White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG 1HZHK551M
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 DYDX crypto-asset referred to in this white paper is a crypto-asset other than an asset-referenced token or e-money token. DYDX is the native layer-1 asset of the dYdX Chain and is also available on the Osmosis network, according to the DTI FFG shown in section F.14, as of 2026-09-09. The dYdX Chain validators created its first block on 2023-10-26 (source: https://www.mintscan.io/dydx/block/1, accessed 2026-09-09). On the Osmosis network, DYDX is represented through the Inter-Blockchain Communication (IBC) protocol rather than by a deployed contract. The transfer channel connecting the two networks, channel-3 on the dYdX Chain side paired with channel-6787 on the Osmosis side, was created on 2023-10-30 (source: https://www.mintscan.io/dydx/relayers/channel-3/osmosis/channel-6787, accessed 2026-09-09). Units of that denomination are created on Osmosis when DYDX is transferred from the dYdX Chain and are destroyed when it is transferred back. The total supply of DYDX is 1,000,000,000, and the dYdX Chain records that supply in full (source: https://www.mintscan.io/dydx/assets, accessed 2026-09-09). The amount recorded on Osmosis at any time forms part of that supply and is not additional to it.
The crypto-asset was previously deployed on the Ethereum network as an ERC-20 token, now referred to as ethDYDX, which has not been convertible into DYDX on the dYdX Chain since dYdX Chain governance ceased support for the bridge on 2025-06-13 (source: https://docs.dydx.community/dydx-token-migration/dydx-token-migration/cessation-of-support-for-the-wethdydx-smart-contract, accessed 2026-09-09).
The dYdX Chain is a proof-of-stake blockchain built with the Cosmos SDK and CometBFT. It operates a decentralised exchange for spot and perpetual futures trading, in which orders are matched by the network's validators and the resulting trades are settled on the chain (source: https://docs.dydx.community/dydx, accessed 2026-09-09).
DYDX is used to pay DYDX-denominated transaction fees, to bond or delegate stake to validators and to participate in on-chain governance. Staking is subject to validator performance, slashing and a 21-day unbonding period. Holding DYDX does not entitle the holder to any share in the revenue, profits or assets of any entity.
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
Not applicable.
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 (source: https://docs.dydx.community/dydx, accessed 2026-09-10), dYdX is a decentralised trading protocol that runs on its own proof-of-stake blockchain, the dYdX Chain, built with the Cosmos SDK and using CometBFT for consensus. Its stated objective is to make open order-book trading available on-chain, with users retaining control of their assets in their own wallets rather than placing them with an operator.
The protocol supports perpetual futures markets and spot markets. Orders are held and matched by the network's validators, which record trades, collateral, funding and liquidations on the chain (source: https://docs.dydx.xyz, accessed 2026-09-10). New markets can be listed without a prior governance vote. A pooled liquidity facility allows users to deposit USDC and receive a share of the returns from automated market making across markets, where returns are not guaranteed and depositors bear the market risk of the positions taken. Indexers, application programming interfaces, wallets and the websites through which users reach the protocol are separate components and may be operated independently of one another.
The software is open source and is developed through public repositories. Protocol parameters, market settings, software upgrades and spending from the community treasury are decided by on-chain governance, and further operational structures are funded through it. The entities and structures connected to the project are legally and operationally separate from one another, and the crypto-asset does not represent ownership of, profit participation in, or any legal claim against any of them.
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 DYDX 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 DYDX token; project plans and past developments are communicated through the project's technical and governance documentation, its governance forum and on-chain proposals, and the publications of the dYdX Foundation and dYdX Labs (sources: https://docs.dydx.community/dydx/start-here/dydx-token-allocation, https://www.dydx.foundation/blog, https://www.dydx.xyz/blog, accessed 2026-09-09).
Past milestones:
- Project foundation (2017-07-27): the project was founded to build protocols for margin trading and derivatives on the Ethereum network. Development at that stage concerned smart contracts on Ethereum only and no crypto-asset had been created.
- First protocol deployments on Ethereum (2018 to 2019): a margin trading protocol and a consumer-facing brokerage application were deployed, followed by a second-generation lending and margin protocol and the project's own order-book trading system, all recorded on Ethereum.
- Perpetual contracts (2020-04): a protocol for perpetual contracts was launched on Ethereum, initially for a single market and subsequently extended to further markets.
- Migration to a Layer 2 protocol (2021-04): the trading protocol was moved off the Ethereum base layer to a Layer 2 protocol based on zero-knowledge rollup technology, in order to address transaction cost and throughput constraints. This deployment is referred to by the project as dYdX v3 and remained an Ethereum-based deployment.
- Introduction of the DYDX crypto-asset (2021-08-03): a total of 1,000,000,000 DYDX was minted on Ethereum as a governance token for the Layer 2 protocol, in the form later referred to as ethDYDX. The initial transfer restrictions were lifted on 2021-09-08, from which date the crypto-asset became transferable.
- Publication of plans for a standalone chain (2022): plans were published for a fourth version of the protocol taking the form of a standalone proof-of-stake blockchain rather than a deployment on Ethereum, with the stated objective of full decentralisation of the order book and matching.
- Native chain launch (2023-10-26): validators created the first block of the dYdX Chain and native DYDX became the proof-of-stake and governance asset of that chain.
- Sunset of the Ethereum-based deployment (2024-10-28): trading, oracle price updates and funding payments on the dYdX v3 Layer 2 deployment ceased.
- dYdX Unlimited (2024-11): permissionless market listings and a pooled liquidity provision facility were introduced to the dYdX Chain software.
- Buyback programme launch (2025-04-23): governance established a recurring programme applying a share of net protocol revenue to open-market purchases of DYDX, with the purchased crypto-assets staked. The share was set initially at 12.5% of net protocol revenue and increased to 25% by a subsequent proposal.
- Migration closure (2025-06-13): validators ended support for the bridge from ethDYDX to native DYDX. Unbridged ethDYDX can no longer be converted into native DYDX.
- Removal of protocol-level trading rewards (2025-09): governance set the trading rewards parameter to zero, ending protocol-level trading rewards and consolidating incentive activity under a separate rewards programme funded by governance decision.
- Revenue-allocation change (2025-11): governance increased the share of net protocol revenue directed to the buyback account to 75%.
- Launch of a separate exchange by the development company (2026-06-30): dYdX Labs announced the launch of a next-generation decentralised exchange built jointly with a third party on a separate network, incubated at dYdX Labs and operating under its own management, and stated that its development focus had moved to that venture. In the same announcement it stated that the dYdX Chain would continue to be supported and that positions and funds on it remain accessible. The dYdX Foundation has stated that the dYdX Chain is unaffected and continues to be governed by its token holders, secured by its validators and owned by its community.
Future milestones:
- The dYdX Chain remains community-governed and upgradeable through on-chain proposals. Governance discussions may concern protocol upgrades, market changes, treasury activity, incentives and revenue allocation.
- DYDX purchased under the buyback programme is staked. The allocation percentage and the execution mandate remain subject to governance.
- The subDAOs responsible for treasury management and for operational infrastructure continue to operate under their existing mandates, with funds deployed only by community decision.
- In connection with the separate exchange launched in June 2026, the development company has stated an intention to reserve an allocation of any future crypto-asset of that venture for the dYdX community, and to prioritise access for participants in dYdX. No such crypto-asset exists at the date of this white paper, no terms have been published, and no assurance can be given that any allocation will be made or that any holder of DYDX would be eligible for it.
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 DYDX crypto-asset for its holders.
D.9 Resource allocation
Based on information from various third-party and industry sources, it is reported that the crypto-asset project associated with the DYDX token and the dYdX exchange has conducted multiple funding rounds involving seed and venture capital financing.
According to publicly referenced information, dYdX raised approximately USD 2 million in a seed financing round in 2017 at a reported valuation of approximately USD 10 million. The round was reportedly led by Andreessen Horowitz and Polychain Capital and also included participation from approximately 15 to 20 angel investors. Public sources further indicate that, in 2018, dYdX raised approximately USD 10 million in a Series A financing round at a reported valuation of approximately USD 40 million. Andreessen Horowitz and Polychain Capital were again reported as the lead investors in this round. Further public reporting indicates that, in January 2021, dYdX raised approximately USD 10 million in a Series B financing round at a reported valuation of approximately USD 80 million. Three Arrows Capital was identified as an investor in the financing. Publicly referenced information indicates that the round took place at a time when the project was seeking additional capital to extend its operational runway. In June 2021, dYdX reportedly completed a Series C financing round of approximately USD 65 million at a reported valuation of approximately USD 215 million. The round was reportedly led by Paradigm and included participation from a number of additional investors, including firms active in the digital-asset trading sector.
However, all such information is derived exclusively from public announcements, portfolio disclosures, press releases, transparency reports, and third-party publications. The issuer, foundation, or entities associated with the DYDX crypto-asset have not independently confirmed the occurrence, precise amounts, valuation, legal structure, or contractual terms of these reported financing rounds. As a result, the referenced investment amounts, investor participation, and any implied cumulative funding figures cannot be independently verified and should be considered indicative only.
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 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 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
According to publicly available information (sources: https://docs.dydx.community/dydx/start-here/dydx-token, https://docs.dydx.community/dydx/modules/distribution, https://docs.dydx.community/dydx/modules/governance, accessed 2026-09-09), DYDX is the native asset of the dYdX Chain and serves three functions within that network: it is bonded to secure the chain under its proof-of-stake consensus mechanism, it carries voting weight in on-chain governance, and it is one of two assets in which transaction fees can be paid.
Holders may operate a validator and self-delegate, or delegate their DYDX to an existing validator. The amount bonded to a validator determines whether that validator enters the active set, which is limited to a fixed number of validators, and determines its weight in consensus. Validators and their delegators share in the fees collected by the protocol each block. That fee pool consists of maker and taker trading fees, which are denominated in USDC, and transaction gas fees, which may be paid in either DYDX or USDC. Rewards are claimed by the staker rather than compounded automatically, and the share allocated to validators and stakers is set by on-chain governance and can be changed by it. Rewards are therefore variable and are not guaranteed.
Only actively staked DYDX carries voting weight, on a one-to-one basis; DYDX that is unstaked or unbonding does not. Governance decides parameter changes, spending from community-controlled accounts, software upgrades, the listing and wind-down of markets, and non-binding text proposals. A proposal enters the voting period once deposits of 2,000 DYDX in unstaked tokens have been pledged, the standard voting period is approximately three days, a quorum of 50% of staked DYDX is required, and a proposal passes on a simple majority of votes cast other than abstentions, subject to rejection where 33.4% vote to veto. An expedited procedure shortens the vote to two days against a 75% threshold. A staker who does not vote inherits the vote of its validator. All of these parameters are themselves adjustable by governance.
Protocol-level trading rewards paid in DYDX have been discontinued by governance decision. Any trading incentive programme operated in the ecosystem is established, funded and withdrawn by governance and is not an inherent function of the crypto-asset or a right attaching to it. Similarly, the function by which the earlier Ethereum-based representation could be converted into DYDX on the dYdX Chain has not been available since 2025-06-13.
The DYDX 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 dYdX protocol environment. The actual usability of DYDX depends on factors such as system stability, governance decisions, development progress and the operational conditions of the dYdX blockchain, which are outside the control of token holders.
F.3 Planned application of functionalities
Future milestones:
- The dYdX Chain remains community-governed and upgradeable through on-chain proposals. Governance discussions may concern protocol upgrades, market changes, treasury activity, incentives and revenue allocation.
- DYDX purchased under the buyback programme is staked. The allocation percentage and the execution mandate remain subject to governance.
- The subDAOs responsible for treasury management and for operational infrastructure continue to operate under their existing mandates, with funds deployed only by community decision.
- In connection with the separate exchange launched in June 2026, the development company has stated an intention to reserve an allocation of any future crypto-asset of that venture for the dYdX community, and to prioritise access for participants in dYdX. No such crypto-asset exists at the date of this white paper, no terms have been published, and no assurance can be given that any allocation will be made or that any holder of DYDX would be eligible for it.
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 DYDX 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 natively implemented on the dYdX blockchain and is also available on the Osmosis network. The crypto-asset is fungible up to 18 decimal places. 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
Based on the available information, the crypto-asset does not appear to be issued through a traditional corporate, foundation, or comparable legal entity structure. Therefore, no other services provided by a registered legal-entity issuer have been identified.
It cannot be excluded that natural persons, organised development teams, or other structures connected to the crypto-asset project provide or may provide additional services 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
Not applicable.
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 native to the dYdX blockchain and is also available on the Osmosis network. The crypto-asset follows the standards described below.
H.2 Protocols and technical standards
The crypto-asset in scope is native to the dYdX blockchain and is also available on the Osmosis network. The crypto-asset follows the standards described below.
The following applies to dYdX Chain:
The dYdX Chain is a layer-one blockchain built with the Cosmos SDK and secured by the CometBFT consensus engine. Its native crypto-asset is DYDX. The network follows Cosmos SDK conventions for account addresses, which use Bech32 encoding derived from public keys, and for transfers, staking and governance, which use the standard Cosmos SDK message types. Trading functions are provided by modules specific to this network rather than by adapted standard modules. Orders are submitted to the validators and held in memory off the ledger; only matched trades, together with the resulting positions, collateral movements and liquidations, are written to the chain. The software is open source. The network connects to other Cosmos networks through the Inter-Blockchain Communication protocol, which is how the stablecoin used as collateral and for fees reaches it.
The following applies to Osmosis:
1. Network Protocols
Osmosis is an application-specific Layer 1 blockchain built using the Cosmos SDK. Consensus and peer-to-peer networking are provided through CometBFT, formerly Tendermint Core, which implements Byzantine Fault Tolerant state-machine replication. Osmosis also supports cross-chain communication through the Inter-Blockchain Communication protocol, which enables transfers and messages between IBC-enabled chains.
2. Transaction and Address Standards
Transactions are processed through Cosmos SDK modules and may include transfers, swaps, staking, governance actions, and IBC transfers. Osmosis uses Cosmos-style account and transaction standards, including Bech32-format addresses and sequence-based account handling. IBC transfers follow the ICS-20 fungible token transfer standard.
3. Blockchain Data Structure & Block Standards
Osmosis separates consensus from application-level execution. CometBFT orders and finalises blocks, while the Osmosis application layer executes deterministic state transitions through Cosmos SDK modules. Application state is committed through cryptographic state roots included in block headers, allowing validators to agree on the resulting network state.
4. Upgrade & Improvement Standards
Protocol upgrades are coordinated through Osmosis governance and scheduled software upgrades. Validators are required to run compatible software at the relevant upgrade point. As an IBC-connected chain, Osmosis upgrades must also preserve compatibility with IBC clients, channels, and counterparty chains where applicable.
H.3 Technology used
The crypto-asset in scope is native to the dYdX blockchain and is also available on the Osmosis network. The crypto-asset follows the standards described below.
The following applies to dYdX Chain:
The network keeps a single record of transactions, balances, staking positions and governance outcomes which every participant can read and on which all validators agree. Once a transaction is recorded it is final and cannot be reversed. Balances are held against addresses on that record, and a transaction is authorised by a signature made with the private key that controls the address concerned, using elliptic curve cryptography of the secp256k1 type. Blocks are linked by SHA-256 hashing. Users hold their crypto-assets in their own wallets and are responsible for keeping control of their private keys and recovery material. If a private key or recovery phrase 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 restoring it. The software needed to operate a node is published, and anyone may run one.
The following applies to Osmosis:
1. Decentralised Ledger
Osmosis operates as a decentralised ledger that records all transactions in an append-only blockchain structure. Blocks are validated and finalised through a Byzantine Fault Tolerant consensus mechanism, with the intention of preserving an unalterable and transparent record of token transfers, liquidity pool interactions, and balances.
2. Private Key Management
To safeguard their OSMO holdings, users must securely store their wallet private keys and recovery phrases. The Osmosis protocol does not define standards for private key storage; key management is handled at the wallet or client level, including software and hardware wallets compatible with the Cosmos SDK.
3. Modular Design and Smart Contracting
Osmosis follows a modular architecture based on the Cosmos SDK. Core protocol functionality, including the AMM and liquidity pool logic, is implemented at the application layer. Additional smart-contract functionality is provided through a permissioned CosmWasm module, whereby contract deployments require on-chain governance approval, ensuring that token logic and application-level rules added to the protocol remain subject to community oversight.
H.4 Consensus mechanism
The crypto-asset in scope is native to the dYdX blockchain and is also available on the Osmosis network. The crypto-asset follows the standards described below.
The following applies to dYdX Chain:
The network is secured by a proof-of-stake mechanism with delegation. Holders of DYDX, the network's native crypto-asset, commit it to a validator of their choice, which is known as staking or delegating, and a validator may also stake its own DYDX. Validators propose blocks and confirm the transactions to be added to the record, and they also hold and match the orders described above. The validators that carry out this work at any time are those with the largest amounts staked to them, up to a maximum number of validators fixed by governance. There is no minimum amount that must be staked, and no approval is required to take part. A block is committed once validators representing more than two thirds of the total amount staked 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. Concentration of stake among a small number of validators, or a coordinated failure among them, can affect the resilience of the network. A validator that fails to sign a sufficient proportion of blocks is jailed, meaning that it is removed from the active set and earns nothing for itself or for those who have staked to it until it is reinstated, and a validator proved to have signed two conflicting blocks is permanently excluded. The parameters that would allow staked crypto-assets to be destroyed for either failure are set to zero, so neither a validator nor those who have staked to it lose staked crypto-assets as a penalty. Crypto-assets withdrawn from staking remain locked for a fixed period set by governance before they can be transferred again.
The following applies to Osmosis:
Osmosis operates a Proof-of-Stake consensus mechanism based on the Cosmos SDK and CometBFT, formerly Tendermint Core. CometBFT provides Byzantine Fault Tolerant state-machine replication for application-specific blockchains and is designed to provide deterministic finality once the required validator voting threshold is reached.
Consensus participants are validators who bond OSMO, or receive delegated OSMO from third-party token holders. Validator voting power is determined by the amount of OSMO bonded to the validator, including delegated stake. Validators participate in block production and consensus by proposing blocks and signing votes.
The active validator set is limited by protocol parameters. Current public parameter data indicates a maximum active validator set of 100 validators, following governance changes that reduced the set from 120 to 100 to improve performance and reduce consensus overhead.
Consensus proceeds through proposal and voting rounds. A block is committed once more than two-thirds of the total validator voting power has signed the relevant pre-commit for that block. This provides immediate finality and avoids probabilistic forks, provided that less than one-third of total validator voting power behaves maliciously or fails.
Osmosis also uses slashing and jailing mechanisms to support validator accountability. Current public parameter data indicates a 5% slash for double-signing, no direct slash for downtime, and a downtime jail duration of one minute. Validators that fail operational requirements may be removed from the active validator set until they rejoin in accordance with protocol rules.
H.5 Incentive mechanisms and applicable fees
The crypto-asset in scope is native to the dYdX blockchain and is also available on the Osmosis network. The crypto-asset follows the standards described below.
The following applies to dYdX Chain:
Validators, and those who stake to them, are rewarded for securing the network. No new DYDX is created for that purpose: the network pays no block reward out of newly issued units, and the rewards come instead from the fees it collects.
A transaction submitted to the network carries a fee, which may be paid in DYDX or in the stablecoin used on the network, and further fees are collected from the activity recorded on it. Before rewards are distributed, defined shares of the net fees are directed by governance to other purposes, at present a pooled liquidity facility, a treasury structure and the purchase of DYDX on the market. What remains is distributed each block to validators and to those who have staked to them, in proportion to the amount staked and after deduction of the commission the validator charges, which is subject to a minimum rate fixed for the whole network and to a maximum rate and a maximum rate of change fixed by each validator. No share is taken for a community pool before distribution. Rewards accumulate on the record and must be claimed.
The protocol also provides for rewards to be paid in DYDX out of a reserve set aside for that purpose to those who trade on the network. The multiplier governing them has been set to zero by governance, so none are currently distributed. The rates and shares applied to all of these mechanisms are published by the project and may be changed by on-chain governance.
The following applies to Osmosis:
Validator and Delegator Rewards
Validators earn rewards from transaction fees and protocol emissions for their role in securing the network and processing transactions. Rewards are distributed in OSMO tokens. Delegators who stake their OSMO tokens with validators receive a proportional share of these rewards. New OSMO tokens are issued on an epoch basis (approximately once per day) and allocated in part to staking rewards. The allocation of newly issued tokens is subject to protocol governance and may be adjusted over time.
Liquidity Provider Incentives
Users providing liquidity to Osmosis pools earn swap fees generated by trading activity and may receive additional incentives in the form of OSMO tokens. These incentives are designed to support liquidity depth and trading efficiency on the protocol. The level and structure of such incentives may be adjusted through governance.
Transaction Fees
Users pay transaction fees in OSMO tokens, or in certain whitelisted assets, for network activities including swaps, staking, and governance participation. These fees are distributed to validators and delegators, contributing to their ongoing economic incentives.
Slashing and Penalties
To discourage malicious or negligent behaviour, the protocol employs a bonded proof-of-stake model in which validators’ staked assets may be subject to slashing. Validators that engage in protocol violations, such as double-signing, may incur a reduction of their staked assets. Validators that fail to meet operational requirements, such as maintaining sufficient uptime, may be temporarily removed from the active validator set. Delegators are exposed to the risks associated with the validators to whom they delegate.
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
Interpretative note for this section: The risk factors set out in this Part I.2 follow the structure of the applicable MiCA white paper template for crypto-assets other than asset-referenced tokens or e-money tokens under Title II of MiCA, including references to issuer-related risks. For the purposes of this Part I.2, references to an “issuer”, “issuer-related risks” or similar terms should be read in line with the definition of “issuer” under MiCA, including any natural or legal person, or other undertaking, that issues crypto-assets.
Based on the available information, the crypto-asset does not appear to be issued through a traditional corporate, foundation, or comparable legal entity structure. Accordingly, the risk descriptions in this Part I.2 should be understood as referring, as applicable, to any natural persons, legal persons, undertakings, organised development teams, governance arrangements, or other project-related structures that may materially influence the crypto-asset or the related project, to the extent such persons or structures can be identified from available information.
1. Absence or insolvency of an identifiable issuer
Where an identifiable issuer exists, that issuer may face insolvency risks. These may result from insufficient funding, low market interest, mismanagement, legal or regulatory developments, or external shocks, including pandemics or armed conflicts. In such a case, ongoing development, support, communication, or governance of the crypto-asset project may be reduced, suspended, or discontinued, potentially affecting the viability, availability, market acceptance, or 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
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.
1. 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.
2. 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.
3. 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.
4. 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.
5. Dependence on continued development and maintenance. The dYdX Chain operates on open-source software. The company that developed that software has publicly stated that its development focus has moved to a separate exchange on a separate network, launched in June 2026, and has stated in the same announcement that it will continue to support the existing deployment. No entity is under any obligation to maintain, upgrade or support the software, to operate a front end or an indexer, or to propose protocol improvements. Continued development therefore depends on the willingness of contributors and on decisions taken through on-chain governance. If maintenance, upgrades or supporting infrastructure were reduced or discontinued, the functionality, security and availability of the crypto-asset and of the trading protocol on which its use depends could be materially and adversely affected.
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. Protocol and software vulnerability risk
The protocol rules, client software implementations, execution-layer and consensus-layer components, or related technical elements that define the crypto-asset's parameters or govern its transfers may contain coding errors or security vulnerabilities. Exploitation of such weaknesses can result in unintended consequences, including loss of funds, incorrect issuance or accounting of units, or disruption of network functionality. Remediation depends on the release of corrected software and, where a protocol change is required, on an on-chain governance decision and its adoption by validators, so a known vulnerability may persist for some time before it is resolved.
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 in scope is native to the dYdX blockchain and is also available on the Osmosis network. The crypto-asset follows the standards described below.
The following applies to dYdX Chain:
The network is secured by a proof-of-stake mechanism with delegation. Holders of DYDX, the network's native crypto-asset, commit it to a validator of their choice, which is known as staking or delegating, and a validator may also stake its own DYDX. Validators propose blocks and confirm the transactions to be added to the record, and they also hold and match the orders described above. The validators that carry out this work at any time are those with the largest amounts staked to them, up to a maximum number of validators fixed by governance. There is no minimum amount that must be staked, and no approval is required to take part. A block is committed once validators representing more than two thirds of the total amount staked 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. Concentration of stake among a small number of validators, or a coordinated failure among them, can affect the resilience of the network. A validator that fails to sign a sufficient proportion of blocks is jailed, meaning that it is removed from the active set and earns nothing for itself or for those who have staked to it until it is reinstated, and a validator proved to have signed two conflicting blocks is permanently excluded. The parameters that would allow staked crypto-assets to be destroyed for either failure are set to zero, so neither a validator nor those who have staked to it lose staked crypto-assets as a penalty. Crypto-assets withdrawn from staking remain locked for a fixed period set by governance before they can be transferred again.
The following applies to Osmosis:
Osmosis operates a Proof-of-Stake consensus mechanism based on the Cosmos SDK and CometBFT, formerly Tendermint Core. CometBFT provides Byzantine Fault Tolerant state-machine replication for application-specific blockchains and is designed to provide deterministic finality once the required validator voting threshold is reached.
Consensus participants are validators who bond OSMO, or receive delegated OSMO from third-party token holders. Validator voting power is determined by the amount of OSMO bonded to the validator, including delegated stake. Validators participate in block production and consensus by proposing blocks and signing votes.
The active validator set is limited by protocol parameters. Current public parameter data indicates a maximum active validator set of 100 validators, following governance changes that reduced the set from 120 to 100 to improve performance and reduce consensus overhead.
Consensus proceeds through proposal and voting rounds. A block is committed once more than two-thirds of the total validator voting power has signed the relevant pre-commit for that block. This provides immediate finality and avoids probabilistic forks, provided that less than one-third of total validator voting power behaves maliciously or fails.
Osmosis also uses slashing and jailing mechanisms to support validator accountability. Current public parameter data indicates a 5% slash for double-signing, no direct slash for downtime, and a downtime jail duration of one minute. Validators that fail operational requirements may be removed from the active validator set until they rejoin in accordance with protocol rules.
S.5 Incentive Mechanisms and Applicable Fees
The crypto-asset in scope is native to the dYdX blockchain and is also available on the Osmosis network. The crypto-asset follows the standards described below.
The following applies to dYdX Chain:
Validators, and those who stake to them, are rewarded for securing the network. No new DYDX is created for that purpose: the network pays no block reward out of newly issued units, and the rewards come instead from the fees it collects.
A transaction submitted to the network carries a fee, which may be paid in DYDX or in the stablecoin used on the network, and further fees are collected from the activity recorded on it. Before rewards are distributed, defined shares of the net fees are directed by governance to other purposes, at present a pooled liquidity facility, a treasury structure and the purchase of DYDX on the market. What remains is distributed each block to validators and to those who have staked to them, in proportion to the amount staked and after deduction of the commission the validator charges, which is subject to a minimum rate fixed for the whole network and to a maximum rate and a maximum rate of change fixed by each validator. No share is taken for a community pool before distribution. Rewards accumulate on the record and must be claimed.
The protocol also provides for rewards to be paid in DYDX out of a reserve set aside for that purpose to those who trade on the network. The multiplier governing them has been set to zero by governance, so none are currently distributed. The rates and shares applied to all of these mechanisms are published by the project and may be changed by on-chain governance.
The following applies to Osmosis:
Validator and Delegator Rewards
Validators earn rewards from transaction fees and protocol emissions for their role in securing the network and processing transactions. Rewards are distributed in OSMO tokens. Delegators who stake their OSMO tokens with validators receive a proportional share of these rewards. New OSMO tokens are issued on an epoch basis (approximately once per day) and allocated in part to staking rewards. The allocation of newly issued tokens is subject to protocol governance and may be adjusted over time.
Liquidity Provider Incentives
Users providing liquidity to Osmosis pools earn swap fees generated by trading activity and may receive additional incentives in the form of OSMO tokens. These incentives are designed to support liquidity depth and trading efficiency on the protocol. The level and structure of such incentives may be adjusted through governance.
Transaction Fees
Users pay transaction fees in OSMO tokens, or in certain whitelisted assets, for network activities including swaps, staking, and governance participation. These fees are distributed to validators and delegators, contributing to their ongoing economic incentives.
Slashing and Penalties
To discourage malicious or negligent behaviour, the protocol employs a bonded proof-of-stake model in which validators’ staked assets may be subject to slashing. Validators that engage in protocol violations, such as double-signing, may incur a reduction of their staked assets. Validators that fail to meet operational requirements, such as maintaining sufficient uptime, may be temporarily removed from the active validator set. Delegators are exposed to the risks associated with the validators to whom they delegate.
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 of this asset is aggregated across multiple components: to determine the energy consumption of a token, the energy consumption of the networks dYdX and Osmosis is calculated first. For the energy consumption of the token, a fraction of the energy consumption of the network is attributed to the token, which is determined based on the activity of the crypto-asset within the network. When calculating the energy consumption, the Functionally Fungible Group Digital Token Identifier (FFG DTI) is used, if available, to determine all implementations of the asset in scope. The mappings are updated regularly, based on data from the Digital Token Identifier Foundation. The information regarding the hardware used and the number of participants in the network is based on assumptions that are verified on a best-effort basis using empirical data. In general, participants are assumed to be largely economically rational. As a precautionary principle, we make assumptions on the conservative side when in doubt, i.e. by making higher estimates of the adverse impacts.
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.