crypto-asset that is the subject of this white paper is available on the Hyperliquid network.
The following applies to Hyperliquid:
The network is secured by a consensus mechanism called HyperBFT. It belongs to the family of mechanisms designed to keep a network in agreement even where some of the participants in that agreement fail or act dishonestly, and it is built for speed.
The mechanism is a form of proof of stake with delegation. Holders of HYPE, the network's native crypto-asset, commit it to a validator of their choice, which is known as staking or delegating. Validators propose and confirm the transactions to be added to the record, and the more HYPE that is staked to a validator, the more of that work it performs. The validators that carry out this work at any time are the twenty-seven with the largest amount staked to them. A transaction becomes final once validators representing more than two thirds of all staked HYPE have agreed on it, so the mechanism is secure for as long as validators holding more than two thirds of the total amount staked act honestly. The choice of validator made by a person staking HYPE therefore bears directly on the security of the network.
Validators are subject to two forms of discipline. A validator that becomes slow or unresponsive can be suspended from the mechanism by a vote of the other validators, in which case it earns nothing for itself or for those who have staked to it until the problem is resolved. Separately, the mechanism provides for a validator to lose part of the HYPE staked to it where it can be proved to have acted dishonestly, although the project's documentation states that this is not currently applied automatically. Validators also vote on certain operational matters, including the removal of a derivatives market from the network.
S.5 Incentive Mechanisms and Applicable Fees
The crypto-asset that is the subject of this white paper is available on the Hyperliquid network.
The following applies to Hyperliquid:
1. Rewards for securing the network
Validators receive HYPE rewards for confirming transactions. Rewards are based on the amount staked to each validator and are shared with holders who stake their HYPE to that validator. Rewards accumulate continuously, are paid out daily and are automatically added to the amount staked. The rate of reward falls as the total amount staked across the network rises: at a total of 400,000,000 units staked it is approximately 2.37% per year. These rewards are paid out of a reserve of HYPE set aside for future distribution, and not out of the fees described below. A validator may keep a share of the rewards of those who stake to it as a commission, and is limited in its ability to increase that share afterwards.
Staking is subject to holding periods. A validator must itself stake 10,000 units to become active, and that amount is locked for one year. An amount staked to a validator is locked for one day. Withdrawing an amount from staking takes seven days.
2. Fees
Three kinds of fee apply on the network. Trading on the network's markets is charged as a percentage of the value traded. The rate depends on whether the user places an order that waits on the order book or one that executes against orders already there, and it falls as the user's trading volume rises and as the amount of HYPE the user has staked rises. The rates themselves are set by a schedule published by the project and are subject to change. Transactions in the part of the network in which third parties deploy their own applications are charged a fee payable in HYPE. Creating a new token on the network carries a one-off charge, also payable in HYPE, set by an auction that runs for a limited period.
Fees are not used to remunerate validators. Trading fees are applied to the pool of crypto-assets that provides liquidity to the network's markets, to an address controlled by the protocol itself, and to the operators of the markets on which the fees arise, who may keep up to half of the fees generated by their own markets. The fees paid in HYPE for transactions in the applications environment are destroyed.
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: Hyperliquid is calculated first. A proportionate share of that energy use is then attributed to the token based on its activity level within the network (e.g. transaction volume, contract execution).
The Functionally Fungible Group Digital Token Identifier (FFG DTI) is used to determine all technically equivalent implementations of the crypto-asset in scope.
Estimates regarding hardware types, node distribution, and the number of network participants are based on informed assumptions, supported by best-effort verification against available empirical data. Unless robust evidence suggests otherwise, participants are assumed to act in an economically rational manner. In line with the precautionary principle, conservative estimates are applied where uncertainty exists – that is, estimates tend towards the higher end of potential environmental impact.
S.10 Renewable energy consumption
S.11 Energy intensity
S.12 Scope 1 DLT GHG emissions – Controlled
S.13 Scope 2 DLT GHG emissions – Purchased
S.14 GHG intensity
S.15 Key energy sources and methodologies
To determine the proportion of renewable energy usage, the locations of the nodes are determined using public information sites, open-source and in-house-developed crawlers. Where no information is available on the geographic distribution of nodes, comparable reference networks are used, taking into account similarities in incentivisation structure and consensus mechanism. This geographic information is then combined with publicly available data from Our World in Data. The resulting intensity is calculated as the marginal energy consumption with respect to one additional transaction.
Ember (2025); Energy Institute, Statistical Review of World Energy (2024), with major processing by Our World in Data. “Share of electricity generated by renewables - Ember and Energy Institute” [dataset]. Underlying sources: Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy”. Retrieved from: https://ourworldindata.org/grapher/share-electricity-renewables
S.16 Key GHG sources and methodologies
To determine GHG emissions, the locations of the nodes are determined using public information sites, open-source crawlers, and crawlers developed in-house. Where no information is available on the geographic distribution of nodes, comparable reference networks are used, taking into account similarities in incentivisation structure and consensus mechanism. This geographic information is then combined with publicly available data from Our World in Data. The resulting intensity is calculated as the marginal emission intensity with respect to one additional 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]. Underlying sources: Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy”. Retrieved from: https://ourworldindata.org/grapher/carbon-intensity-electricity. Licensed under CC BY 4.0.