White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG M8VRWT0GF

The crypto-asset ASSET referred to in this white paper is a crypto-asset other than EMTs and ARTs and will be issued natively on the Real blockchain network, according to the DTI FFG shown in Section F.14, as of 2026-04-20. At launch, the initial supply of the crypto-asset will be 1,000,000,000 ASSET. There is no fixed maximum supply, as the supply is expected to increase through protocol emissions, with 50,000,000 ASSET planned to be emitted during the first year.

The Real project is a decentralised Layer 1 network designed to support the tokenisation and on-chain administration of real-world assets. The network is built using the Cosmos SDK and uses a Tendermint-based Proof-of-Stake consensus model. It supports smart-contract functionality through CosmWasm and is designed to enable asset onboarding, risk scoring, insurance-related processes and settlement functions within a single blockchain environment. The project also includes interoperability features associated with the Cosmos ecosystem, including IBC-based connectivity, and uses a Bech32 address format with the prefix real1. Within the network design, technical validators operate alongside business function validators, and tokenised assets may include on-chain metadata relevant to their classification and operational status.

The crypto-asset ASSET is the native crypto-asset of the Real network and is used to pay transaction fees and smart-contract execution fees on the network. It is also used for staking in connection with the Proof-of-Stake consensus model and may be used in governance processes relating to protocol upgrades, parameter changes and ecosystem-level decisions. In addition, ASSET may be required to be staked by certain business function validators participating in asset-related verification and operational processes, and such stake may be subject to slashing in accordance with the network rules.

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.

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.

Real Technologies Inc. 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.

Design, development, implementation and maintenance of software products, information systems and digital platforms in the field of financial technology (fintech), artificial intelligence (AI), automation and data analysis; development of digital platforms for trading, payments, investment and other fintech services; research and development in the field of AI and financial technology; provision of technological, consulting, analytical and information services.

The company is registered with share capital in the amount of EUR 100,000. As the company was only recently established, it has not yet generated any revenue.

The Real Finance project is centred on the development and operation of the Real blockchain, a decentralised Layer-1 network designed to support the tokenisation of real-world assets within an on-chain environment. The project provides infrastructure through which users, developers, and small and medium-sized enterprises may represent cash-flow generating assets, including real estate, inventory, and invoices, in tokenised form. Its core operational framework comprises an onboarding process through which assets may be tokenised by means of smart contracts and embedded metadata, assessed by specialised participants through probability-of-default scoring, and structured with insurance-supported cash-flow arrangements that allow issuance in multiple tranches with differentiated risk-return profiles. In this way, the project is designed to combine asset representation, risk assessment, and insurance-related structuring within a single protocol environment.

The Real blockchain further incorporates a dual-validator model consisting of technical validators responsible for network security and consensus, and business-function validators such as tokenisation providers, risk scorers, and insurance-related participants. The project is intended to align participation in these business functions with protocol-level accountability mechanisms, including staking and slashing conditions applicable within the network design. From a technical perspective, the Real blockchain is built using the Cosmos SDK, uses a Tendermint-based proof-of-stake consensus model, supports smart-contract functionality through CosmWasm, and is intended to allow interoperability through the Inter-Blockchain Communication protocol.

The project does not involve the granting of ownership, profit-participation rights, or legal claims against the Real Finance project or its contributors. Instead, it centres on the creation of a technical environment in which the ASSET crypto-asset may serve as an operational input for certain protocol processes. The long-term evolution of the Real blockchain system, including the scope of available features, the validator-participation framework, committee- or leader-selection mechanisms, and the operational continuity of the infrastructure, may vary based on technical, economic, and regulatory considerations. All future developments remain subject to change.

This section provides an overview of the historical developments related to the ASSET crypto-asset and a description of planned or anticipated project milestones as publicly communicated. All forward-looking elements are subject to significant uncertainty. They do not constitute commitments, assurances, or guarantees, and may be modified, delayed, or discontinued at any time. The implementation of past milestones cannot be assumed to continue in the future, and future changes may have adverse effects for token holders.

Past milestones (project development to date):

- Protocol design and specification (2025): REAL completed the design and specification of its Layer-1 blockchain infrastructure for the tokenisation of real-world assets, including its consensus model, validator framework, and tokenomics structure.

- Definition of tokenomics and network roles (2025): The project formalised its economic model, including staking mechanisms, fee structure, and the dual-validator system (technical validators and business validators such as tokenisation providers and risk assessors).

- Development of risk and protection framework (2025): REAL defined its on-chain risk grading methodology and the structure of its Disaster Recovery Fund (DRF), intended to support asset-level risk mitigation and investor protection mechanisms.

- Ecosystem framework establishment (2025): The project established the operational framework for participation of ecosystem actors, including tokenisation entities, risk scoring providers, and insurance participants.

Future roadmap (planned development and milestones):

- Network deployment and validator onboarding (2026–2027): REAL intends to deploy and scale its network infrastructure, including onboarding of validators and ecosystem participants necessary for network operation and asset lifecycle management.

- Expansion of tokenised asset issuance (2026–2028): The project plans to enable issuance and management of additional categories of real-world assets, including but not limited to structured credit, real estate-backed instruments, and revenue-generating financial products.

- Enhancement of risk and protection mechanisms (ongoing): Continued development of on-chain risk classification, transparency features, and integration of insurance-related structures linked to tokenised assets.

- Interoperability and ecosystem integration (2026–2028): REAL plans to expand interoperability through integration with external blockchain networks and financial infrastructure, including cross-chain functionality.

- Governance framework development (2027 onward): The project intends to introduce governance mechanisms enabling stakeholder participation in protocol-level decisions, subject to regulatory and operational considerations.

- Transparency and reporting (ongoing): Implementation of periodic disclosures, including reporting on reserves, validator activity, and risk mitigation mechanisms, in line with regulatory expectations and market standards.

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 ASSET crypto-asset for its holders.

Resources, including financial resources, have already been allocated to the Real Finance project associated with the ASSET crypto-asset. On 10 December 2025, funding of approximately USD 29,000,000 was secured, consisting of approximately USD 4,000,000 raised through a token financing component and a USD 25,000,000 capital commitment provided by Nimbus Capital in connection with an equity raise undertaken at an indicated valuation of approximately USD 210,000,000. In addition, the project received an investment from Alpha Fund Bulgaria in 2026.

These resources have been allocated to support the project’s international expansion, strengthen regulated banking connectivity, including through relationships such as Canal Bank, S.A. in Panama and Wiener Bank SE in Austria, and scale the network’s infrastructure. The allocated resources therefore comprise growth capital and infrastructure support for the continued development and operational expansion of the Real Finance ecosystem.

Not applicable, as this white paper serves the purpose of admission to trading and is not associated with any fundraising activity for the crypto-asset project.

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.

Holder restrictions are subject to the rules applicable to the crypto-asset service provider, as well as any additional restrictions that provider may impose.

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.

The costs involved in accessing the trading platform depend on the specific fee structure and terms of the respective crypto-asset service provider. These may include trading fees, deposit or withdrawal charges, and network-related gas fees. Investors are advised to consult the applicable fee schedule of the chosen platform before engaging in trading activities.

Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.

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.

Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.

Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.

ASSET is the native crypto-asset of the Real blockchain and functions as the principal on-chain technical component within the network environment. It is used to pay transaction fees on REAL Mainnet, including fees associated with tokenisation processes, smart contract execution, and transfers of ASSET and tokenised real-world assets between accounts. Transaction fees may be dynamically adjusted based on network demand. ASSET is also used within the network’s Tendermint-based proof-of-stake consensus model. Validators are required to stake ASSET in order to operate validator nodes and participate in consensus, while other holders may delegate ASSET to validators. Staked ASSET is also used in governance processes relating to protocol upgrades, inflation adjustments, parameter changes, and treasury-related decisions, with voting power determined by the amount of ASSET staked. Within the Real ecosystem’s dual-validator structure, certain business-function validators may also be required to stake ASSET in proportion to their on-chain activity, and such stake may be subject to slashing in defined cases, including dishonest data provision, metadata errors, or failures to meet applicable obligations.

The token is further used in connection with incentive mechanisms funded through transaction fees and protocol inflation. ASSET may also be used within the Disaster Recovery Fund mechanism, under which Network Debt Tokens (NDTs) may be redeemable over time on a 1:1 basis against ASSET, subject to the operation and terms of that mechanism. Protocol inflation may be used to support staking and validator incentives. The first-year emission amount is expected to be approximately 50,000,000 ASSET, corresponding to 5.0% of the initial supply. The inflation rate expressed as a percentage of the total supply may decline over time as the overall supply base increases.

The ASSET crypto-asset does not confer ownership, profit participation rights over the issuer or any related entity, or any other form of economic entitlement as such. Its functionalities are technical and protocol-related in nature and relate to interactions within the Real blockchain environment, including transaction processing, staking, delegation, governance participation, validator accountability mechanisms, incentive mechanisms, and the operation of network-specific recovery arrangements. The usability and value of ASSET depend on factors such as the continued operation of the relevant protocol infrastructure, the performance and security of the Real blockchain, the correct functioning of consensus, staking, governance, and smart-contract related systems, and future development decisions associated with the Real project.

Future roadmap (planned development and milestones):

- Network deployment and validator onboarding (2026–2027): REAL intends to deploy and scale its network infrastructure, including onboarding of validators and ecosystem participants necessary for network operation and asset lifecycle management.

- Expansion of tokenised asset issuance (2026–2028): The project plans to enable issuance and management of additional categories of real-world assets, including but not limited to structured credit, real estate-backed instruments, and revenue-generating financial products.

- Enhancement of risk and protection mechanisms (ongoing): Continued development of on-chain risk classification, transparency features, and integration of insurance-related structures linked to tokenised assets.

- Interoperability and ecosystem integration (2026–2028): REAL plans to expand interoperability through integration with external blockchain networks and financial infrastructure, including cross-chain functionality.

- Governance framework development (2027 onward): The project intends to introduce governance mechanisms enabling stakeholder participation in protocol-level decisions, subject to regulatory and operational considerations.

- Transparency and reporting (ongoing): Implementation of periodic disclosures, including reporting on reserves, validator activity, and risk mitigation mechanisms, in line with regulatory expectations and market standards.

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 ASSET crypto-asset for its holders.

The crypto-asset referred to herein is a crypto-asset other than EMTs and ARTs, and will be available on the Real network. 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.

No further services are currently planned.

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.

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.

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.

No future public offers of crypto-assets are currently planned by the issuer at the time of writing this white paper.

The crypto-asset is not subject to any technical or contractual transfer restrictions and is 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.

For the crypto-asset in scope, there is no fixed maximum supply. The initial supply at the token generation event is expected to be 1,000,000,000 ASSET, with additional ASSET potentially issued over time through protocol inflation. Investors should note that changes in the supply of the crypto-asset can have a negative impact.

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 Republic of Bulgaria.

Any disputes arising in relation to this white paper or the admission to trading may be brought before the competent courts in Sofia, Bulgaria.

The crypto-asset in scope is implemented on the Real network following the standards described below.

The crypto-asset in scope is implemented on the Real network following the standards described below.

The following applies to Real network:

ASSET operates as a decentralised, permissionless Layer 1 blockchain built using the Cosmos SDK. Consensus and peer-to-peer networking are provided through a Tendermint-based Byzantine Fault Tolerant Proof-of-Stake mechanism, which coordinates validator block proposals and votes to achieve deterministic finality. Interoperability with other compatible blockchain networks is supported through the Inter-Blockchain Communication protocol, enabling cross-chain message passing and transfers based on cryptographic proofs. ASSET additionally uses CosmWasm as its smart-contract framework, under which smart contracts are written in Rust and executed as WebAssembly bytecode in a sandboxed environment.

Transactions are processed through a standardised validation pipeline that includes digital-signature verification, sequence and nonce checks, gas accounting, and fee deduction prior to execution. Accounts and addresses follow Cosmos-style representations using Bech32 encoding, including the real1 address prefix. The network further references established technical standards such as BIP-39 for mnemonic seed phrases, Bech32 for address encoding, and WebAssembly for smart-contract execution.

The protocol relies on established cryptographic primitives. Key generation and digital signatures are based on elliptic curve cryptography using the Secp256k1 curve. Hashing is performed using SHA-256 for transaction digests and a combination of SHA-256 and RIPEMD-160 for address derivation. Network communication and message propagation are handled through the standard Tendermint peer-to-peer and gossip-based networking layers.

Protocol changes and upgrades are coordinated through on-chain governance processes involving stakers and node operators. Governance may be used to amend protocol parameters and adopt software upgrades, including changes affecting staking, rewards, and other network-level settings. In this respect, the protocol rules are primarily defined through the Cosmos SDK-based application logic and on-chain parameters, rather than through a separate stand-alone specification document.

The crypto-asset in scope is implemented on the Real network following the standards described below.

The following applies to Real network:

ASSET operates as a decentralised, account-based ledger that records transactions in an append-only blockchain structure. The network uses the Cosmos SDK framework and supports smart-contract execution through CosmWasm, allowing users and applications to interact with the protocol through native module messages and smart-contract calls.

Users control accounts through public and private key pairs. The protocol relies on cryptographic signatures for transaction authorisation, while wallet software and client implementations handle practical key management, including storage of private keys and recovery material.

Nodes maintain the ledger state and may be operated in different configurations, including setups that retain broader historical data and configurations that prune older data in order to reduce storage requirements.

The crypto-asset in scope is implemented on the Real network following the standards described below.

The following applies to Real network:

ASSET operates a Tendermint-based Proof-of-Stake consensus mechanism provided through the Cosmos SDK. This mechanism is designed to support decentralised security, deterministic finality, and replicated state execution across the network.

Consensus participants consist of validators that participate in block production and block validation. The network distinguishes between normal validators, which are responsible for technical block production, uptime, and consensus participation, and business function validators, which are intended to support the financial and operational integrity of tokenised real-world asset processes within the broader protocol design. Validators are selected on the basis of staked ASSET and a selection process embedded in the protocol. Operation of a validator node requires staking ASSET.

Token holders may participate in network security either directly by operating validator infrastructure or indirectly by delegating ASSET to an existing validator. Delegated stake contributes to validator voting power and may entitle delegators to a proportional share of protocol rewards, net of validator commission. Unstaking is subject to an unbonding period of 21 days, during which the relevant crypto-assets remain locked and do not accrue staking rewards.

Consensus proceeds through the Tendermint Byzantine Fault Tolerant process. Validators propose and vote on blocks in rounds, and a block is finalised once the required supermajority threshold is reached. This produces deterministic finality within seconds and is intended to ensure that committed transactions cannot be reversed absent a failure of the underlying consensus assumptions. The mechanism is designed to tolerate faults or malicious behaviour affecting up to one-third of validator voting power while maintaining network safety and consistency.

The protocol also provides for slashing and penalty mechanisms. Validators may be penalised for double-signing and for sustained downtime or unavailability. A broader business-slashing framework is applicable to business function validators in cases such as metadata errors, misreporting, or failure to meet protocol-defined obligations in relation to real-world asset processes.

The crypto-asset in scope is implemented on the Real network following the standards described below.

The following applies to Real network:

ASSET secures its Proof-of-Stake consensus mechanism through a combined system of issuance, transaction fees, staking rewards, and penalties designed to incentivise validator performance and delegator participation.

The protocol provides for on-chain token issuance to support network security. The first-year issuance amount is expected to be approximately 50,000,000 ASSET, corresponding to 5.0% of the initial supply of 1,000,000,000 ASSET. These newly issued crypto-assets are intended to fund network rewards. The inflation rate expressed as a percentage of total supply may decline over time as the overall supply base increases.

Validators and delegators may receive rewards through a combination of transaction fees and block rewards. Inflation-based rewards are split between technical validators and business-enabler participants. Delegators that bond ASSET to validators may receive a proportional share of validator rewards, less any validator commission.

The network applies a gas-based transaction fee model. Fees are paid by users initiating on-chain actions, including transfers, smart-contract execution, and asset-tokenisation related transactions. These fees are distributed to validators and participating stakers rather than being burned as a default rule, although certain module-level mechanisms may apply fee burning or other supply-reducing effects in specific cases.

Bonded ASSET is subject to slashing for protocol violations. This includes penalties for double-signing and for validator downtime or unavailability. Under a business-slashing model, business function validators may also be penalised for misreporting, metadata errors, or failure to satisfy relevant protocol obligations. Slashing serves as an economic disincentive for conduct that may impair the security, reliability, or integrity of the network.

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.

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.

1. Insolvency of the issuer

As with any commercial entity, the issuer may face insolvency risks. These may result from insufficient funding, low market interest, mismanagement, or external shocks (e.g. pandemics, armed conflicts). In such a case, ongoing development, support, and governance of the project may cease, potentially affecting the viability and tradability of the crypto-asset.

2. Legal and regulatory risks

The issuer operates in a dynamic and evolving regulatory environment. Failure to comply with applicable laws or regulations in relevant jurisdictions may result in enforcement actions, penalties, or restrictions on the project’s operations. These may negatively impact the crypto-asset’s availability, market acceptance, or legal status.

3. Operational risks

The issuer may fail to implement adequate internal controls, risk management, or governance processes. This can result in operational disruptions, financial losses, delays in updating the white paper, or reputational damage.

4. Governance and decision-making

The issuer’s management body is responsible for key strategic, operational, and disclosure decisions. Ineffective governance, delays in decision-making, or lack of resources may compromise the stability of the project and its compliance with MiCA requirements. High concentration of decision-making authority or changes in ownership/control can amplify these risks.

5. Reputational risks

The issuer’s reputation may be harmed by internal failures, external accusations, or association with illicit activity. Negative publicity can reduce trust in the issuer and impact the perceived legitimacy or value of the crypto-asset.

6. Counterparty dependence

The issuer may depend on third-party providers for certain core functions, such as technology development, marketing, legal advice, or infrastructure. If these partners discontinue their services, change ownership, or underperform, the issuer’s ability to operate the project or maintain investor communication may be impaired. This could disrupt project continuity or undermine market confidence, ultimately affecting the crypto-asset’s value.

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.

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.

Delays, failures, or changes in the implementation of the project as outlined in its public roadmap or technical documentation may negatively impact the perceived credibility or usability of the crypto-asset. This includes risks related to project governance, resource allocation, technical delivery, and team continuity.

Key-person risk: The project may rely on a limited number of individuals for development, maintenance, or strategic direction. The departure, incapacity, or misalignment of these individuals may delay or derail the implementation.

Timeline and milestone risk: Project milestones may not be met as announced. Delays in feature releases, protocol upgrades, or external integrations can undermine market confidence and affect the adoption, use, or value of the crypto-asset.

Delivery risk: Even if implemented on time, certain functionalities or integrations may not perform as intended or may be scaled back during execution, limiting the crypto-asset’s practical utility.

As this white paper relates to admission to trading of the crypto-asset, the following risks concern the underlying distributed ledger technology (DLT), its supporting infrastructure, and related technical dependencies. Failures or vulnerabilities in these systems may affect the availability, integrity, or transferability of the crypto-asset.

1. Blockchain dependency risk

The functionality of the crypto-asset depends on the continuous and stable operation of the blockchain(s) on which it is issued. Network congestion, outages, or protocol errors may temporarily or permanently disrupt on-chain transactions. Extended downtime or degradation in network performance can affect trading, settlement, or the usability of the crypto-asset.

2. Smart contract vulnerability risk

The smart contract that defines the crypto-asset’s parameters or governs its transfers may contain coding errors or security vulnerabilities. Exploitation of such weaknesses can result in unintended token minting, permanent loss of funds, or disruption of token functionality. Even after external audits, undetected vulnerabilities may persist due to the immutable nature of deployed code.

3. Wallet and key-management risk

The custody of crypto-assets relies on secure private key management. Loss, theft, or compromise of private keys results in irreversible loss of access. Custodians, trading venues, or wallet providers may be targeted by cyberattacks. Compatibility issues between wallet software and changes to the blockchain protocol (e.g. network upgrades) can further limit user access or the ability to transfer the crypto-asset.

Outdated or vulnerable wallet software:

Users relying on outdated, unaudited, or unsupported wallet software may face compatibility issues, security vulnerabilities, or failures when interacting with the blockchain. Failure to update wallet software in line with protocol developments can result in transaction errors, loss of access, or exposure to known exploits.

4. Network security risks

Attack risks: Blockchains may be subject to denial-of-service (DoS) attacks, 51% attacks, or other exploits targeting the consensus mechanism. These can delay transactions, compromise finality, or disrupt the accurate recording of transfers.

Centralisation concerns: Despite claims of decentralisation, a relatively small number of validators or a high concentration of stake may increase the risk of collusion, censorship, or coordinated network downtime, which can affect the resilience and operational reliability of the crypto-asset.

5. Bridge and interoperability risk

Where tokens can be bridged or wrapped across multiple blockchains, vulnerabilities in bridge protocols, validator sets, or locking mechanisms may result in loss, duplication, or misrepresentation of assets. Exploits or technical failures in these systems can instantly impact circulating supply, ownership claims, or token fungibility across chains.

6. Forking and protocol-upgrade risk

Network upgrades or disagreements among node operators or validators can result in blockchain “forks”, where the blockchain splits into two or more incompatible versions that continue separately from a shared past. This may lead to duplicate token representations or incompatibilities between exchanges and wallets. Until consensus stabilises, trading or transfers may be disrupted or misaligned. Such situations may be difficult for retail holders to navigate, particularly when trading platforms or wallets display inconsistent token information.

7. Economic-layer and abstraction risk

Mechanisms such as gas relayers, wrapped tokens, or synthetic representations may alter the transaction economics of the underlying token. Changes in transaction costs, token demand, or utility may reduce its usage and weaken both its economic function and perceived value within its ecosystem.

8. Spam and network-efficiency risk

High volumes of low-value (“dust”) or automated transactions may congest the network, slow validation times, inflate ledger size, and raise transaction costs. This can impair performance, reduce throughput, and expose address patterns to analysis, thereby reducing network efficiency and privacy.

9. Front-end and access-interface risk

If users rely on centralised web interfaces or hosted wallets to interact with the blockchain, service outages, malicious compromises, or domain expiries affecting these interfaces may block access to the crypto-asset, even while the blockchain itself remains fully functional. Dependence on single web portals introduces a critical point of failure outside the DLT layer.

10. Decentralisation claim risk

While the technical infrastructure may appear distributed, the actual governance or economic control of the project may lie with a small set of actors. This disconnect between marketing claims and structural reality can lead to regulatory scrutiny, reputational damage, or legal uncertainty – especially if the project is presented as ‘community-governed’ without substantiation.

None.

The crypto-asset in scope is implemented on the Real network following the standards described below.

The following applies to Real network:

ASSET operates a Tendermint-based Proof-of-Stake consensus mechanism provided through the Cosmos SDK. This mechanism is designed to support decentralised security, deterministic finality, and replicated state execution across the network.

Consensus participants consist of validators that participate in block production and block validation. The network distinguishes between normal validators, which are responsible for technical block production, uptime, and consensus participation, and business function validators, which are intended to support the financial and operational integrity of tokenised real-world asset processes within the broader protocol design. Validators are selected on the basis of staked ASSET and a selection process embedded in the protocol. Operation of a validator node requires staking ASSET.

Token holders may participate in network security either directly by operating validator infrastructure or indirectly by delegating ASSET to an existing validator. Delegated stake contributes to validator voting power and may entitle delegators to a proportional share of protocol rewards, net of validator commission. Unstaking is subject to an unbonding period of 21 days, during which the relevant crypto-assets remain locked and do not accrue staking rewards.

Consensus proceeds through the Tendermint Byzantine Fault Tolerant process. Validators propose and vote on blocks in rounds, and a block is finalised once the required supermajority threshold is reached. This produces deterministic finality within seconds and is intended to ensure that committed transactions cannot be reversed absent a failure of the underlying consensus assumptions. The mechanism is designed to tolerate faults or malicious behaviour affecting up to one-third of validator voting power while maintaining network safety and consistency.

The protocol also provides for slashing and penalty mechanisms. Validators may be penalised for double-signing and for sustained downtime or unavailability. A broader business-slashing framework is applicable to business function validators in cases such as metadata errors, misreporting, or failure to meet protocol-defined obligations in relation to real-world asset processes.

The crypto-asset in scope is implemented on the Real network following the standards described below.

The following applies to Real network:

ASSET secures its Proof-of-Stake consensus mechanism through a combined system of issuance, transaction fees, staking rewards, and penalties designed to incentivise validator performance and delegator participation.

The protocol provides for on-chain token issuance to support network security. The first-year issuance amount is expected to be approximately 50,000,000 ASSET, corresponding to 5.0% of the initial supply of 1,000,000,000 ASSET. These newly issued crypto-assets are intended to fund network rewards. The inflation rate expressed as a percentage of total supply may decline over time as the overall supply base increases.

Validators and delegators may receive rewards through a combination of transaction fees and block rewards. Inflation-based rewards are split between technical validators and business-enabler participants. Delegators that bond ASSET to validators may receive a proportional share of validator rewards, less any validator commission.

The network applies a gas-based transaction fee model. Fees are paid by users initiating on-chain actions, including transfers, smart-contract execution, and asset-tokenisation related transactions. These fees are distributed to validators and participating stakers rather than being burned as a default rule, although certain module-level mechanisms may apply fee burning or other supply-reducing effects in specific cases.

Bonded ASSET is subject to slashing for protocol violations. This includes penalties for double-signing and for validator downtime or unavailability. Under a business-slashing model, business function validators may also be penalised for misreporting, metadata errors, or failure to satisfy relevant protocol obligations. Slashing serves as an economic disincentive for conduct that may impair the security, reliability, or integrity of the network.

For the calculation of energy consumptions, the so-called 'bottom-up' approach is being used. The nodes are considered to be the central factor for the energy consumption of the network. These assumptions are made on the basis of empirical findings through the use of public information sites, open-source crawlers and crawlers developed in-house. The main determinants for estimating the hardware used within the network are the requirements for operating the client software. The energy consumption of the hardware devices was measured in certified test laboratories. When calculating the energy consumption, we used - if available - the Functionally Fungible Group Digital Token Identifier (FFG DTI) to determine all implementations of the asset in scope and we update the mappings regluarly, based on data of 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 with best effort 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. making higher estimates for the adverse impacts.

To determine the proportion of renewable energy usage, the locations of the nodes are to be 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 cost 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

To determine the GHG emissions, the locations of the nodes are to be 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 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.