RAY MiCA White Paper

Index

General information Page 3
Part A - Information about the offeror or the person seeking admission to trading Page 4
Part B - Information about the issuer, if different from the offeror or person seeking admission to trading Page 5
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 Page 6
Part D - Information about the crypto-asset project Page 7
Part E - Information about the offer to the public of crypto-assets or their admission to trading Page 8
Part F - Information about the crypto-assets Page 9
Part G - Information on the rights and obligations attached to the crypto-assets Page 10
Part H – Information on underlying technology Page 11
Part I - Information on risks Page 12
Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts Page 13
RAY MiCA White Paper

General information

N Field Content
00 Table of contents

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

01 Date of notification

2026-05-29

02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114

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

03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114

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.

04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114

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.

05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114

False

06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114

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.

07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114

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.

08 Characteristics of the crypto-asset

RAY is the native crypto-asset of the Raydium protocol, a decentralised finance (DeFi) protocol built on the Solana blockchain.

The RAY token has a total supply of 555,000,000.

The Raydium protocol provides automated market maker (AMM) services, liquidity pools, token swaps, concentrated liquidity market maker (CLMM) functionality, yield farming and related decentralised trading infrastructure. The protocol is designed to enable users to provide liquidity, trade digital assets and participate in DeFi applications operating on Solana.

RAY does not provide holders with ownership rights, equity rights, repayment rights, guaranteed redemption rights, profit participation rights or claims against any legal entity. Holding RAY does not grant any rights comparable to shares, securities or other financial instruments.

09

Not applicable

10 Key information about the offer to the public or admission to trading

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

RAY MiCA White Paper

Part A - Information about the offeror or the person seeking admission to trading

N Field Content
A.1 Name N/A
A.2 Legal form N/A
A.3 Registered address N/A
A.4 Head office N/A
A.5 Registration date N/A
A.6 Legal entity identifier N/A
A.7 Another identifier required pursuant to applicable national law N/A
A.8 Contact telephone number N/A
A.9 E-mail address N/A
A.10 Response time (Days) N/A
A.11 Parent company N/A
A.12 Members of the management body N/A
A.13 Business activity N/A
A.14 Parent company business activity N/A
A.15 Newly established N/A
A.16 Financial condition for the past three years N/A
A.17 Financial condition since registration N/A
RAY MiCA White Paper

Part B - Information about the issuer, if different from the offeror or person seeking admission to trading

N Field Content
B.1 Issuer different from offerror or person seeking admission to trading

TRUE

B.2 Name

Raydium Foundation

B.3 Legal form

K575

B.4 Registered addess

c/o MetaBase58 Cayman Limited of 71 Fort Street, PO Box 10035 George Town, Grand Cayman

B.4 Country

Cayman Islands

B.4 Sub-division

KY1-1001

B.5 Head office

c/o MetaBase58 Cayman Limited of 71 Fort Street, PO Box 10035 George Town, Grand Cayman

B.5 Country

Cayman Islands

B.5 Sub-division

KY1-1001

B.6 Registration date

2024-12-10

B.7 Legal entity identifier N/A
B.8 Another identifier required pursuant to applicable national law 416504
B.9 Parent company

Not applicable

B.10 Members of the management body
Identity Business Address Functions
Marc Piano Horizons Global Ltd, Suite OS25 Harbour Walk, 52a Edgewater Way, Grand Harbour, Cayman Islands Director
Bryce Howarth Horizons Global Ltd, Suite OS25 Harbour Walk, 52a Edgewater Way, Grand Harbour, Cayman Islands Director
B.11 Business activity

Raydium foundation supports and develops the Raydium protocol, a decentralised exchange and AMM built on the Solana blockchain. The protocol provides decentralised liquidity provision, token swap and trading infrastructure through multiple pool types, including CPMM, CLMM and hybrid AMM pools. The business activity also includes supporting LaunchLab, a token issuance and liquidity bootstrapping platform within the Raydium ecosystem.

B.12 Parent company business activity

Not applicable

RAY MiCA White Paper

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

N Field Content
C.1 Name

Bitstamp Europe S.A.

C.2 Legal form

5GGB

C.3 Registered address

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

C.3 Country

Luxembourg

C.3 Sub-division

LU-LU

C.4 Head office

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

C.4 Country

Luxembourg

C.4 Sub-division

LU-LU

C.5 Registration date

2015-05-19

C.6 Legal entity identifier

549300XIBGTJ0PLIEO72

C.7 Another identifier required pursuant to applicable national law

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

C.8 Parent company

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

C.9 Reason for crypto-asset white paper Preparation

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).

C.10 Members of the management body
Identity Business Address Functions
Johann Kerbrat 40, Avenue Monterey, L-2163, LU Director
Robert Caplehorn 40, Avenue Monterey, L-2163, LU Director
Roger Younan 40, Avenue Monterey, L-2163, LU Director
Jerome Dave 40, Avenue Monterey, L-2163, LU Authorised Manager
Gillian Gallimore 40, Avenue Monterey, L-2163, LU Authorised Manager
Cygnarowicz Damian MichaŁ 40, Avenue Monterey, L-2163, LU Authorised Manager
C.11 Operator business activity

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.

C.12 Parent company business activity

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

C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

MiCA Crypto Alliance Limited

C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

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.

RAY MiCA White Paper

Part D - Information about the crypto-asset project

N Field Content
D.1 Crypto-asset project name

Raydium

D.2 Crypto-asset name

Raydium

D.3 Abbreviation

RAY

D.4 Crypto-asset project description

Raydium is a DeFi project built on the Solana blockchain that provides a range of on-chain trading, liquidity and yield generation products. The project operates through decentralised smart contracts and infrastructure designed to facilitate the exchange, trading and provision of liquidity for crypto-assets within the Solana ecosystem.

The core products of the Raydium project include AMM and Constant Product Market Maker (CPMM)liquidity pools, CLMM pools, token swap functionality, liquidity provision infrastructure, yield farming mechanisms and staking functionality. Raydium enables users to deposit crypto-assets into liquidity pools to facilitate trading and to receive liquidity provider incentives and fees generated through protocol activity.

Raydium also provides concentrated liquidity functionality, which allows liquidity providers to allocate liquidity within selected price ranges. The protocol further supports routing and aggregation mechanisms designed to optimise token swap execution across available liquidity sources within the Solana ecosystem.

In addition, the project includes launch and token distribution infrastructure through LaunchLab, Raydium’s token-launch program within the Raydium ecosystem. LaunchLab enables projects to deploy tokens against a bonding curve, with trading taking place against that curve until a funding threshold is reached, after which the remaining curve supply and collected quote tokens may be migrated into a Raydium AMM pool, where trading continues. The project also supports staking functionality associated with the RAY token and governance participation mechanisms connected to protocol development and ecosystem decisions.

Raydium protocol applies several protocol fee categories associated with the operation of its decentralised finance infrastructure. These include swap fees, pool creation fees, Solana network rent requirements and LaunchLab-related fees.

Swap fees apply to token swap transactions conducted through Raydium products and are used for purposes including liquidity provider incentives, RAY buyback mechanisms and treasury-related allocations. Pool creation fees apply when users create CPMM or Standard AMM v4 liquidity pools and are intended to support protocol infrastructure and mitigate spam-related activity. Solana network rent requirements apply in connection with the creation of pools, liquidity positions, farms and token accounts and relate to blockchain account storage requirements on the Solana network. LaunchLab fees apply in connection with token launch and graduation mechanisms within the LaunchLab infrastructure and support protocol and creator-related fee flows.

The RAY token is used within the Raydium ecosystem for governance participation, staking and incentive mechanisms associated with liquidity provision and protocol participation. The project may evolve through governance decisions, protocol upgrades and ongoing technical development. RAY token is not needed to pay any of the Radyium protocol fees.

D.5 Details of all natural or legal persons involved in implementation of crypto-asset project
Name of person Type of person Business address Domicile
Raydium Foundation
Development team
c/o MetaBase58 Cayman Limited of 71 Fort Street, PO Box 10035 George Town, Grand Cayman KY1-1001, KY
Cayman Islands
D.6 Utility Token Classification

FALSE

D.7 Key Features of Goods/Services for Utility Token Projects

Not applicable

D.8 Description of past milestones

Past milestones

Raydium launched on the Solana blockchain in February 2021 as a hybrid AMMintegrating constant-product liquidity pools with Serum’s, later OpenBook’s, central limit order book infrastructure. The initial product launched as AMM v4 and used standard constant-product pool mechanics combined with order book integration to improve trade execution and liquidity access.

Farm v3 was launched alongside AMM v4 to incentivise liquidity provision by distributing Raydium’s native RAY token to liquidity providers who staked their LP tokens, thereby supporting the growth of total value locked (TVL) within the protocol in March 2021.In May 2021, Raydium introduced AcceleRaytor, a token launch platform for projects within the Solana ecosystem.

In 2022, Raydium introduced CLMM infrastructure. The CLMM implementation entered public testing in April 2022 and launched on the Solana mainnet in August 2022. In October 2022, Farm v5 was deployed with support for multiple reward streams, scheduled emissions and additional administrative controls. During the same year, the project underwent audits conducted by MadShield and OtterSec.

In December 2022, Raydium disclosed a pool authority compromise affecting certain AMM v4 liquidity pools. This incident related to operational key management rather than a protocol bug. Following the incident, authority roles were migrated to multisignature infrastructure and the project published incident response documentation.

In 2023, Raydium deployed Farm v6 using Anchor architecture and introduced support for Solana Token-2022 standards within concentrated liquidity pools. Additional audits and infrastructure updates were conducted during this period.

In 2024, the project announced and deployed CPMM infrastructure intended as the long-term replacement for AMM v4, without any external dependencies beyond SPL Token and Token-2022, such as OpenBook and Serum legacy. During the same year, Raydium launched LaunchLab, replacing the earlier AcceleRaytor platform with a token launch infrastructure using bonding curve and liquidity pool mechanisms. Additional audits relating to CPMM and LaunchLab were completed during 2024.

In January 2025 the total value locked in CPMM exceeded the total value locked in AMM v4 following ongoing community-led liquidity migration activities. In July 2025, the total value locked in the CLMM product exceeded USD 1 billion for the first time. In November 2025, Raydium deployed CPMM v0.2, which included fixes relating to an accounting edge case identified during an OtterSec re-audit. The official documentation states that no user funds were impacted.

D.8 Description of future milestones

Future milestones

Raydium continues to operate and maintain multiple decentralised trading, liquidity provision, staking and token launch products within the Solana ecosystem.

D.9 Resource allocation

The token has a maximum supply of 555,000,000 RAY and uses six decimal places. The official mint address of the RAY token is 4k3Dyjzvzp8eMZWUXbBCjEvwSkkk59S5iCNLY3QrkX6R.

34% of the total token supply, representing 188,700,000 RAY, is allocated to the mining reserve. The current emissions of the crypto-asset is coming from the mining reserve, representing approximately 1,900,000 RAY per year. Additional allocations include 30% of the total supply allocated to partnerships and ecosystem development, 20% allocated to the team, 8% allocated to liquidity initiatives, 6% allocated to community and seed allocations and 2% allocated to advisors.

The team and seed allocations were fully locked during the first 12 months following the token generation event and subsequently unlocked linearly on a daily basis between months 13 and 36. Accordingly, vesting concluded on 21 February 2024.

D.10 Planned use of Collected funds or crypto-Assets

Not applicable

RAY MiCA White Paper

Part E - Information about the offer to the public of crypto-assets or their admission to trading

N Field Content
E.1 Public offering or admission to trading

ATTR

E.2 Reasons for public offer or admission to trading

By admitting the RAY asset to trading, holders of the token will gain transparent price discovery and improved liquidity. This enables the project’s community and ecosystem participants to more easily enter and exit positions, supporting a dynamic and efficient market.

E.3 Fundraising target N/A
E.4 Minimum subscription goals N/A
E.5 Maximum subscription goals N/A
E.6 Oversubscription acceptance N/A
E.7 Oversubscription allocation N/A
E.8 Issue price N/A
E.9 Official currency or any other crypto-assets determining the issue price N/A
E.10 Subscription fee N/A
E.11 Offer price determination method N/A
E.12 Total number of offered/traded crypto-assets 268967970

The circulating supply of RAY changes over time as tokens are released into circulation in accordance with the allocation and emission mechanisms.

For the purpose of complying with the technical requirements of the MiCA Regulation XBRL taxonomy, a circulating supply of 268967970.467351 has been reflected as the number of tokens in the machine-readable version of the white paper. This figure emerges from https://api.raydium.io/ray/circulating, as consulted on 12 May 2026 is indicative and may vary over time depending on the token emissions, vesting releases, market activity of RAY tokens.
E.13 Targeted holders

ALL

E.14 Holder restrictions N/A
E.15 Reimbursement notice N/A
E.16 Refund mechanism N/A
E.17 Refund timeline N/A
E.18 Offer phases N/A
E.19 Early purchase discount N/A
E.20 Time-limited offer N/A
E.21 Subscription period beginning N/A
E.22 Subscription period end N/A
E.23 Safeguarding arrangements for offered funds/crypto-Assets N/A
E.24 Payment methods for crypto-asset purchase N/A
E.25 Value transfer methods for reimbursement N/A
E.26 Right of withdrawal N/A
E.27 Transfer of purchased 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. 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.

E.28 Transfer time schedule N/A
E.29 Purchaser's technical requirements

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.

E.30 Crypto-asset service provider (CASP) name N/A
E.31 CASP identifier N/A
E.32 Placement form

NTAV

E.33 Trading platforms name

Bitstamp Europe S.A.

E.34 Trading platforms Market identifier code (MIC)

BESA

E.35 Trading platforms access

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

E.36 Involved costs

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.

E.37 Offer expenses

Not applicable

E.38 Conflicts of interest

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.

E.39 Applicable law

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

E.40 Competent court

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

RAY MiCA White Paper

Part F - Information about the crypto-assets

N Field Content
F.1 Crypto-asset type

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

F.2 Crypto-asset functionality

The token is used within the Raydium ecosystem for governance participation, staking and liquidity-related functions associated with the operation of the protocol and its DeFi infrastructure.

RAY may be used in connection with staking mechanisms available through the Raydium application. The token is also used in liquidity pools and may function as a base or quote asset within Raydium trading infrastructure. A portion of trading fees generated through the Raydium protocol is used to buy back RAY tokens.

The Raydium protocol provides decentralised trading and liquidity infrastructure through products including automated market maker pools, CLMM pools, liquidity farming infrastructure, token swap routing mechanisms and token launch infrastructure. RAY is associated with participation in and interaction with these ecosystem functionalities.

Ownership or use of RAY is not required in order to swap tokens, provide liquidity, create pools or use perpetual trading functionality within the Raydium ecosystem.

F.3 Planned application of functionalities

Not applicable

F.4 Type of crypto-asset white paper

OTHR

F.5 The type of submission

NEWT

F.6 Crypto-asset characteristics

RAY is the native crypto-asset of the Raydium protocol, a DeFi protocol built on the Solana blockchain.

The RAY token has a total supply of 555,000,000.

The Raydium protocol provides AMM services, liquidity pools, token swaps, CLMM functionality, yield farming and related decentralised trading infrastructure. The protocol is designed to enable users to provide liquidity, trade digital assets and participate in decentralised finance applications operating on Solana.

RAY does not provide holders with ownership rights, equity rights, repayment rights, guaranteed redemption rights, profit participation rights or claims against any legal entity. Holding RAY does not grant any rights comparable to shares, securities or other financial instruments.

F.7 Commercial name or trading name

Raydium Protocol

F.8 Website of the issuer

https://raydium.io/

F.9 Starting date of offer to the public or admission to trading

2026-07-01

F.10 Publication date

2026-06-30

F.11 Any other services provided by the issuer

Not applicable

F.12 Language or languages of the crypto-asset white paper

English

F.13 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available

BL6GMJNDW

F.14 Functionally fungible group digital token identifier, where available

7HFXRDFHH

F.15 Voluntary data flag

FALSE

F.16 Personal data flag

TRUE

F.17 LEI eligibility

TRUE

F.18 Home Member State

Luxembourg

F.19 Host Member States

Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden

RAY MiCA White Paper

Part G - Information on the rights and obligations attached to the crypto-assets

N Field Content
G.1 Purchaser rights and obligations

Not applicable as the RAY crypto-asset holders do not acquire any ownership, equity, profit participation, repayment, or redemption rights against any natural or legal person associated with the Raydium project. Holding RAY does not give rise to contractual claims or entitlements against any natural or legal person.

G.2 Exercise of rights and obligations

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

G.3 Conditions for modifications of rights and obligations

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

G.4 Future public offers

Not applicable

G.5 Issuer retained crypto-assets 111000000
G.6 Utility Token Classification

FALSE

G.7 Key features of goods/services of utility tokens

Not applicable

G.8 Utility tokens redemption

Not applicable

G.9 Non-trading request

TRUE

G.10 Crypto-assets purchase or sale modalities

Not applicable

G.11 Crypto-assets transfer restrictions

Not applicable

G.12 Supply adjustment protocols

FALSE

G.13 Supply adjustment mechanisms

Not applicable

G.14 Token value protection schemes

FALSE

G.15 Token value protection schemes description

Not applicable

G.16 Compensation schemes

FALSE

G.17 Compensation schemes description

Not applicable

G.18 Applicable law

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.

G.19 Competent court

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.

RAY MiCA White Paper

Part H – Information on underlying technology

N Field Content
H.1 Distributed ledger technology

Not applicable as DTI is provided in F.13

H.2 Protocols and technical standards

RAY is a fungible token issued on the Solana mainnet-beta network under the Solana Program Library (SPL) token standard. All protocols, standards, and interfaces described in this section are those of the Solana network and the SPL Token program on which RAY operates; Raydium does not operate a separate distributed ledger.

Networking, Transport and Session

RAY transactions and Raydium protocol interactions reach the network through Solana's remote procedure call (RPC) interface, which provides HTTP and WebSocket endpoints for reading network state, submitting transactions, simulating execution, and subscribing to live updates. RPC requests target a specific cluster: the mainnet endpoint serves production traffic using real SOL, whilst devnet and testnet serve development and validator testing, respectively. Public RPC endpoints are shared infrastructure subject to rate limits and traffic restrictions; production applications are expected to use dedicated or private RPC infrastructure.

Commitment levels govern how finalised a state view must be before a node returns data. The processed level reflects the node's most recently processed block, which may still be rolled back. Confirmed reflects a block that a supermajority of the network's active stake has voted on directly. Finalised reflects a block the cluster has recognised with maximum lockout, the strongest confirmation state available on the network.

At the application layer, Raydium publishes a REST API (v3) for querying pool, mint, farm, and chain-time data on Solana, and a route API for computing swap quotes and building swap transactions. These interfaces support front ends, wallets, and integrators in constructing Raydium-related transactions and reading protocol state; settlement remains an on-chain Solana transaction and does not bypass the network's consensus process. Solana RPC supplies the base read-and-write interface for the network, providing state queries, transaction submission, simulation, and live WebSocket subscriptions.

Serialisation

Solana transactions comprise signatures and a message, with the message carrying account addresses, a recent blockhash, and compiled instructions. Multiple instructions may be composed into a single transaction, allowing a single user interaction to span several Solana programs or account updates within one atomic execution unit. The current maximum transaction size is 1,232 bytes; an increase to this limit is under development and expected by Agave 4.1 but does not form part of the current baseline.

RAY transfers are executed as an SPL Token program Transfer instruction, which moves token units between token accounts. The owner of the sender's token account must sign the transaction; a transfer cannot proceed without an authorised signature and cannot alter balances outside the Token program's instruction logic.

Cryptography and Key Material

Solana accounts are keyed by 32-byte addresses. Transaction signing uses the Edwards-curve Digital Signature Algorithm (Ed25519); the base network fee covers Ed25519 signature verification, with additional precompile verifications supported for Secp256k1 and Secp256r1. Proof of History uses a sequentially run cryptographic hash function, chosen so that output cannot be predicted without fully executing the function, to create an ordered, verifiable record of events that can be checked in parallel by multi-core verifiers.

The RAY mint account records supply, decimal precision, mint authority, and freeze authority in its on-chain state. No mint authority is present on the RAY mint, meaning the supply is permanently fixed and no further tokens may be minted by any party. No freeze authority is set, meaning no party can freeze holder token accounts. Solana Explorer confirms this configuration.

Ledger

Solana's ledger stores state in accounts. Each account holds lamports, arbitrary data, an owner program, an executable flag, and a rent epoch. programs are stateless: mutable program state lives in separate data accounts passed to program instructions as arguments. The RAY mint, holder token accounts, and Raydium program accounts are each distinct Solana accounts, updated exclusively by valid signed transactions.

Each RAY token account records the mint, the account owner, and the token amount held. Associated token accounts derive a deterministic default address from the owner's public key and the RAY mint address, providing a standard derivation path for wallets and integrators without requiring an additional on-chain lookup.

Execution

Solana programs are compiled to the Solana Bytecode Format (sBPF) and are stateless. Instructions carry a program identifier, a list of accounts, and opaque instruction data. RAY token transfers execute under the SPL Token program. Raydium protocol interactions, swaps, liquidity provision, farming, and staking, execute under the respective Raydium program identifiers on the Solana mainnet-beta runtime.

Token Standards

RAY is an SPL token under the original Token program. The original Token program provides core token functionality, minting, transfer, delegation, freezing, and burning, and is immutable and widely deployed across the Solana ecosystem. Token-2022, the extension-capable successor program, is used in Raydium's CPMM for pool pairs denominated in Token-2022 tokens. The RAY mint itself is not a Token-2022 mint and carries none of the extension configurations available under that program.

Permits, Approvals and Compliance

The SPL Token program supports delegated spending authority: a token-account owner may approve a delegate to transfer or burn a defined amount on their behalf, and may revoke that delegation at any time. Authority roles which are mint authority, freeze authority, account owner, and close authority, may be changed or renounced at the mint or token-account level. No transfer restriction, allow-list, or compliance hook specific to RAY is identifiable in the token's current on-chain configuration. Solana Explorer records no programmable configuration on the RAY mint.

H.3 Technology used

Implementation and Architecture

RAY is implemented as a Solana SPL token. Raydium's protocol is delivered through a set of Solana on-chain programs, each deployed at a canonical mainnet-beta program address. The active program set comprises AMM v4, CPMM, CLMM, Stable AMM, Farm v6, LaunchLab, AMM Routing, and Burn & Earn or LP Lock. Farm v3 and Farm v5 remain deployed and operational for existing positions but are in wind-down: no new farms are accepted on these versions, and all new ecosystem farms are created exclusively on Farm v6. Farm v3 additionally serves as the legacy RAY single-asset staking program.

AMM v4 is a constant-product market maker that was originally integrated with the OpenBook CLOB. That OpenBook integration has since been deactivated; AMM v4 pools no longer share liquidity to OpenBook, and all swaps execute purely against the constant-product curve. AMM v4 is in stewardship mode having security fixes only, with no new feature development, and new pool creation is discouraged in favour of CPMM.

CPMM is the current default constant-product pool, rewritten in the Anchor framework. It supports Token-2022 pairs, requires no OpenBook market account, and has a simpler account structure than AMM v4. CLMM is the concentrated liquidity program and operates on a single program version; improvements are delivered as in-place upgrades behind the 24-hour timelocked upgrade multisig rather than as new program generations. A SwapV2 instruction was added to CLMM to handle Token-2022 transfer-fee mathematics correctly; integrators should target SwapV2 for Token-2022 pairs.

Program-derived addresses (PDAs) are used throughout the architecture for account organisation. PDAs are deterministic addresses derived from a program identifier and seed bytes; only the owning program may sign on behalf of a PDA through Solana's cross-program invocation mechanism. Canonical PDA seed conventions are published for CPMM and CLMM account types. Token-pair ordering in CPMM pool PDAs follows public-key byte order (token0 < token1) before hashing.

AMM v4, CPMM, and CLMM ship with public source repositories under the Raydium GitHub organisation. Stable AMM, LaunchLab, AMM Routing, Burn & Earn or LP Lock, and the Farm programs are closed-source and verifiable against live on-chain bytecode and published IDL schemas in the raydium-idl repository.

Runtime and Build Parameters

Solana programs are compiled to sBPF and deployed via the standard BPF Loader v3 upgrade mechanism. Raydium operates two distinct Squads multisigs for program governance. The program upgrade multisig operates at a 3-of-4 threshold with a mandatory 24-hour timelock; it is the sole authority for deploying new bytecode for all Raydium programs. The four signers are independent, air-gapped cold-device holders; signing is sequential and every transaction carries a fixed expiration window. The treasury multisig operates at a 3-of-5 threshold with no timelock and governs operational roles including creating new AmmConfigs, sweeping protocol fees, and configuring pool parameters.

Raydium has not set any program's upgrade authority to null. All programs remain upgradeable; users can monitor pending upgrade transactions through the public Squads Protocol interface, which provides a 24-hour window to respond before any upgrade executes.

Account-level operational authorities, including protocol-owner and fund-owner fields in CPMM and CLMM AmmConfig accounts, are stored on-chain and may differ from the program-level admin key. For CLMM specifically, a separate limit-order admin role exists: a single operational hot wallet (not a multisig) that can settle and close filled limit orders on behalf of their owners, routing output exclusively to the order owner's associated token account. This role cannot open, modify, or redirect orders, and cannot interact with any other program instruction.

AmmConfig accounts, which define fee tiers and tick spacings, are created by the treasury multisig. Existing pools reference their AmmConfig by PDA; the pool's fee parameters are whatever the AmmConfig specifies at the time of interaction. Protocol policy is to create a new AmmConfig for any fee-tier change rather than modifying an existing config, because modifying a deployed AmmConfig would silently affect all pools referencing it.

Dependencies

Token interactions depend on the Solana Token program for RAY and non-Token-2022 pool tokens, and on the Token Extension program for Token-2022 pool pairs. Published IDL schemas serve as the verifiable interface for each program. A 2021 security review performed RustSec advisory checks on the AMM and staking codebase, identifying dependency advisories present in that historical version at the audited commit hashes; those findings are specific to that codebase snapshot.

Deployment and Addresses

The RAY mint address is 4k3Dyjzvzp8eMZWUXbBCjEvwSkkk59S5iCNLY3QrkX6R. The token has a fixed maximum supply of 555,000,000 units with six decimal places of precision. Solana Explorer records the circulating fixed supply at 554,997,740.34359 RAY, consistent with the absence of a mint authority. Protocol program identifiers for all mainnet-beta deployments are published in the Raydium documentation and are independently verifiable on-chain; the expected upgrade authority for each program is the 3-of-4 program upgrade multisig.

Client Interfaces and SDKs

Application access is provided through Raydium's REST API v3 and route APIs, together with published program IDLs that underpin SDK and front-end integrations. The live API at api-v3.raydium.io provides configuration lookups including AmmConfig lists for CPMM and CLMM, which should be fetched at runtime rather than hardcoded, as new configs may be added at any time. Solana RPC and WebSocket subscriptions provide the base connectivity layer for balance queries, transaction submission, and event streaming. On-chain token and program state is independently verifiable through block explorers such as Solana Explorer.

H.4 Consensus Mechanism

RAY does not run a standalone consensus mechanism. As a Solana SPL token, its issuance record, transfers, and token-account balances are ordered, validated, and finalised by Solana's consensus process. Raydium's on-chain programs add application logic but do not alter or substitute for Solana's underlying consensus.

Solana's consensus architecture combines Proof of History with a Proof-of-Stake validator voting process. Proof of History is a sequential cryptographic hash computation that produces a verifiable record of the ordering and passage of time between events. A designated leader sequences user messages, executes transactions against current state, and publishes the resulting state signature to verifier nodes. Verifier nodes execute the same transactions on their own state copies and publish signed confirmations, which serve as votes in the consensus process.

Solana's consensus protocol is Tower BFT, a variant of Practical Byzantine Fault Tolerance that uses Proof of History as a cryptographic clock. Validators vote on the PoH sequence using an exponential lockout mechanism: each vote commits the validator to the voted fork for a doubling lockout period, making it progressively harder to roll back earlier votes and producing increasing practical finality as confirmations accumulate.

Consensus validity requires a supermajority involving 2-of-3 of validators weighted by their staked bonds. A branch is accepted once a supermajority of bonded validators votes within the prescribed timeout. The leader for each slot is determined by a stake-weighted leader schedule computed at the start of each epoch. If the scheduled leader for a slot fails to produce a block, that slot is skipped and the network moves to the next scheduled leader; no election occurs at the time of failure.

Slashing, the penalty destruction of a portion of a validator's stake for double-voting or voting on an invalid hash, is a stated roadmap objective, but the Solana network currently has no in-protocol slashing implementation. The first planned step is the introduction of slashing proofs without any automatic penalty enforcement. . No slashing penalties are presently enforced on the Solana mainnet.

An updated consensus protocol, Alpenglow, is under development and targeted for Agave 4.1. Alpenglow would replace Proof of History and on-chain vote transactions with a new mechanism designed to deliver approximately 150-millisecond confirmation times, and would introduce a Validator Admission Ticket fee of 1.6 SOL per epoch for validators included in the consensus set. Until Alpenglow is active on mainnet, Solana's current Proof of History and Proof-of-Stake mechanism governs RAY transactions.

H.5 Incentive Mechanisms and Applicable Fees

Network-Level Fees

Every RAY transfer and every Raydium protocol interaction settles as a Solana transaction and incurs a network fee. The total fee is the sum of a base fee and an optional prioritisation fee. The base fee is 5,000 lamports per signature and is charged whether the transaction succeeds or fails, deducted from the fee payer before execution begins. 50% of the base fee is burned, permanently removed from the circulating SOL supply, and the remaining 50% is distributed to the block-producing validator. The prioritisation fee, calculated as the compute-unit price multiplied by the compute-unit limit divided by 1,000,000 lamports, is paid entirely to the validator and is not burned. Account rent is also payable when creating pools, positions, farms, or token accounts; rent is a redeemable deposit recoverable on account closure and is separate from Raydium protocol fees.

Protocol-Level Fees

Every swap on Raydium incurs a trading fee calculated as a percentage of the trade amount. The liquidity-provider, RAY buyback and treasury allocations are then calculated as percentages of that trading fee. For CLMM and CPMM pools, 84% of the trading fee is distributed to liquidity providers, 12% funds RAY buybacks, and 4% goes to the treasury. For Standard AMM v4 pools, 88% is distributed to liquidity providers and 12% funds RAY buybacks, with no treasury allocation. Common swap-fee tiers differ by product: CLMM pools are available at 0.01%, 0.05%, 0.25%, and 1%; CPMM pools at 0.01%, 0.25%, and 1%; AMM v4 pools use a fixed legacy rate of approximately 0.25%.

CPMM and CLMM use a fee denominator of 1,000,000 (so a stored value of 2,500 represents 0.25%); AMM v4 uses a denominator of 10,000. The default CPMM AmmConfig (index 0, standard 0.25% pool) additionally carries a creator fee of 500 basis points in the 1,000,000 denominator, equivalent to 0.05% of trade volume, routed to the original pool creator.

Pool creation fees apply when creating a CPMM or Standard AMM v4 pool: 0.15 SOL per pool, payable to the protocol for spam prevention and infrastructure support. CLMM pools carry no separate Raydium pool creation fee; only Solana account rent applies.

Fee Collection and Buyback Routing

Protocol-side fees accumulate at program-specific collection addresses before being converted and routed: the CLMM collection address is projjosVCPQH49d5em7VYS7fJZzaqKixqKtus7yk416, the CPMM collection address is ProCXqRcXJjoUd1RNoo28bSizAA6EEqt9wURZYPDc5u, and the AMM v4 collection address is PNLCQcVCD26aC7ZWgRyr5ptfaR7bBrWdTFgRWwu2tvF. Each collection address may hold various SPL tokens, as fees are paid in the tokens traded by each pool. Bought-back RAY is held by the protocol at the public on-chain address DdHDoz94o2WJmD9myRobHCwtx1bESpHTd4SSPe6VEZaz, which can be inspected directly on any Solana block explorer. Bought-back RAY is retained by the protocol and is neither redistributed nor burned.

Validator Incentives

Solana validator rewards are funded by base-fee proceeds and staking inflation. SOL staked and delegated to a validator increases the probability of that validator being selected to produce blocks; validators and their delegators earn proportionally more rewards as transaction throughput increases. Validators may charge commission as a percentage of rewards earned by their delegators. A further under-development protocol change, SIMD-123, would additionally enable validators to share block revenue, comprising priority fees and maximal extractable value, with delegators on-chain at each epoch.

SIMD-0123 is currently in the review stage and has not been approved or activated on mainnet; it is not an active reward mechanism at the time of this white paper.

RAY Staking

RAY holders may stake RAY through an application-level mechanism to earn additional RAY rewards. This is executed by the Farm v3 program, which operates as the legacy RAY single-asset staking program and remains functional for this purpose. It is distinct from Solana validator staking: it is a protocol-level farming arrangement distributing RAY token rewards proportional to staked balances, with no connection to Solana consensus security or SOL validator reward flows.

Governance of Protocol Parameters

Raydium protocol parameters are managed through the program-level upgrade multisig (3-of-4, 24-hour timelock) and the treasury multisig (3-of-5, no timelock). New AmmConfig accounts, which set fee tiers and fee splits, are created by the treasury multisig; existing pool fee parameters derive from their referenced AmmConfig and cannot be changed by modifying an existing config in practice. No RAY tokenholder governance mechanism for protocol parameters currently exists on-chain, though the prior RAY white paper identifies governance participation as a planned feature. Solana base-layer parameters are governed through the Solana Improvement Document (SIMD) process.

H.6 Use of distributed ledger technology

FALSE

H.7 DLT functionality description N/A
H.8 Audit

TRUE

H.9 Audit outcome

Security audits of Raydium's technology have been conducted by Kudelski Security/Nagravision, OtterSec, MadShield, Halborn, and Sec3. Members of the Neodyme team have additionally performed reviews under bug-bounty agreements. The audits span ten engagements across successive program generations, covering the order-book AMM, concentrated liquidity, staking, CPMM, LaunchLab, and the LP lock program; assessing logic correctness, account validation, arithmetic handling, Token-2022 composability, administrative access controls, and dependency hygiene. A continuous bug-bounty program is also active on Immunefi, covering on-chain programs, SDKs, and off-chain components.

Kudelski Security/Nagravision, Q2 2021, Raydium Order-Book AMM Security Code Review Assessment

  • Object: External security code review of the Raydium AMM and staking smart-contract applications on the Solana blockchain. The engagement ran from 15 March to 9 April 2021 against identified commit hashes in the raydium-staking and raydium-amm repositories. Third-party libraries were out of scope.
  • Results: 0 high, 4 medium, 5 low, and 3 informational findings. Findings concerned memory and secure-information handling, arithmetic overflow, low test coverage, coding practices, RustSec advisory exposure, and sensitive-data zeroing.
  • Actions: Several findings, including RustSec dependency advisories and sensitive-data zeroing, remained open at the time of publication. The report does not confirm final closure of these findings.

OtterSec, Q3 2022, Raydium Staking program Audit

  • Object: Assessment of the raydium-staking program, which allows users to stake tokens to earn reward tokens, and the farm program, which allows users to stake liquidity-pool tokens to earn up to two reward tokens. The audit was performed against commit 76a2744.
  • Results: 5 findings in total: 1 critical, 0 high, 0 medium, 0 low, and 4 informational. The critical finding concerned missing validation on a reward vault account that could allow an attacker to steal liquidity-provider tokens.
  • Actions: The critical vulnerability was resolved, with corrective account validation confirmed in the report. Informational recommendations addressed code redundancy, ambiguous program states, purposeless instructions, and optional reward vault inconsistency.

OtterSec, Q3 2022, Raydium Updated Order-Book AMM Audit

  • Object: Assessment of the raydium-amm constant-product market maker with OpenBook integration. The assessment was conducted between 24 October and 11 November 2022, with incremental patch confirmations through to February 2023. The audit was performed against commits d70a8fb through 8da289a.
  • Results: 6 findings in total: 0 critical, 1 high, 1 medium, 0 low, and 4 informational. The high-severity finding concerned liquidity-pool monopolisation through manipulation of the share-to-token ratio. The medium-severity finding concerned stale open-orders account data during swap operations, potentially leading to improper settlement of funds.
  • Actions: Both the high and medium vulnerabilities were resolved prior to report finalisation, with patches confirmed by OtterSec during the incremental review period.

OtterSec, Q3 2022, Raydium Concentrated Liquidity (CLMM) Audit

  • Object: Assessment of the raydium-amm-v3 concentrated-liquidity market maker program. The assessment was conducted between 25 September and 9 December 2022, with final patch confirmation delivered on 30 December 2022. The audit was performed against commit 4fe73c7.
  • Results: 12 findings in total: 0 critical, 1 high, 2 medium, 3 low, and 6 informational. The high-severity finding involved an unchecked type cast in liquidity mathematics. Medium-severity findings included ungated closing of personal positions and arbitrary AMM configuration use in a swap-router instruction. Low-severity findings addressed unsafe account closing, active-account closure, and a reward-state denial-of-service risk.
  • Actions: All listed vulnerabilities were marked resolved, with specific fixes confirmed during the final patch-confirmation review.

MadShield, Q2 2023, Raydium Order-Book AMM and OpenBook Migration Audit

  • Object: Assessment of the updated order-book AMM program and its migration from the original Serum/OpenBook integration. Full scope and commit range are detailed in the published report, available in the Raydium audit repository on GitHub.
  • Results: Full findings are detailed in the published report. Per Raydium's audit documentation, per-finding breakdowns should be read directly from the report.
  • Actions: Resolution status per finding is detailed in the published report.

MadShield, Q1 2024, Raydium Constant Product AMM program (CPMM) Audit

  • Object: Assessment of the CPMM program in the raydium-cp-swap repository, which removes OpenBook integration, adds support for SPL Token-2022 pairs, and is written in the Anchor framework. The audit ran from commit 0d56d2c to 8f10f25. The scope included review of the Token-2022 program's composability with the CPMM, specifically the TransferFeeConfig extension.
  • Results: 4 findings in total: 3 critical and 1 high. Within the CPMM program: two critical findings ;pool-account initialisation failure due to Solana runtime stack limits, and incorrect evaluation of pool vault relationships in swap instructions; and one high-severity finding concerning misplaced rounding in swap division calculations. One further critical finding was identified in the SPL Token-2022 program itself, concerning incorrect inverse-fee calculation for mints using the TransferFeeConfig extension; this vulnerability affects any program interacting with Token-2022 transfer-fee configurations, not only the CPMM. One informational improvement recommendation was raised concerning incorrect swap-event token-amount logging.
  • Actions: All four vulnerabilities were communicated privately to the Raydium developer team and are confirmed resolved. The informational recommendation was acknowledged without a remediation commitment.

Halborn, Q4 2024, Raydium Burn & Earn (Liquidity Locker) Audit

  • Object: Assessment of the Burn & Earn or LP Lock program, which provides liquidity-position locking functionality. Full scope and commit range are detailed in the published report, available in the Raydium audit repository on GitHub.
  • Results: Full findings are detailed in the published report.
  • Actions: Resolution status per finding is detailed in the published report.

Halborn, Q2 2025, Raydium LaunchLab Audit

  • Object: Assessment of the LaunchLab program, which supports permissionless token issuance and liquidity bootstrapping with bonding-curve mechanics. Full scope and commit range are detailed in the published report, available in the Raydium audit repository on GitHub.
  • Results: Full findings are detailed in the published report.
  • Actions: Resolution status per finding is detailed in the published report.

Sec3, Q3 2025, Raydium CPMM Update Audit

  • Object: Re-audit of a significant update to the CPMM program (raydium-cp-swap). The scope was limited to the program diff rather than a full re-audit of the entire program. Full scope and commit range are detailed in the published report.
  • Results: Full findings are detailed in the published report.
  • Actions: Resolution status per finding is detailed in the published report.

Sec3, Q2 2026, Raydium CLMM Update Audit — Limit Order, Dynamic Fee, and Single Asset Fee

  • Object: Re-audit of CLMM program updates covering the Limit Order instruction set, the Dynamic Fee configuration mechanism, and the Single Asset Fee feature. The scope was limited to the program diff for these three additions. Full scope and commit range are detailed in the published report.
  • Results: Full findings are detailed in the published report.
  • Actions: Resolution status per finding is detailed in the published report.

Historical Security Incidents

Two notable security incidents in Raydium's operational history are on record in the published security documentation.

In December 2022, the AMM v4 pool authority private key was compromised, allowing an attacker to drain several pools. The incident arose from a key management failure, not a program code vulnerability. The code had been reviewed by OtterSec and no bug was present in the program logic; the failure was in the operational handling of the authority key. The remediation was a full migration of all authority roles to the Squads multisig structure currently in use.

In January 2023, an OpenBook program update changed account semantics, preventing AMM v4's settlement mechanism from correctly processing pending profit-and-loss calculations until an AMM v4 patch was deployed. The incident was an integration bug ;neither program was incorrect in isolation; and was resolved through a coordinated AMM v4 patch and upgrade.

RAY MiCA White Paper

Part I - Information on risks

N Field Content
I.1 Offer-related risks

Market volatility and liquidity

RAY's market price can fluctuate materially, and trading depth varies across centralised and decentralised venues. Reduced trading volume, uneven token distribution or broader market stress can widen spreads, increase slippage and impair execution quality.

Exchange access and compliance constraints

Access to RAY trading can be affected by listing decisions, delisting, geo-restrictions, AML/KYC checks and local legal requirements. Verification delays, account restrictions or platform policy changes can restrict deposits, withdrawals or trading activity without prior notice.

Market manipulation and price discovery

RAY is exposed to manipulative trading practices that can distort market prices and impair fair price discovery. Wash trading, spoofing or coordinated trading activity can increase volatility and mislead holders regarding available liquidity.

No statutory compensation

RAY is not covered by investor compensation schemes under Directive 97/9/EC or deposit guarantee schemes under Directive 2014/49/EU. Holders cannot rely on statutory recovery arrangements if the token loses value, becomes illiquid or is lost through custody failure.

Delisting Risks

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

I.2 Issuer-related risks

Financial resilience and continuity

Raydium Foundation supports the Raydium Protocol, which provides decentralised exchange, AMM, liquidity pool and LaunchLab functionality. Public information on the Foundation's financial condition for the past 3 years is not available, limiting external assessment of long-term operational resilience.

Governance and administrative authority concentration

The Raydium Foundation, as issuer, is responsible for the governance of the Raydium protocol through two administrative structures. Raydium's program upgrade authority is held under a 3-of-4 Squads multisig with a mandatory 24-hour execution timelock. Operational admin authority ;including the creation of AmmConfig fee tiers and the routing of protocol fee collection; is held under a separate 3-of-5 treasury multisig with no execution timelock, meaning fee parameter and configuration changes can be applied immediately without a user response window. Both multisig structures represent concentrated control: a threshold compromise or coordinated misuse of either could alter program behaviour or fee routing. The treasury multisig's admin authority over protocol parameters is disclosed as an interim arrangement subject to periodic review.

Treasury and buyback control risk

Fee collection, treasury and RAY buyback holding addresses are controlled by the Raydium Foundation through the protocol multisig. Misconfiguration, compromise or operational error affecting those controls could disrupt treasury operations, fee handling or RAY buyback execution. Bought-back RAY is held at a single on-chain address, creating concentration in post-buyback custody.

Brand and ecosystem dependency

The Raydium Foundation's reputation is closely linked to the performance and security of the Raydium protocol. Foundation-level failures, including security incidents, loss of key personnel, governance failures, or adverse regulatory outcomes affecting the Foundation directly, can impair community confidence in the protocol and reduce the utility and market value of RAY.

Regulatory and jurisdictional exposure

Raydium Foundation, incorporated in the Cayman Islands and operating a globally accessible protocol, is exposed to regulatory developments across multiple jurisdictions. Changes to legal frameworks governing decentralised finance protocols, token issuance, or the classification of RAY may require the Foundation to modify or cease operations in certain markets, alter the protocol's functionality, or comply with requirements that affect its capacity to support the Raydium ecosystem.

I.3 Crypto-assets-related risks

Supply allocation and holder concentration

RAY has a fixed maximum supply of 555,000,000 tokens, distributed across mining reserve, partnership and ecosystem, team, liquidity, community pool and adviser allocations, with team, community and adviser tranches subject to lock-up periods. Concentrated holdings among early allocatees, the foundation or the mining reserve can affect perceived scarcity, secondary-market sell pressure and governance influence.

Emissions and liquidity mining

Ongoing RAY emissions from the 34% mining reserve (188,700,000 RAY) distribute liquidity mining rewards to incentivise pool participation. Emission flows increase circulating supply over time and may create sell pressure if reward recipients liquidate positions. The 12% of protocol trading fees directed to programmatic RAY buybacks provides a partial offset, but the net supply impact varies with protocol trading volume and participation levels.

Key custody, bearer risk and transfer error

RAY is a non-custodial bearer asset: control of a wallet's private key constitutes control of the associated RAY balance. Loss or compromise of private keys or recovery credentials provides no protocol-level mechanism for fund recovery. Transfer errors ;including incorrect recipient addresses, wrong network selection or misdirected on-chain operations; result in permanent, irrecoverable loss. RAY token accounts on Solana require correct SPL token program compatibility, and using a wrong-chain or incompatible address will render tokens unrecoverable.

Future use-case uncertainty

RAY's present utility includes governance participation and ecosystem alignment. Future uses depend on community decisions, developer commitment and continued ecosystem success. Expected utility may not materialise if product adoption or development activity weakens.

I.4 Project implementation-related risks

Technical delivery and implementation risk

New Raydium product features, liquidity strategies and integrations may be delayed by technical hurdles, resource constraints or unanticipated security flaws. Delays or defects can affect protocol functionality and the utility of RAY.

Quality assurance and residual audit risk

Raydium smart contracts have undergone multiple audits across AMM, CLMM, staking, CPMM, Burn & Earn, LaunchLab, and program update engagements. These audits identified critical, high, medium, low and informational findings. Resolved findings reduce known-defect risk but do not eliminate residual implementation risk in deployed or future program versions.

Third-party reliance

Raydium's ecosystem relies on liquidity providers, custodians, aggregators and infrastructure partners including RPC operators and off-chain indexers. Operational disruption or policy changes among those parties can reduce token effectiveness or degrade platform performance without Raydium's direct control.

Product interdependency

Raydium includes multiple product surfaces ;AMM v4, CPMM, CLMM, Farm and Staking, LaunchLab and Perps. Farm v3 and v5 remain deployed in wind-down for existing positions but no longer accept new farms; Farm v6 is the current program. Failures, deprecated states or changes in one product can affect user activity, liquidity routing or the perceived utility of RAY across the ecosystem.

Speculative value and ecosystem dependency

RAY has no intrinsic value independent of its use within the Raydium ecosystem. Its market value is speculative and may be influenced by user participation, broader market sentiment, macroeconomic conditions and network activity. Holders may experience significant mark-to-market losses unrelated to protocol performance. Demand for RAY is further linked to the continued use of Raydium products, governance participation, and the buyback and staking reward flows generated by protocol activity; a sustained reduction in protocol usage reduces those flows directly.

Integration and API dependency

Raydium integrators rely on public APIs, SDKs, program addresses, IDLs and route-building tools. API synchronisation lag ;including newly created pools taking several minutes to appear in the API; incorrect program IDs, outdated integrations or transaction-building errors can impair swaps, pool discovery and application reliability. Raydium explicitly notes that a mismatched program ID is the single easiest way to lose funds on Solana.

I.5 Technology-related risks

Solana Layer 1 dependency

RAY is an SPL token on Solana and inherits the network's consensus, transaction, fee and account-model characteristics and risks. Network congestion, transaction expiry from exceeded blockhash lifetime, fee changes, validator disruption or protocol-level upgrades ;including the planned Alpenglow consensus replacement and Validator Admission Ticket fee; can delay execution, increase costs or affect settlement visibility. Any Solana-level incident affects all RAY transactions regardless of Raydium's own program state.

Smart-contract and program logic defects

Raydium smart contracts implement AMM, liquidity pool, LP-token, staking and LaunchLab functionality. Implementation defects; including those identified in past audits — can cause incorrect execution, disrupted liquidity operations, mispriced swaps or fund loss. CPMM, CLMM and associated programs are also subject to composability risks when interacting with other Solana programs.

Upgradeable programs and admin-key exposure

All Raydium programs remain fully upgradeable under the Solana BPF Loader v3 upgrade mechanism; no program's upgrade authority has been set to null. program upgrades are gated by the 3-of-4 upgrade multisig and subject to a 24-hour execution timelock, providing a response window before any upgrade takes effect. However, 24 hours may be insufficient for holders or integrators to assess, react to or unwind positions in response to complex program changes. Operational admin paths ;including AmmConfig creation and protocol fee routing; are governed by the 3-of-5 treasury multisig, which carries no timelock and can take effect immediately. A compromised or misused admin key could introduce regressions, alter program behaviour or redirect fee flows before users can react.

Token-2022 extension and mint-support risk

CPMM and CLMM use a strict allow-list for Token-2022 mint extensions and reject unsupported configurations at pool creation. Supported transfer-fee mints transfer less than the nominal amount per instruction due to the fee deduction; naive UI implementations may understate effective costs or received amounts. Epoch-based fee updates on Token-2022 mints can alter swap economics between a quote and its settlement. Pools created with Token-2022 mints are supported only on Farm v6; older farm programs reject Token-2022 staking mints.

AMM and CLMM liquidity mechanics

Constant-product pools, concentrated-liquidity ranges and LaunchLab bonding curves carry distinct execution and liquidity risks. CLMM positions stop accruing fees when the market price moves outside the deposited range; impermanent loss is amplified relative to wide-range positions as a result. CLMM positions are represented as non-fungible tokens: loss of the position NFT prevents retrieval of associated liquidity. LaunchLab tokens trade along a bonding curve prior to graduation, which means pre-graduation liquidity is limited and graduation mechanics create discrete price-transition risk.

Execution and slippage

RAY swaps and routed trades depend on prevailing pool depth, route selection, transaction settings and slippage tolerance. Market movement beyond the selected tolerance can cause failed transactions, while thin liquidity can produce material price impact. Solana transactions that fail due to slippage, expired blockhash or insufficient compute still incur the base network fee.

RPC, API and explorer visibility risk

Raydium users and integrators rely on RPC endpoints, block explorers, REST APIs and indexers to view on-chain state and build transactions. Public RPC endpoints are shared infrastructure subject to rate limits; exceeding limits returns HTTP 429 errors and can block transaction submission. API synchronisation delays can cause stale pool visibility or outdated configuration reads. Explorer parsing issues can display incorrect balances or transaction statuses.

Perps infrastructure dependency

Raydium Perps uses Orderly Network infrastructure for perpetual futures functionality, including account management, order routing, market data, and deposit, withdrawal and settlement rails. Disruptions, parameter changes or dependency failures in the Orderly infrastructure can affect Raydium Perps trading, collateral handling and withdrawals, even where the underlying RAY SPL token remains transferable on Solana. Raydium Perps collateral parameters are subject to change by Orderly independently of Raydium's own program controls.

Quantum computing and cryptographic forward risk

Solana's transaction authentication relies on Ed25519 elliptic-curve signatures, and Proof of History is built on sequential SHA-256 hashing. The security of Ed25519 rests on the hardness of the elliptic-curve discrete logarithm problem, which is solvable in polynomial time by Shor's algorithm running on a sufficiently large, fault-tolerant quantum computer. Every RAY holder account or program account that has ever signed a transaction has its public key publicly visible on-chain and would be at risk if such a quantum capability were achieved, as private keys could in principle be derived from exposed public keys. SHA-256 is subject to Grover's algorithm, which reduces the effective brute-force security margin from 256 bits to approximately 128 bits; this remains computationally infeasible with current or near-term quantum hardware but degrades the classical security assumption. Solana has not published a post-quantum cryptographic migration roadmap; any transition to post-quantum signature standards would require a coordinated upgrade across the Solana validator set, carrying its own implementation and compatibility risks.

I.6 Mitigation measures

Offer-related risks

  • Market volatility and liquidity: Trading-fee shares distributed to liquidity providers across CLMM, CPMM and AMM v4 pools create an economic incentive for liquidity provision. RAY token rewards distributed through Farm v6 incentivise pool participation in selected pairs. These mechanisms support continuous liquidity but do not guarantee price stability, minimum depth or protection against adverse market conditions.

Issuer-Related Risks

  • Governance and administrative authority concentration: program upgrade authority is held under a 3-of-4 Squads multisig with a 24-hour mandatory execution timelock. This provides users and integrators a minimum window to observe, assess and; where possible; unwind positions before any program upgrade takes effect. The Squads transaction queue is publicly monitorable in real time, and air-gapped cold-device signing with sequential approval reduces the risk of single-point compromise. Treasury multisig operations carry no timelock and require independent monitoring to detect misuse; Raydium's treasury multisig address and pending operations are publicly visible on the Squads Protocol interface.
  • Treasury and buyback control risk: Protocol fee collection, treasury and buyback holding addresses are published and publicly verifiable on-chain. The buyback holding address (DdHDoz94o2WJmD9myRobHCwtx1bESpHTd4SSPe6VEZaz), pool-specific fee collection addresses and the treasury multisig address are disclosed, allowing independent monitoring of flows and balances without relying on Raydium's own reporting.
  • Regulatory and jurisdictional exposure: RAY holder restrictions require compliance with applicable securities laws, sanctions and jurisdictional restrictions. Exchange-level KYC and AML checks create access controls at trading venues. These requirements operate at the disclosure and platform level and do not remove the risk of future changes to the regulatory treatment of RAY.

Crypto-Assets-Related Risks

  • Supply allocation and holder concentration: RAY's maximum supply is fixed at 555,000,000 tokens and cannot be increased, as no mint authority is present on the RAY mint account. The full allocation breakdown — mining reserve, partnership and ecosystem, team, liquidity, community pool and advisers — together with applicable lock-up categories, is publicly disclosed.
  • Emissions and liquidity mining: 12% of all Raydium protocol trading fees are directed to programmatic RAY buybacks, creating a demand-side flow that partially offsets mining-reserve emissions. Bought-back RAY is retained by the protocol at a published on-chain address and is not burned or redistributed, providing an auditable record of the buyback program's scale relative to emissions.
  • Key custody, bearer risk and transfer error: Raydium publishes canonical program addresses and instructs users not to sign transactions where a program ID does not match the published table, reducing spoofing and wrong-program transaction risk. Correct recipient address and network verification before signing are user-level controls; no protocol mechanism exists to recover transferred tokens sent to an incorrect address or an incompatible network.

Project Implementation-Related Risks

  • Quality assurance and residual audit risk: Raydium maintains a published audit record across ten engagements covering AMM, CLMM, staking, CPMM, Burn & Earn, LaunchLab and program update scopes, with identified critical, high, medium and low findings resolved across those reviews. An active bug-bounty program on Immunefi provides a continuous post-deployment vulnerability disclosure channel, with critical smart-contract reports eligible for rewards up to USD 505,000.
  • Integration and API dependency: Raydium publishes official SDK repositories, program IDLs, canonical program addresses and on-chain verification guidance. Integrators can validate program IDs against on-chain upgrade authority, fetch live IDLs to compare against published interfaces, and use the live API configuration endpoint for current AmmConfig data rather than cached or hardcoded values.

Technology-Related Risks

  • Smart-contract and program logic defects: The Immunefi bug-bounty program provides an active external vulnerability disclosure channel with proof-of-concept requirements and defined response timelines. Critical smart-contract vulnerabilities are eligible for rewards up to USD 505,000, aligning external researcher incentives with protocol security.
  • Upgradeable programs and admin-key exposure: The program upgrade multisig operates with a 24-hour timelock, giving users and integrators a minimum response window before any deployed upgrade takes effect. All pending upgrade transactions are visible on the public Squads Protocol interface. Users who disagree with a proposed upgrade have the timelock window to assess positions and unwind if necessary. Operational admin paths not gated by the upgrade multisig, including AmmConfig creation and fee-parameter updates under the treasury multisig, do not carry a timelock and are not subject to this mitigation.
  • Token-2022 extension and mint-support risk: CPMM and CLMM apply strict allow-list gating at pool creation, reverting unsupported Token-2022 extensions before any pool state is written. Transfer-checked instruction flows are used for supported transfer-fee mints, allowing the program to account for fee deductions in swap calculations. These controls limit unexpected extension-related failures to pool creation time rather than allowing them to affect active pools.
  • Execution and slippage: Raydium's Trade API includes slippage tolerance expressed in basis points, route-plan selection, price-impact fields and minimum output thresholds when building swap transactions. These parameters allow integrators and users to set execution guardrails, though they do not prevent market impact from large orders or failed transactions in fast-moving markets.
  • RPC, API and explorer visibility risk: Raydium's official SDK, published program addresses, on-chain IDLs and the live configuration API provide primary sources for program state that do not depend on a single third-party RPC provider. Integrators are directed to refresh AmmConfig data at runtime and to verify program IDs on-chain rather than relying on explorer displays. These approaches reduce but do not eliminate exposure to RPC rate limits, availability issues or synchronisation delays.
RAY MiCA White Paper

Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts

N Field Content
Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism
General information about adverse impacts
S.1 Name

Bitstamp Europe S.A.

S.2 Relevant legal entity identifier

549300XIBGTJ0PLIEO72

S.3 Name of the crypto-asset

RAY

S.4 Consensus Mechanism

RAY does not run a standalone consensus mechanism. As a Solana SPL token, its issuance record, transfers, and token-account balances are ordered, validated, and finalised by Solana's consensus process. Raydium's on-chain programs add application logic but do not alter or substitute for Solana's underlying consensus.

Solana's consensus architecture combines Proof of History with a Proof-of-Stake validator voting process. Proof of History is a sequential cryptographic hash computation that produces a verifiable record of the ordering and passage of time between events. A designated leader sequences user messages, executes transactions against current state, and publishes the resulting state signature to verifier nodes. Verifier nodes execute the same transactions on their own state copies and publish signed confirmations, which serve as votes in the consensus process.

Solana's consensus protocol is Tower BFT, a variant of Practical Byzantine Fault Tolerance that uses Proof of History as a cryptographic clock. Validators vote on the PoH sequence using an exponential lockout mechanism: each vote commits the validator to the voted fork for a doubling lockout period, making it progressively harder to roll back earlier votes and producing increasing practical finality as confirmations accumulate.

Consensus validity requires a supermajority involving 2-of-3 of validators weighted by their staked bonds. A branch is accepted once a supermajority of bonded validators votes within the prescribed timeout. The leader for each slot is determined by a stake-weighted leader schedule computed at the start of each epoch. If the scheduled leader for a slot fails to produce a block, that slot is skipped and the network moves to the next scheduled leader; no election occurs at the time of failure.

Slashing, the penalty destruction of a portion of a validator's stake for double-voting or voting on an invalid hash, is a stated roadmap objective, but the Solana network currently has no in-protocol slashing implementation. The first planned step is the introduction of slashing proofs without any automatic penalty enforcement. . No slashing penalties are presently enforced on the Solana mainnet.

An updated consensus protocol, Alpenglow, is under development and targeted for Agave 4.1. Alpenglow would replace Proof of History and on-chain vote transactions with a new mechanism designed to deliver approximately 150-millisecond confirmation times, and would introduce a Validator Admission Ticket fee of 1.6 SOL per epoch for validators included in the consensus set. Until Alpenglow is active on mainnet, Solana's current Proof of History and Proof-of-Stake mechanism governs RAY transactions.

S.5 Incentive Mechanisms and Applicable Fees

See H.5

S.6 Beginning of the period to which the disclosed information relates

2026-01-01

S.7 End of period to which disclosed information relates

2026-05-19

Mandatory key indicator
S.8 Energy consumption 305.05433
Sources and methodologies
S.9 Energy consumption sources and methodologies

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 : www.micacryptoalliance.com/methodologies

Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of the consensus mechanism
Supplementary key indicators
S.10 Renewable energy consumption 0.4163075368
S.11 Energy intensity 0.00001
S.12 Scope 1 DLT GHG emissions – Controlled 0
S.13 Scope 2 DLT GHG emissions – Purchased 0.08828
S.14 GHG intensity 0.0000038567
Sources and methodologies
S.15 Key energy sources and methodologies

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: www.micacryptoalliance.com/methodologies

S.16 Key GHG sources and methodologies

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: www.micacryptoalliance.com/methodologies

Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism
Optional indicators
S.17 Energy mix
Energy Source Percentage
Bioenergy 3.8884692535%
Coal 13.3569606976%
Flared Methane 0%
Gas 30.3409544225%
Hydro 8.3159291901%
Nuclear 11.9445486103%
Other Fossil 2.7267825854%
Other Renewables 0.5355831998%
Solar 10.3425861261%
Vented Methane 0%
Wind 18.5481859148%
S.18 Energy use reduction N/A
S.19 Carbon intensity 0.28940
S.20 Scope 3 DLT GHG emissions – Value chain N/A
S.21 GHG emissions reduction targets or commitments N/A
S.22 Generation of waste electrical and electronic equipment (WEEE) 0.00034
S.23 Non-recycled WEEE ratio 0.5902633473
S.24 Generation of hazardous waste 0.0000001708
S.25 Generation of waste (all types) 0.00034
S.26 Non-recycled waste ratio (all types) 0.5902633473
S.27 Waste intensity (all types) 0.00001
S.28 Waste reduction targets or commitments (all types) N/A
S.29 Impact of the use of equipment on natural resources

Land use: 8.57375 m²

S.30 Natural resources use reduction targets or commitments N/A
S.31 Water use 1.41938
S.32 Non recycled water ratio 0.7289028316
Sources and and methodologies
S.33 Other energy sources and methodologies

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: www.micacryptoalliance.com/methodologies

S.34 Other GHG sources and methodologies

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: www.micacryptoalliance.com/methodologies

S.35 Waste sources and methodologies

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: www.micacryptoalliance.com/methodologies

S.36 Natural resources sources and methodologies

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: www.micacryptoalliance.com/methodologies