Index

General Information
Part A: Information about the offeror or the person seeking admission to trading
Part B: Information about the issuer, if different from the offeror or person seeking admission to trading
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
Part D: Information about the crypto-asset project
Part E: Information about the offer to the public of crypto-assets or their admission to trading
Part F: Information about the crypto-assets
Part G: Information on the rights and obligations attached to the crypto-assets
Part H: Information on the underlying technology
Part I: Information on the risks
Part J: Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts

2026-09-03

This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The operator of the trading platform of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid.

The utility token referred to in this white paper may not be exchangeable against the good or service promised in this white paper, especially in the case of a failure or discontinuation of the crypto-asset project.

The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

Warning
This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto-asset on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other documents pursuant to the applicable national law.
This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.

BILL is the native crypto-asset of the Billions ecosystem. Billions is a human and AI verification network that provides privacy-first identity and verification services for humans, AI agents and digital applications. Its services include proof of humanity, zero-knowledge KYC, age verification, Know Your Agent, secure token distribution and real-world asset onboarding.

BILL is intended to provide access to specific digital services, functionalities and participation mechanisms within the Billions ecosystem, including identity-related services, verification processes, staking-based reputation mechanisms and other utilities described in the applicable white paper and related documentation.

BILL is an ERC-20 crypto-asset that has a fixed supply of 10,000,000,000 BILL, with no plans to create new tokens through inflationary mechanisms.

Holders of BILL do not, solely by acquiring, holding or using BILL, acquire ownership rights, profit-sharing rights, repayment rights, redemption rights, governance rights, unless expressly introduced in later protocol phases, or other rights commonly associated with shares, debt instruments or financial products.

BILL gives access to digital services, functionalities and participation mechanisms within the Billions ecosystem. The Billions platform is designed to provide privacy-first verification services for humans, AI agents and digital applications, including proof of humanity, zero-knowledge KYC, age verification, Know Your Agent, secure token distribution and real-world asset onboarding.

The main services accessible through BILL relate to credential verification, identity verification, reputation and ecosystem participation. BILL powers access to the ecosystem, including credential verification, reputation staking, fee discounts and premium features. Users may stake BILL to boost reputation, unlock higher-tier benefits and earn ecosystem rewards, subject to availability and applicable conditions.

The BILL token version on the Ethereum blockchain has been admitted to trading to the trading platform operated by Bitstamp Europe S.A. on its own initiative.

TRUE

Billions Limited

6EH6

2nd Floor Water’s Edge Building, Wickhams Cay II, Road Town

Tortola

2nd Floor Water’s Edge Building, Wickhams Cay II, Road Town

Tortola

2025-11-21

Not applicable

Billions Limited’s business activity consists of developing and operating the BILLIONS ecosystem, a digital identity and trust infrastructure intended to enable the issuance, validation and reuse of verifiable digital credentials. The project is designed to support identity and credential verification for human users, artificial intelligence agents, decentralised applications, Web3 protocols and enterprise users through privacy-preserving technologies, including zero-knowledge proof-based verification.

Not applicable

Bitstamp Europe S.A.

5GGB

40, avenue Monterey, L-2163, Grand Duchy of Luxembourg

LU-LU

40, avenue Monterey, L-2163, Grand Duchy of Luxembourg

LU-LU

2015-05-19

549300XIBGTJ0PLIEO72

Bitstamp Europe S.A. is registered with the Luxembourg Trade and Companies Register under the number B196856.

Robinhood Markets, Inc with its registered office at 85 Willow Road, Menlo Park, California 94025, USA.

Bitstamp Europe S.A., acting in its capacity as a crypto-asset service provider (CASP) and operator of a trading platform, has prepared this crypto-asset white paper to support the admission to trading of the crypto-asset on its platform and to provide users with the information required under Regulation (EU) 2023/1114 (MiCA).

Bitstamp Europe S.A. is a Crypto-Asset Service Provider authorised with the CSSF under the number N00000003 to provide the following crypto-asset services:

• providing custody and administration of crypto-assets on behalf of clients;
• operation of a trading platform for crypto-assets;
• exchange of crypto-assets for funds;
• exchange of crypto-assets for other crypto-assets;
• execution of orders for crypto-assets on behalf of clients;
• reception and transmission of orders for crypto-assets on behalf of clients; and
• providing transfer services for crypto-assets on behalf of clients.

Bitstamp Europe S.A. is a payment institution authorised by the CSSF under number Z00000012 to provide the following payment services:

3.a) execution of direct debits, including one-off direct debits,

3.b) execution of payment transactions through a payment card or a similar device,

3.c) execution of credit transfers, including standing orders and

6.) money remittance.

Bitstamp Europe S.A. has notified the cross-border provision of payment services and of crypto-asset services in all EU and EEA member states.

Bitstamp has admitted the asset to which this white paper relates to, to trading on its own initiative on its trading platform.

Robinhood Markets, Inc. is the parent holding company of the Robinhood group.

MiCA Crypto Alliance Limited

MiCA Crypto Alliance Limited was mandated to assist in the white paper preparation by Bitstamp Europe S.A. Bitstamp Europe S.A. retains the role of person seeking admission to trading.

Billions Network

Billions Network Token

BILL

BILLIONS is a digital identity and trust infrastructure project designed to enable the issuance, validation and reuse of verifiable digital credentials. The project aims to support identity and credential verification for human users, artificial intelligence agents, Web3 applications, decentralised protocols and enterprise users.

The Billions ecosystem uses privacy-preserving technologies, including zero-knowledge proof-based verification, to allow users and applications to verify relevant attributes without unnecessary disclosure of personal data. The project is intended to support use cases such as proof of humanity by distinguishing between human involvement and machines, credential verification, verifying and proving the AI agent identity, reusable KYC and AML processes, secure token distribution - particularly in airdrops and token reward distributions - and interoperable digital trust across applications and ecosystems.

The BILL token is intended to function as the utility token of the Billions ecosystem. It supports access to ecosystem functionalities, participation mechanisms, staking-based reputation and trust mechanisms, and credential-related services, subject to the applicable platform terms, technical requirements and smart-contract conditions.

TRUE

BILL provides access to digital services, functionalities and participation mechanisms within the Billions ecosystem. The Billions platform includes the mobile application, the web wallet, the Identity Dashboard, and digital services for identity verification, issuance and management of identity credentials, including services based on cryptographic and zero-knowledge proof technologies.

BILL powers access to the ecosystem, including credential verification, reputation staking, fee discounts and premium features. Users may stake BILL to boost reputation, unlock higher-tier benefits and earn ecosystem rewards, subject to availability and applicable conditions.

The Billions platform may issue verifiable credentials to users’ identity wallets based on the verification steps completed by the user. These credentials are privacy-preserving digital certificates that allow users to prove attributes about themselves using cryptography, including zero-knowledge proofs, without exposing unnecessary personal data. Billions may offer different types of credentials, including Human, Verified Human and Uniqueness credentials, depending on availability and user eligibility. These credentials may enable access to platform features, verification badges, rewards and other ecosystem benefits, and may be required for specific initiatives, campaigns or promotional programmes.

BILL also supports identity and trust mechanisms for AI agents. Users can link agents to their profile, and the Verified Agent Identity skill gives an AI agent its own permanent identity, privately linked to the user’s verified profile. It further states that the agent receives a decentralised identifier that can be verified on-chain without exposing the user’s personal data.

BILL holders have access to discounts of 10% to 15% on verification and credential fees when making payments.

Past milestones

The BILLIONS roadmap is structured around three phases. The first phase, Human and AI Internet, focuses on establishing the boundary between humans and machines by enabling users to prove that they are real humans while preserving privacy. The Billions platform already provides a mobile application, web wallet, Identity Dashboard and digital services for identity verification, issuance and management of identity credentials, including cryptographic and zero-knowledge proof technologies.

In the second phase, Reputation Layer, the project focuses on connecting humans and AI agents through verified reputation. The official Know Your Agent materials describe a system that gives AI agents verifiable identity, links them to their creators, and allows trust and reputation to develop publicly while preserving privacy. The Billions App page also states that users can prove that they are real humans, obtain a verified Universal ID and link agents to their profile.

In the third phase, Global Trust Economy, the project focuses on enabling richer identities backed by trusted credentials. Billions’ official materials describe use cases including proof of humanity, zero-knowledge KYC, age verification, Know Your Agent, secure token distribution and real-world asset onboarding. The official BNB Chain integration announcement also describes cross-chain identity flows, decentralised identities for humans and AI agents, private credentials, zero-knowledge verification and “verify once, use everywhere” functionality.

Future milestones

The project also intends to continue developing privacy-preserving verification and AI-agent identity services using zero-knowledge proofs, including decentralised identifiers, verifiable credentials, per-app pseudonymity, unlinkable ZK proofs and human-linked AI-agent identity.

The Billions Network also aims to include additional functionalities for the BILL token, notably governance features enabling holders to participate in guiding the evolution of the network, including voting on funding, parameters, and trust curation decisions. These are not contractual features and do not confer any legal governance rights.

BILL is an ERC-20 utility token with a total supply of 10,000,000,000 tokens and 18 decimal places. The current token design is based on a fixed-supply model with no mint or burn functionality.

At the Token Generation Event (TGE), the initial circulating supply is expected to represent approximately 24.48% of the total supply.

The token is planned to be distributed across multiple groups with 40% allocated to Community. Approximately 6.28% of the Community allocation is released at the TGE, while the remainder of the allocation is distributed progressively over a period of 4 years, following a front-loaded emissions profile, with a higher concentration of emissions during the first 2 years and a gradual reduction until the fourth year.

32% of the supply is allocated to Foundation and is divided into two equal tranches. On the one hand, 16% is unlocked at the TGE and is intended to cover operational needs and liquidity provision. On the other hand, 16% is subject to a lock-up period until the second year, followed by a linear and progressive release until the fourth year.

20% to Team the allocation is subject to a one-year cliff, followed by three-year linear vesting, beginning in the second year and extending until the fourth year.

2% is allocated to the Creators Program. This allocation is intended for initiatives aimed at creators within the ecosystem and 6% is allocated to Investors.

Not applicable

Bitstamp Europe S.A. has admitted the token, in its Ethereum version, to trading based on its market considerations.

When a client purchases a token on the Bitstamp Europe S.A.'s trading platform, the crypto-asset will be credited to their Bitstamp account. If a client wants to hold the token in their own wallet, they will need to (i) provide an external blockchain wallet address, where the crypto-assets will be sent if a withdrawal is initiated and (ii) satisfy all other requirements applicable to a withdrawal in line with the Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets.

When a client purchases a token on the Bitstamp Europe S.A.'s trading platform, the crypto-asset will be credited to their Bitstamp account and a client does not need to fulfill any other technical requirement to hold the crypto-assets on their Bitstamp account, apart from have either a computer or phone with an internet connection and appropriate software in order to interact with the Bitstamp services.

Bitstamp Europe S.A.

BESA

Investors can access the trading platform through https://www.bitstamp.net or via the Bitstamp applications.

There are no costs involved in creating an account on the trading platform, however trading fees and other costs apply in accordance with the fee schedule available at https://www.bitstamp.net/fee-schedule.

Not applicable

There are no conflicts of interest arising at the moment of writing the white paper in relation to the offer or admission to trading. Bitstamp Group has a strict Code of Conduct and Trading Policy in place. They both mitigate the possibility of conflicts of interest.

In accordance with the Code of Conduct all officers, directors, employees, agents, representatives, contractors and consultants (and other persons, regardless of job or position), are required to report any situation where there is the potential for conflict of interest between their interests and interests of Bitstamp. The Trading Policy that is in place within the Bitstamp Group prohibits all forms of market manipulation and has been designed to prevent insider trading.

Not applicable, as this point pertains to an 'offer to the public', whereas this white paper relates to admission to trading.

Not applicable, as this point pertains to an 'offer to the public', whereas this white paper relates to admission to trading.

Crypto-assets other than asset-referenced tokens or e-money tokens

BILL is a utility token within the Billions ecosystem. It is intended to provide access to specific digital services, functionalities and participation mechanisms, including identity-related services, verification processes, staking-based reputation mechanisms and other utilities. The acquisition, holding or use of BILL does not confer ownership rights, profit-sharing rights, or rights commonly associated with shares, debt instruments or financial products.

The Billions platform provides digital identity and verification services, including identity verification, issuance and management of identity credentials, and services using cryptographic and zero-knowledge proof technologies. Users may create and manage identity credentials through the platform, and credentials may enable access to certain platform features, verification badges, rewards and other ecosystem benefits, subject to availability, eligibility and the applicable platform conditions.

The functionalities associated with BILL include access to identity-related services, credential verification, participation in platform functionalities, and staking-based participation mechanisms.

The Billions ecosystem also supports use cases involving proof of humanity, zero-knowledge KYC, age verification, Know Your Agent, secure token distribution and real-world asset onboarding. These use cases are designed to enable privacy-preserving verification for humans, artificial intelligence agents, Web3 projects, decentralised applications and enterprise users.

The Billions Network also aims to include additional functionalities for the BILL token, notably governance features enabling holders to participate in guiding the evolution of the network, including voting on funding, parameters, and trust curation decisions. These are not contractual features and do not confer any legal governance rights.

Governance functionalities are planned to be implemented in future phases of the protocol’s development.

BILL is the native crypto-asset of the Billions ecosystem. BILL is intended to provide access to specific digital services, functionalities and participation mechanisms within the Billions ecosystem, including identity-related services, verification processes, staking-based reputation mechanisms and other utilities described in the applicable white paper and related documentation.

BILL has a fixed supply of 10,000,000,000 BILL, with no plans to create new tokens through inflationary mechanisms.

Holders of BILL do not, solely by acquiring, holding or using BILL, acquire ownership rights, profit-sharing rights, repayment rights, redemption rights, governance rights, unless expressly introduced in later protocol phases, or other rights commonly associated with shares, debt instruments or financial products

Billions Network

www.billions.network

2026-10-03

2026-10-02

Not applicable

English

KX72D65KT

TD9BTNFZ2

FALSE

TRUE

TRUE

Not applicable, holders of the BILL crypto-asset do not, solely by acquiring or holding BILL, acquire any ownership, equity, profit participation, repayment, redemption or compensation rights against any identified issuer, the Billions Limited, Billions Network or any other natural or legal person. Holding BILL does not give rise to contractual claims or entitlements against any natural or legal person.

Accordingly, all functionalities and utilities associated with BILL are functional and protocol-based. These functionalities are further described in F.2 and G.7.

Not applicable as the asset confers no ownership or financial claims and does not impose any legal obligations.

Not applicable as the asset confers no ownership or financial claims and does not impose any legal obligations.

Not applicable

TRUE

BILL provides access to digital services, functionalities and participation mechanisms within the Billions ecosystem. The Billions platform includes the mobile application, the web wallet, the Identity Dashboard, and digital services for identity verification, issuance and management of identity credentials, including services based on cryptographic and zero-knowledge proof technologies.

BILL powers access to the ecosystem, including credential verification, reputation staking, fee discounts and premium features. Users may stake BILL to boost reputation, unlock higher-tier benefits and earn ecosystem rewards, subject to availability and applicable conditions.

The Billions platform may issue verifiable credentials to users’ identity wallets based on the verification steps completed by the user. These credentials are privacy-preserving digital certificates that allow users to prove attributes about themselves using cryptography, including zero-knowledge proofs, without exposing unnecessary personal data. Billions may offer different types of credentials, including Human, Verified Human and Uniqueness credentials, depending on availability and user eligibility. These credentials may enable access to platform features, verification badges, rewards and other ecosystem benefits, and may be required for specific initiatives, campaigns or promotional programmes.

BILL also supports identity and trust mechanisms for AI agents. Users can link agents to their profile, and the Verified Agent Identity skill gives an AI agent its own permanent identity, privately linked to the user’s verified profile. It further states that the agent receives a decentralised identifier that can be verified on-chain without exposing the user’s personal data.

BILL holders have access to discounts of 10% to 15% on verification and credential fees when making payments.

BILL may be used to access the goods and services provided through the Billions ecosystem in accordance with the applicable platform terms, smart-contract conditions and technical requirements. These services include digital identity verification, issuance and management of identity credentials, credential verification, reputation staking, fee discounts and premium features. Access is exercised through the Billions mobile application, web wallet, Identity Dashboard and other official interfaces or domains operated by Billions.

BILL does not confer any claim to cash, repayment, profit participation or any financial return. Instead, BILL redemption is understood as access to the token’s goods and services within the Billions Network ecosystem.

TRUE

Not applicable

Not applicable

FALSE

Not applicable

FALSE

Not applicable

FALSE

Not applicable

There is no written legal agreement between the issuer and the crypto asset-holder that sets out the laws that govern the legal relationship between those two parties. In the absence of such an agreement, the laws that govern that relationship will depend on the location of the issuer and the given crypto asset-holder and characteristic performance of the legal relationship, and any agreed intention of the issuer and crypto asset-holder.

There is no written legal agreement between the issuer and the crypto asset-holder that sets out which jurisdiction's courts will have authority to deal with a dispute between the crypto asset-holder and the issuer. In the absence of such an agreement, the laws of the competent court will depend on the location of the issuer and the given crypto asset-holder and characteristic performance of the legal relationship, and any agreed intention of the issuer and crypto asset-holder.

BILL is deployed on two distributed ledger networks. The primary network is Ethereum Mainnet, a permissionless, public, proof-of-stake blockchain maintained by a global and independent validator set. Ethereum is the network on which BILL was originally issued and where the token contract is settled. The BILL token contract on Ethereum is deployed at 0xb1110919016846972056ab995054d65560d5f05e.

The Billions Network chain serves as the Layer 2 network for the ecosystem's identity and verification infrastructure and carries a corresponding BILL token deployment. It is a Polygon CDK-based EVM-compatible rollup, designed to anchor DID state transitions, verifiable credential attestations and reputation records. All state transitions on the Billions Network chain are ultimately settled on Ethereum Mainnet, from which the chain derives its finality guarantees. The BILL token contract on the Billions Network chain is deployed at 0xb060E40C3B053C33D458f7105F95DA52741CAb62.

Token Standards

BILL conforms to the ERC-20 token standard, which defines the interface for fungible token balances, allowances, and transfers on Ethereum-compatible networks. The contract also implements ERC20Permit in accordance with EIP-2612, enabling holders to approve token expenditures through off-chain signatures, thereby eliminating the need for a separate on-chain approval transaction and reducing gas costs for users. Typed structured data signing follows EIP-712, which establishes a structured encoding format for signature payloads to prevent cross-domain replay attacks. These standards apply equally to BILL on the Billions Network chain, which is an EVM-compatible rollup that implements identical token interface semantics to Ethereum Mainnet.

Contract Architecture

The token contract is deployed behind an OpenZeppelin Transparent Proxy, enabling logic upgrades whilst preserving the token address and all holder balances. Upgrades to the implementation contract are gated by a TimelockController, introducing a mandatory delay between proposal and execution of any change. The staking contract is similarly upgradeable and includes administrative pause functionality, allowing operations to be suspended in the event of an identified security issue. Contract addresses for the staking infrastructure are confirmed at 0x58201A4826Dc07443d1280bA194604B12A3b8FaB on the Billions Network chain.

Token Cross-Chain Transferability

BILL is issued on Ethereum Mainnet and made transferable to five additional networks through a LayerZero Omnichain Fungible Token Adapter (BillOFTAdapter, paired with BillOFT deployments on each connected network). The Adapter operates on a lock-and-mint model: BILL transferred out of Ethereum is held in the Adapter contract as the anchor-chain balance, and an equivalent BillOFT balance is minted on the destination network. The reverse transfer burns the destination-network balance and releases the corresponding amount on Ethereum. This mechanism preserves a single unified circulating supply across every connected network — no network can hold more BILL than has been locked against it on Ethereum.

Live bidirectional transfer pathways currently connect six networks: Ethereum, BNB Chain, Base, Polygon PoS, Arbitrum and Optimism. BillOFTAdapter and BillOFT contracts are additionally deployed to Mantle as part of the same ownership and administrative framework as the six live networks.

Identity Protocol and Standards

The Billions Network identity layer is built on the W3C Decentralised Identifiers (DID) Core Specification, using the Iden3 DID method. Credentials issued within the network conform to the W3C Verifiable Credentials Data Model, enabling portable, standards-aligned attestations that can be selectively disclosed without revealing underlying personal data. The complete identity stack, Issuer Node, wallets, Verifier SDK, and Universal On-Chain Verifier, is implemented by and through the Privado ID framework (formerly Polygon ID), which maintains the open-source infrastructure supporting this standard.

Zero-Knowledge Proof Layer

Zero-knowledge proofs are generated client-side, on the user's own device. The prover operates within the mobile application or embedded browser environment and produces a compact cryptographic proof that an assertion holds (for example, that the user is over 18, or that they have passed a uniqueness check) without transmitting the underlying credential data to verifiers. Verification occurs on-chain using the Universal On-Chain Verifier contracts deployed on the Billions Network chain, which evaluate these proofs against the on-chain identity state. ZK circuits undergo external security review and testing before any major upgrade or deprecation, following a published schedule.

Cross-Chain Interoperability

Identity State Oracles broadcast DID state updates and credential status information across supported networks, including Ethereum, Polygon PoS, Aurora, and Linea, enabling verifiable proofs to be consumed by smart contracts and decentralised applications on multiple chains without requiring users to repeat the verification process on each. Developer integrations use WalletConnect and OAuth-like flows for both web and enterprise environments. Selective disclosure and pairwise DIDs prevent correlation of user identity across verifier domains and between sessions.

Architecture Stack

The full Billions Network architecture comprises the following components, each operating as part of an integrated verification and identity stack:

The Issuer Node provides a credential issuance back-end for credential providers, enabling them to issue verifiable credentials to users in a programmable, API-driven workflow. It is available as an open-source self-hosted deployment or as a managed service.

The Mobile Identity Wallet and Web Identity Wallet serve as the user-facing component of the system. The mobile wallet enables on-device verification and credential storage, including real-time camera-based passport scanning and liveness checks. The web wallet operates as an embedded, browser-native application requiring no download, supporting multi-device access and integration within third-party platforms.

The Verifier SDK enables applications and enterprises to request verifiable proof presentations from users in a flow analogous to OAuth-based authorisation. Applications receive a cryptographic proof of a claim (not the raw credential) allowing compliant, standards-aligned identity gates without touching personal data.

The Universal On-Chain Verifier is a set of smart contracts deployed on the Billions Network chain that accept and validate ZK proof presentations on-chain, enabling smart contracts in decentralised applications to condition logic on verified identity attributes.

Identity State Oracles enable cross-chain propagation of DID state, broadcasting identity status updates and revocation information to supported external networks, allowing verification to occur on networks other than the Billions Network chain itself.

The Billions Network Chain provides the settlement and anchoring layer for identity state. It runs as a Polygon CDK-based rollup with Ethereum Mainnet finality, hosting the on-chain verifier contracts, the identity state registry, and the staking infrastructure.

End-to-end encrypted storage governed by smart contracts provides a privacy-preserving data layer where credential-related data can be stored without Billions Network itself having access to plaintext user data.

The Agent SDK allows AI agents to obtain decentralised identifiers, receive foundational attestations linking them to a human or organisational owner, and present verifiable proofs of their identity, ownership, and declared policy constraints to interacting parties.

Third-Party Dependency

The identity protocol layer is built on and depends on the Privado ID (formerly 0xPolygonID) open-source framework. This dependency includes the Issuer Node implementation, the JS SDK, the circuit library, and the on-chain contract infrastructure. Any material changes to this upstream codebase may require corresponding updates to Billions Network's deployed components.

Ethereum Mainnet Proof-of-Stake

BILL transactions on Ethereum Mainnet are processed by the Ethereum network's proof-of-stake consensus protocol, which has been in operation since The Merge in September 2022. Consensus is achieved through a combination of the LMD-GHOST fork-choice rule and Casper the Friendly Finality Gadget. Validators stake a minimum of 32 ETH and are pseudo-randomly assigned to propose blocks and to attest to the canonical chain head.

Blocks are proposed by a single designated validator per slot (twelve seconds), and each validator committee attests to the block within that slot. Finality is reached after two consecutive epochs (approximately 12.8 minutes under normal network conditions) at which point the relevant checkpoint blocks become irreversible. The validator set is permissionless: any party meeting the minimum stake requirement may participate as a validator.

Billions Network Layer 2 Sequencing

The Billions Network chain, as a Polygon CDK-based rollup, processes transactions through a designated sequencer that orders and batches Layer 2 transactions. Batches of transactions are periodically submitted to Ethereum Mainnet, where they are validated and the resulting state root is anchored. Finality for transactions on the Billions Network chain is therefore derived from Ethereum Mainnet: once a batch is included and finalised on Layer 1, the corresponding Layer 2 state transitions become final. No distinct token stake is required to operate the sequencer; as its operation is governed by Billions Limited in the current phase of network development.

Ethereum Layer 1 Transaction Fees

All BILL transfers and interactions with the token contract on Ethereum Mainnet incur gas fees denominated in ETH. Gas fees are set by the Ethereum base-fee mechanism introduced under EIP-1559, adjusted per block in response to network demand, with an optional priority fee (tip) paid to the block proposer. Gas costs are not fixed and vary with network congestion. The ERC20Permit extension allows token approvals to be signed off-chain and submitted by a third party on behalf of the holder, which may reduce the number of on-chain approval transactions and associated gas expenditure.

Billions Network Layer 2 Transaction Fees

Transactions on the Billions Network chain, including ZK attestation submissions, identity state updates, and staking operations, incur Layer 2 transaction fees. These fees are lower than Ethereum Mainnet fees, reflecting the rollup's batching and compression architecture. Fees may be denominated in BILL or in ETH-equivalent gas, depending on the specific contract being called.

Protocol Verification Fees

Users and integrators pay verification and credential fees to the Billions Network protocol. Basic humanity proof fees are set at approximately USD 0.50 per verification. Full KYC and AML verification fees range from USD 3 to USD 5, with custom pricing available for enterprise integrations. Credential reuse fees generate ongoing revenue through small per-lookup charges on previously issued credentials, with near-zero marginal cost at scale.

Fees paid in BILL receive a discount of between 10% and 15% on the applicable service charge. This discount mechanism is designed to drive native demand for BILL within the verification economy.

Attester and Staking Incentives

Attesters, entities that issue verifiable credentials within the Billions Network, are required or strongly encouraged to stake BILL to participate in the network's trust registries. Stake size directly affects the reputation coefficient applied to a given attester's issued credentials. Higher stakes unlock access to premium credential types and priority network features.

Individual users who stake BILL gain enhanced reputation scores, priority access to newly issued credential types, and eligibility for ecosystem rewards. Vendors and enterprise integrations that stake receive higher API rate limits, priority technical support, and early access to new network features.

AI agents may stake BILL as collateral to signal trustworthy behaviour and to access higher-tier data and service tiers within the Billions Network ecosystem. Future protocol versions may introduce slashing mechanisms for agent misbehaviour as dispute resolution infrastructure matures.

Staking rewards for long-term participants are funded from within the Community allocation (40% of total supply), with 10% of that allocation (equivalent to 4% of the total token supply) dedicated to staking rewards and incentives.

FALSE

TRUE

There are 3 independent security audits that have been completed by Halborn Security covering the BILL token contract and the staking rewards smart contract infrastructure.

Halborn Security, December 2025, Billions Token Smart Contract Security Audit

• Object: Audit of the BILL token smart contracts on Ethereum Mainnet as deployed via a Transparent Proxy architecture. The scope covered the upgradeable ERC-20 implementation, the ERC20Permit extension (EIP-2612), the TimelockController governing upgrade execution, and the Transparent Proxy contract itself. The audit assessed the correctness of access controls, upgrade mechanisms, permit logic, and potential for supply manipulation or unauthorised minting.
• Results: The full findings are documented in the published Halborn audit report, available at https://www.halborn.com/audits/billions/billions-token-7661d8. The audit report is dated 9 December 2025.
• Actions: Billions Network engaged with Halborn's findings prior to token launch. The remediation status of all identified issues is set out in the published report. External security audits precede all major contract releases.

Halborn Security, January 2026, Billions Staking Rewards Smart Contract Security Audit (Initial)

• Object: Audit of the StakingRewards smart contract deployed on the Billions Network chain at 0x58201A4826Dc07443d1280bA194604B12A3b8FaB. The scope covered the contract's pausing functionality, administrative operations (including role assignment and privilege escalation paths), upgradeability via the proxy pattern, and the time-locking mechanisms applied to staked positions.
• Results: The full findings are documented in the published Halborn audit report, available at https://www.halborn.com/audits/billions/staking-rewards-0b472f. The audit report is dated 15 January 2026.
• Actions: Identified issues were addressed prior to the follow-up audit described below. The remediation status of all initial findings is set out in the published report.

Halborn Security, March 2026, Billions Staking Rewards Smart Contract Security Audit (Follow-up)

• Object: Follow-up audit of the StakingRewards contract conducted to verify remediation of findings from the January 2026 audit and to assess the security of changes introduced in the revised implementation. The scope covered the updated timelock configuration, the multi-signature control structure, and the status of all previously identified findings.
• Results: The full findings are documented in the published Halborn audit report, available at https://www.halborn.com/audits/billions/staking-rewards-2c6ee6. The audit report is dated 23 March 2026.
• Actions: All previously identified issues were reviewed in the follow-up engagement. The remediation confirmation and residual risk assessment are set out in the published report. Billions Network follows a policy of conducting external security and cryptography audits before major releases, with circuit upgrades and deprecations following a published schedule with grace periods for integrators.

Market volatility and liquidity

BILL may experience sharp price swings and variable liquidity, particularly around token generation, initial exchange listings and early secondary-market activity. Execution quality depends on venue depth and prevailing market conditions.

Multi-chain deployment and bridge risk

BILL is issued on Ethereum Mainnet and the Billions Network chain, and is made transferable to five further networks, namely BNB Chain, Base, Polygon PoS, Arbitrum and Optimism, through a LayerZero Omnichain Fungible Token Adapter operating on a lock-and-mint basis. Tokens transferred off Ethereum are held in the Adapter's lockbox contract for as long as they circulate on a connected network. The integrity of BILL's cross-chain supply depends on the continued security of the Adapter contract and of the LayerZero messaging layer that verifies and relays transfer instructions between networks: a compromise of either could allow a connected-network balance to become unbacked by its corresponding locked amount on Ethereum, or could prevent BILL from being moved back to Ethereum. Cross-chain transfers are also subject to message-delivery delay and destination-network congestion, independent of any error by the holder.

Access and jurisdiction risk

Access to BILL-related features, staking and rewards may be restricted by jurisdiction, sanctions controls, eligibility checks or regulatory requirements. Billions may also restrict or withhold participation where non-compliant, fraudulent or abusive conduct is identified.

Irreversibility and network-fee risk

Blockchain transactions involving BILL are irreversible once executed on the relevant network, and users remain exposed to variable gas fees, failed transactions, incorrect addresses and wallet-signing errors.

Key custody and operational security

Control of BILL depends entirely on the security of the user's wallet, private keys and recovery phrases. Billions does not custody users' private keys for staking services; loss or compromise of credentials results in permanent loss of token control.

Staking availability and reward variability

Staking may be subject to lock-up periods, minimum amounts, withdrawal limitations, jurisdictional restrictions and technical constraints. Reward rates are variable and may decrease to zero.

No investment, repayment or profit claim

BILL is a utility token and is not a deposit, e-money token, asset-referenced token, financial instrument, security or repayment claim. Acquisition or holding of BILL does not create financial-product rights or statutory return expectations.

Delisting Risks

Bitstamp Europe S.A. might remove the token from trading in line with Bitstamp Markets Trading Rules.

Issuer and operator structure risk

The token issuer was changed from ZKID LAB AG to Billions Limited (BVI), which creates uncertainty regarding the continuity of issuer obligations and the legal and contractual history of the project. Billions Limited is incorporated in the British Virgin Islands, where statutory requirements for public financial disclosure are limited; no 3-year audited financial history is available for the current issuer entity. As a result, holders cannot independently assess the issuer's financial stability, solvency position or operational track record prior to acquiring BILL. Additionally, Billions Limited operates the sequencer for the Billions Network Layer 2 in the current phase of network development, giving the issuer sole control over transaction ordering for identity state updates, staking operations and attestation records. If the sequencer is unavailable or is operated in a manner adverse to holders, no sequencer rotation mechanism or forced-transaction pathway is described in publicly accessible official documentation to guarantee continuity of Layer 2 operations.

Governance and future decision-making risk

BILL does not confer corporate ownership, dividends or corporate voting rights. In the absence of an active token-holder governance mechanism, all material decisions concerning protocol upgrades, parameter adjustments, fee structures and feature development remain at the sole discretion of the issuer. Holders currently have no formal mechanism to object to, delay or override such decisions, meaning that changes which affect BILL utility or access conditions may be implemented unilaterally. Broader token-holder governance is described as a planned mechanism from 2027, but the timing, scope and practical effect of future participation remain uncertain and are not contractually guaranteed. Until such mechanisms are operational, holders bear the risk that issuer decisions may not align with their interests.

Operational discretion and enforcement risk

Billions retains broad unilateral discretion to modify, suspend or discontinue platform features and to restrict, adjust, cancel or withhold token-related benefits, including staking rewards, airdrop eligibility, ecosystem incentives and premium feature access, in response to conduct it determines to be abusive, prohibited or non-compliant. This determination is made by Billions without any requirement for judicial or regulatory sanction. The criteria for such actions are not exhaustively defined in the platform terms, and the outcome may include effective denial of BILL utility even where the holder retains on-chain custody of their token balance. Holders cannot rely on the smart contract layer alone to guarantee access to all ecosystem benefits associated with BILL.

Regulatory and jurisdictional exposure

BILL availability and platform functionality depend on compliance with MiCA, sanctions, AML/KYC, data-protection and jurisdictional requirements. Features, verification methods and staking services may vary or become unavailable in certain jurisdictions.

Data protection and processor dependency risk

The platform processes account, wallet, biometric and identity-verification data using third-party providers for authentication, biometric verification, hosting, email delivery and payment flows. Failures, policy changes, cross-border transfer issues or data-protection incidents involving those providers could affect verification, rewards or support availability.

Utility and demand dependency

BILL utility depends on verification payments, credential fees, staking-based reputation, ecosystem rewards, future governance and AI-agent identity functions. Lower adoption of identity services, reusable credentials or partner integrations may reduce practical demand for the token.

Supply, allocation and unlock risk

BILL has a fixed total supply of 10,000,000,000 tokens and an initial circulating supply of approximately 24.28% at TGE. Allocations to Community, Foundation, Contributors, Investors and Creators are released over a 4-year schedule. These scheduled unlocks may increase circulating supply and affect market conditions.

Large-holder and treasury concentration risk

Foundation receives 32% of total supply, Contributors 20% and Investors 6%, with cliff and vesting arrangements for relevant categories. Transactions or unlocks by large allocation holders may affect liquidity, market depth and price discovery.

Rights and claims limitations

BILL does not grant ownership, dividend, corporate voting, repayment, profit-participation or financial-product rights. Holders depend on the token's functional utility rather than legal claims to issuer assets, revenue or distributions.

Staking and reward risk

Staking rewards are funded from a finite allocation of 400,000,000 BILL tokens (4% of total supply). Once this pool is exhausted, rewards will fall to zero unless the protocol is amended. The January 2026 Halborn audit identified 3 low-severity findings formally accepted as risk rather than remediated in the live staking contract, covering fee-on-transfer incompatibility, redundant lock-duration storage and expired lock-state persistence.

Credential-linked access risk

Certain credentials, badges, reward programmes and platform features accessible through BILL depend on completed verification steps, including human verification, government ID submission and uniqueness checks. Because BILL powers access to credential verification services, reputation staking, ecosystem reward eligibility and fee discount benefits, the revocation of a holder's verified credentials directly limits the practical utility of any BILL held by that user. Withdrawal of biometric consent may revoke the Proof of Uniqueness credential, which is a prerequisite for features, staking tiers and reward eligibility that require verified status. Holders who lose verified status through consent withdrawal or a failed re-verification process may therefore find a material portion of BILL's intended utility unavailable to them, regardless of their on-chain token balance.

Roadmap and delivery risk

The project roadmap includes token launch, initial CEX/DEX listings, market-maker agreements, expanded use cases, reusable credentials, monetisation and progressive governance. Delivery depends on technical execution, partner onboarding, regulatory alignment and user adoption.

Adoption and network-usage risk

BILL's economic model depends on verification usage, credential reuse, staking participation, attester quality and partner integrations. Slower-than-expected growth in verification volumes or ecosystem integrations may reduce the realised utility of the token.

Third-party infrastructure and upstream dependency risk

Billions relies on third-party providers for authentication, biometric verification, cloud hosting, email delivery and payment flows. Outages or policy changes may impair onboarding, verification, communications or platform availability. The entire Billions identity stack — Issuer Node, ZK circuit library, JS SDK and on-chain verification contracts — is built on the Privado ID (formerly 0xPolygonID) open-source framework. Material changes to that upstream codebase may require corresponding updates across deployed components.

Verification and biometric execution risk

Human verification, uniqueness checks and KYC-related flows require identity documents, biometric processing or third-party verification services. Errors, failed scans, consent withdrawal, provider unavailability or automated eligibility decisions may prevent access to features or rewards that depend on verified status.

Cross-chain and interoperability implementation risk

The architecture includes mobile and web wallets, Issuer Node, Verifier SDK, Universal On-Chain Verifier and Identity State Oracles broadcasting DID state to Ethereum, Polygon PoS, Aurora and Linea. Cross-chain identifiers and multi-network verification create integration risk if routing, proofs, schemas or network deployments do not operate consistently.

Platform continuity and modification risk

The platform is provided on an as-available basis and may be modified, suspended or discontinued. Interruptions, feature changes or service termination may affect identity services, staking interfaces, reward visibility and user participation.

Layer 2 sequencer centralisation and issuer control risk

Block production on the Billions Network Layer 2 is performed by a single designated sequencer operated by Billions Limited in the current phase of network development. If the sequencer is unavailable, no new Billions Mainnet blocks are produced and pending staking calls, identity state updates and attestation records cannot be processed. No sequencer rotation mechanism or forced-transaction pathway is described in publicly accessible official documentation.

Smart-contract vulnerability risk

BILL and staking functionality rely on smart contracts including an upgradeable ERC-20 and StakingRewards contract. Completed audits reduced known-defect risk but did not cover third-party dependencies, economic attacks or features introduced after the relevant audit commits.

Upgradeable contract and administrative control risk

The token uses a Transparent Proxy pattern and TimelockController and the staking architecture includes a multisig with operational powers to pause staking, set reward duration and recover ERC-20 tokens. Compromise, misuse or misconfiguration of these controls may affect upgrades, staking operations or user expectations.

Staking contract lock and withdrawal risk

The staking contract implements time-locked staking and has been audited for issues involving lock duration, locked balances, ownership and role management. Despite remediation of identified findings, staking remains exposed to implementation defects, lock-parameter errors, withdrawal constraints and user interaction errors.

Ethereum and Billions L2 dependency risk

BILL is deployed on Ethereum and Billions Mainnet. Identity state, proofs, attestations and reputation use Billions L2 with finality on Ethereum. Network congestion, gas-price changes, validator or client issues, finality delays (approximately 12.8 minutes under normal Ethereum conditions) or network-level attacks could affect transaction inclusion, state visibility and settlement confidence.

Identity proof, revocation and privacy technology risk

Billions uses DIDs, verifiable credentials, selective disclosure, pairwise DIDs, on-device proof generation and public revocation mechanisms. Errors in proof generation, revocation status, issuer keys, verifier-domain binding or device recovery may impair verification or expose users to failed authentication and access restrictions.

Oracle and cross-chain identifier risk

Identity State Oracles broadcast DID state updates to supported networks; on-chain ZK verifier smart contracts evaluate proofs against anchored state. Incorrect oracle routing, delayed cross-chain state propagation, verifier misconfiguration or unsupported network integrations may cause verification failures or inconsistent identity state across applications.

User-signing and wallet interaction risk

BILL users interact with wallets, smart contracts and EIP-712 typed-message flows. Opaque transaction data, broad approvals, incorrect contract addresses or compromised signing environments may lead to unintended transactions, failed staking actions or loss of access.

Quantum computing and cryptographic transition risk

BILL token signing uses ECDSA on the secp256k1 curve, ERC20Permit and EIP-712 authorisations rely on the same scheme. The Billions identity layer generates ZK proofs using circuits on pairing-friendly elliptic curves. A sufficiently advanced quantum computer running Shor's algorithm could in principle derive a private key from an exposed on-chain public key, enabling unauthorised transfers or forgeries without knowledge of the private key. Migration away from elliptic-curve cryptography requires Ethereum base-layer changes beyond any single issuer's control.

Data availability dependency and Polygon CDK upstream risk

The Billions Layer 2 uses Celestia as an external data availability layer. Extended Celestia unavailability or protocol incompatibility weakens the ability to reconstruct intermediate L2 states. The Billions L2 is built on the Polygon CDK rollup framework and changes to Polygon CDK's protocol, feature support or development roadmap may require significant adaptation of Billions L2 infrastructure.

Offer-related risks

• Access and jurisdiction risk: Jurisdictional restrictions and sanctions controls are applied at platform level. The enforcement of token-related measures requires documented evidence of non-compliant or abusive conduct and is subject to proportionality requirements, with notice and appeal channels available for material actions.
• Multi-chain deployment and bridge risk: The lock-and-mint design ties every connected-network BILL balance to an equivalent amount locked in the Adapter contract on Ethereum, so supply cannot be created on a connected network without a corresponding lock event on the anchor chain. Transfers are verified through LayerZero's Decentralised Verifier Network model, under which multiple independent verifiers must attest to a message before it is delivered, rather than a single relayer's attestation.
• Irreversibility and network-fee risk: ERC20Permit enables permit-based approvals through off-chain signatures, reducing the number of on-chain approval transactions required; users are responsible for verifying smart-contract addresses and securing wallet credentials before executing staking, claiming or withdrawal transactions.
• Staking availability and reward variability: Reward rates and lock parameters are governed by on-chain smart-contract configuration, publicly auditable on the Billions Mainnet explorer; no yield is guaranteed and staking reward sustainability is bounded by the finite 400,000,000 BILL allocation designated for staking incentives.

Issuer-related risks

• Operational discretion and enforcement risk: Billions' discretion to restrict token-related benefits is limited to cases supported by documented evidence of non-compliant or abusive conduct and is subject to an internal proportionality review, which reduces the risk of arbitrary or blanket enforcement. Where technically and legally feasible, Billions provides advance notice of material enforcement actions and makes appeal channels available to affected holders, enabling holders to contest adverse decisions. These procedural constraints do not remove the issuer's discretion but limit its exercise to documented and proportionate circumstances.
• Regulatory and jurisdictional exposure: Access restrictions for sanctioned and excluded jurisdictions are enforced through technical platform controls as the primary compliance mechanism.
• Data protection and processor dependency risk: Biometric data is processed under explicit consent, stored as encrypted FaceMap templates not shared with integrators, and deleted or anonymised on consent withdrawal. Data-subject rights and human review of automated decisions are available through the platform.

Crypto-assets-related risks

• Supply, allocation and unlock risk: Total supply is fixed at 10,000,000,000 tokens by smart contract with no mint function active after deployment. Allocation categories and 4-year vesting schedules are publicly documented, enabling advance monitoring of unlock events.
• Staking and reward risk: Staking is conducted from the user's own wallet without private-key custody by Billions Reward amounts are set by audited on-chain contract parameters, with the three low-severity findings accepted as risk in the January 2026 Halborn audit publicly disclosed in the published report.
• Credential-linked access risk: Credential revocation, deletion and consent-withdrawal consequences are defined in advance. FaceMap biometric templates are deleted or anonymised on consent withdrawal and human review of adverse credential decisions is available.

Project implementation-related risks

• Roadmap and delivery risk: Mobile and web wallet, Issuer Node, Verifier SDK, Agent SDK and Universal On-Chain Verifier are live, reducing delivery uncertainty for core protocol components.
• Third-party infrastructure and upstream dependency risk: Third-party data processors operate under defined processing agreements with EU-West-1 hosting and standard contractual safeguards; the Privado ID framework is open-source, enabling Billions to fork or adapt it in the event of upstream discontinuation.
• Verification and biometric execution risk: Verification checks are purpose-limited and consent-based; human review and appeal rights are available for automated decisions with significant effects on user access or eligibility.
• Cross-chain and interoperability implementation risk: W3C DID and Verifiable Credentials standards with versioned ZK circuits and published deprecation schedules mitigate integration breakage across wallets, verifiers and supported networks.
• L2 sequencer centralization and issuer control risk: Ethereum L1 finality protects state in submitted and finalised batches; previously settled L2 state cannot be reverted by the sequencer operator regardless of sequencer operational status.

Technology-related risks

• Smart-contract vulnerability risk: Three Halborn security audits cover the BILL token and StakingRewards contracts. All critical and medium findings were remediated before deployment and published audit reports are publicly accessible at halborn.com.
• Upgradeable contract and administrative control risk: All contract upgrades require a two-day TimelockController delay between proposal and execution; ProxyAdmin is controlled by the Timelock and day-to-day staking operations are governed by a multisig.
• Staking contract lock and withdrawal risk: The March 2026 Halborn follow-up audit found all four reported findings solved. ZK circuit upgrades follow a versioned deprecation schedule with grace periods for integrators.
• Ethereum and Billions L2 dependency risk: Ethereum PoS finality requires supermajority confirmation across 2 consecutive epochs (~12.8 minutes), making reversal of finalised state computationally prohibitive without major validator coordination.
• Identity proof, revocation and privacy technology risk: Pairwise DIDs, scoped credentials, verifier-domain-bound session nonces and revocation registries reduce cross-verifier correlation, replay exposure and compromised-credential risk. Any revoked credentials fail verification and users may request re-issuance.
• Oracle and cross-chain identifier risk: Versioned ZK circuits and credential schemas with published deprecation schedules reduce breakage risk when verifiers and applications rely on updated proof formats.
• User-signing and wallet interaction risk: EIP-712 domain-separated typed-message signing prevents cross-domain replay. Contract deployment addresses are published and verifiable in the official BillionsNetwork token repository on GitHub.
• Quantum computing and cryptographic transition risk: The upgradeable proxy architecture supports contract-level logic migration without token redeployment. ZK circuit upgrades follow a versioned deprecation schedule, allowing transition to updated cryptographic schemes as compatible standards emerge at Ethereum infrastructure level.
• Data availability dependency and Polygon CDK upstream risk: Ethereum L1 finality protects state in submitted and finalised batches regardless of Celestia availability. Previously committed L2 state anchored to Ethereum mainnet is not affected by Celestia outages or incompatibilities.

Bitstamp Europe S.A.

549300XIBGTJ0PLIEO72

BILL

Ethereum Mainnet Proof-of-Stake

BILL transactions on Ethereum Mainnet are processed by the Ethereum network's proof-of-stake consensus protocol, which has been in operation since The Merge in September 2022. Consensus is achieved through a combination of the LMD-GHOST fork-choice rule and Casper the Friendly Finality Gadget. Validators stake a minimum of 32 ETH and are pseudo-randomly assigned to propose blocks and to attest to the canonical chain head.

Blocks are proposed by a single designated validator per slot (twelve seconds), and each validator committee attests to the block within that slot. Finality is reached after two consecutive epochs (approximately 12.8 minutes under normal network conditions) at which point the relevant checkpoint blocks become irreversible. The validator set is permissionless: any party meeting the minimum stake requirement may participate as a validator.

Billions Network Layer 2 Sequencing

The Billions Network chain, as a Polygon CDK-based rollup, processes transactions through a designated sequencer that orders and batches Layer 2 transactions. Batches of transactions are periodically submitted to Ethereum Mainnet, where they are validated and the resulting state root is anchored. Finality for transactions on the Billions Network chain is therefore derived from Ethereum Mainnet: once a batch is included and finalised on Layer 1, the corresponding Layer 2 state transitions become final. No distinct token stake is required to operate the sequencer; as its operation is governed by Billions Limited in the current phase of network development.

See H.5

2026-01-01

2026-08-31

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at : https://www.micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: https://www.micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: https://www.micacryptoalliance.com/methodologies/esg

Land use: 12.35951 m²

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: https://www.micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: https://www.micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5). Estimates on individual node weight, hazardous components and depreciation rate are used.
Full methodology available at: https://www.micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5). Usage of natural resources is approximated through land use metrics. Land use, water use and water recycling are calculated based on energy mix-specific estimates of purchased electricity land intensity, purchased electricity water intensity, and water recycling rates.
Full methodology available at: https://www.micacryptoalliance.com/methodologies/esg