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  • Writer's pictureадв. Светослав Григоров

Obligations of an issuer of asset-referenced tokens

Updated: Jun 13, 2023

Asset-referenced token issuers act with integrity, impartiality, and professionalism. Communicates with token holders in an unbiased, clear, and non-misleading manner.

It acts in the interests of holders and they are treated equally, except where preferential treatment is provided in the crypto-asset white paper and marketing communications.

Publish the crypto-asset white paper and marketing messages as obligations of an issuer of asset-referenced tokens

The issuer shall publish on its website the approved white paper for the crypto-asset, the amended white paper, as well as the marketing communications. The information remains publicly available from the start of the public offering of the tokens or their admission to trading on a trading platform. They remain available for the entire period that the tokens are held publicly.

Marketing communications

Meet the following requirements:

- are clearly recognised as such;

- the information is objective, clear, and non-misleading;

- the information corresponds to what is described in the white paper;

- indicates the website where the white paper is published.

When the right of direct claim or redemption is not granted to all token holders, it is mentioned that all holders have no right of claim against the reserve assets or cannot request redemption at any time.

Current information provided to token holders

At least once a month, the issuer publishes on its website the number of tokens in circulation and the value and composition of reserve assets.

The result of the audit of reserve assets will be announced shortly. Any information that would affect the value of tokens or reserve assets is published.

Complaints Procedure

The token issuer shall establish procedures for handling complaints submitted by holders. When the distribution is through third parties, the procedure goes through them.

The issuer provides customers with a complaint form, keeping all received complaints and responses to them. The procedure is free for holders and ends within a reasonable time.


The token issuer implements a policy to prevent conflicts of interest.

The issuer shall notify the competent authorities of any change in its governing body.

Management rules

The token issuer establishes governance rules. The members of the governing body have a good reputation and competence, experience, skills, and time to perform their duties. Persons holding more than 20% of the shares or voting rights must be of good standing and competence. They cannot be convicted of money laundering, terrorist financing, or other financial crimes.

Issuers shall adopt policies and procedures to comply with the provisions of the Regulation, specifically for:

- a reserve of assets and their custody;

- rights granted and not granted to holders;

- the emission, creation, and destruction mechanism;

- self-designed distributed ledger technology;

- the method of ensuring the redemption of the tokens or their liquidity;

- agreements with third parties regarding the management of the reserve of assets, investment, custody, and distribution among their holders;

- the consideration of complaints;

- conflicts of interest;

- the liquidity management policy for meaningful tokens.

Issuers implement systems, resources, and procedures for the continuous and regular performance of their services and activities. Minimize operational risks. In the event of a business interruption, they guarantee the preservation of the most important functions and quick recovery.

Issuers implement internal control and risk assessment procedures and ensure the security and confidentiality of information. They are regularly independently audited.

EBA and ESMA approve standards for the minimum content of management rules on:

- risk monitoring tools;

- the internal control mechanism;

- the business continuity plan;

- the audits.

Capital requirements

The issuers have at all times owned funds equal to at least EUR 350,000 or 2% of the average amount of reserve assets, at the end of each calendar day, for the previous 6 months.

Regarding the obligations of an issuer of asset-referenced tokens, please contact us by going to contacts.

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