White Paper Report


			..
	White paper for crypto-assets other than asset-referenced tokens or e-money tokens

	Digital Token Identifier:	978RVFGVX
	Offeror or person seeking admission to trading:	Swiss Commercial Register Registration Number: CHE-199.927.372 - Provable GmbH (the "Person Seeking Admission to Trading")
	Type of submission:	New

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




[Table 2] Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens

Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens [abstract]
General information
00 Table of content	boolean true	true
01 Date of notification	date	2026-02-06
02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114	boolean true	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	boolean true	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	boolean true	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	boolean true	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.
06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114	boolean true	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.
SUMMARY
07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114	boolean true	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 offer 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	textBlock	Overview. The ALEO Token (the "Token") is the native token of the Aleo layer 1 blockchain (the "Network"), issued based on its fungible ARC-20 standard, and which also lives, in a bridged version, on the BNB Chain, notably for the purpose of its admission to trading. Functionalities. The Token grants access to the following functionalities as further described under Section F.2: Transaction Fee Functionality: The Token serves to pay for the fees required to transact on the Network; Prover Staking Functionality: The Tokens can be staked to join the Network as a prover, and thereby participate in the Proof of Succinct Work mechanism ("PoSW") by submitting computations and generating zero-knowledge proofs ("ZKPs"), specifically of the SNARK type, in exchange for rewards ("Prover Rewards"); Validator Staking Functionality: Tokens can be staked to join the network as a validator, thereby contributing to its consensus mechanism - the Aleo Byzantine Fault Tolerant (BFT) protocol - by verifying solutions submitted by provers and assembling transactions into blocks together with the verified ZKPs, in exchange for rewards ("Validator Rewards"). Delegated Staking Functionality: Token holders may delegate their Tokens to a validator, rather than directly operating as a validator themselves, while still receiving their proportional share of Validator Rewards generated by the validator to whom they have delegated. Governance Functionality: Token holders can access the governance mechanism of the Network, effectively voting on its future development in the context of Aleo Requests for Comment ("ARC"), relating to upgrades, modifications to fee structures, or changes in staking parameters. The Governance Functionality may give rise to the adoption of Network upgrades that modify or extend the functionalities associated with the Token. Any such upgrades are outside the control and responsibility of the Person Seeking Admission to Trading. Supply. The Token had an initial supply of 1.5 billion units at Network main net launch ("Initial Supply"), which at the date of this White Paper increased to about 1.85 billion units as a result of the ongoing emissions to validators and provers, as further described under Section G.13. A community governance vote closed on 2026-01-06 (ARC-0047) fixed the total supply at five (5) billion Tokens. Qualification. The Token qualifies as a crypto-asset other than e-money token and asset-reference token, and specifically a utility token, under Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets ("MiCAR").
09 Further information about utility tokens	textBlock	All goods and services are provided by the Network in accordance with the Network protocol. Accordingly: The quality of each Token functionality depends on the state of both the Network itself and its ecosystem, namely applications deployed thereon and involved actors (including validators and provers). It will be further shaped by governance votes and ensuing changes made to the Network. The scale of each Token functionality depends on the circulating supply of Tokens available for use with such functionality. Considering the foregoing, the quality and quantity of the functionalities are unquantifiable as they will constantly evolve as the Network and ecosystem develop. The Tokens to be admitted to trading (see E.12) are freely transferable.
10 Key information about the offer to the public or admission to trading	textBlock	Provable GmbH acts as the Person Seeking Admission to Trading and seeks admission of the Token on multiple Trading Platforms, operating within the European Union ("EU") and the European Economic Area ("EEA") ("Trading Platforms"). The Token has been trading on the following Trading Platforms prior to this White Paper: Coinbase, Gate and Hashkey since 2024-09-18. Additional listings on Trading Platforms are sought. The most current list of available Trading Platforms will be at all times available on the website of the parent of the Person Seeking Admission to Trading (see Sections A.11 and F.8). In seeking admission to trading, the Person Seeking Admission to Trading complies with its obligations under article 5 of Regulation (EU) 2023/1114.
Part A - Information about offeror or person seeking admission to trading
A.1 Name	text	Provable GmbH (the "Person Seeking Admission to Trading")
A.2 Legal form	text	3EKS (GmbH -Gesellschaft mit beschränkter Haftung)
A.3 Registered address
Registered addess	text	c/o Sielva Management SA, Gubelstrasse 11, 6300 Zug, Switzerland
Country	enumeration	Switzerland
Sub-division	text	Not applicable.
A.4 Head office
Head office	text	Not applicable.
Country	enumeration
Sub-division	text
A.5 Registration date	date	2024-03-15
A.6 Legal entity identifier	LEI
A.7 Another identifier required pursuant to applicable national law	text	Swiss Commercial Register Registration Number: CHE-199.927.372
A.8 Contact telephone number	text	001.530.693.6194
A.9 E-mail address	text	legal@provable.com
A.10 Response time (days)	integer	14
A.11 Parent company	text	Provable Inc., a Delaware corporation incorporated under U.S. law, with registered office at 5470 Kietzke Lane, Suite 300, Reno, Nevada 89511, USA.
A.12 Members of the management body
Member #1	id	1
Identity	text	Howard Hu
Business address	text	c/o Sielva Management SA, Gubelstrasse 11, 6300 Zug, Switzerland
Function	text	President of the Board Director (Board Member) Oversees strategic direction and overall management
Member #2	id	2
Identity	text	Collin Daniel Chin
Business address	text	c/o Sielva Management SA, Gubelstrasse 11, 6300 Zug, Switzerland
Function	text	Director (Board Member) Oversees operational and financial management
Member #3	id	3
Identity	text	Silvan Andermatt
Business address	text	c/o Sielva Management SA, Gubelstrasse 11, 6300 Zug, Switzerland
Function	text	Director (Board Member) Oversees Swiss operations and financial management
A.13 Business activity	textBlock	The Person Seeking Admission to Trading provides services in the field of information technology, notably to its parent company, supporting it with the development, marketing, distribution, and licensing of software products, platforms, and related digital applications, with a focus on privacy-preserving blockchain infrastructure and zero-knowledge proof technology.
A.14 Parent company business activity	textBlock	The parent of the Person Seeking Admission to Trading provides services in the field of information technology, with a focus on privacy-preserving blockchain infrastructure and zero-knowledge proof technology.
A.15 Newly established	boolean	true
A.16 Financial condition for the past three years	textBlock	Not applicable.
A.17 Financial condition since registration	textBlock	Source of Financial Resources. The Person Seeking Admission to Trading has been primarily funded through capital contributions and intercompany support from its parent company, which provided the initial fully paid-in share capital of USD 27,000, as a contribution in kind at incorporation. The parent company continues to provide ongoing intercompany funding, as the Person Seeking Admission to Trading has not yet begun generating commercial revenue. The Person Seeking Admission to Trading is at the date of the present White Paper still in its early operational phase, and its expenditures are primarily tied to operating costs, notably in relation to the Network. Its balance sheet consists primarily of digital assets (USDC), with no significant external debt obligations. The company's financial position has remained stable since registration, with sufficient liquidity provided by the parent company to cover all operational and capital requirements. No material adverse changes have occurred in its financial condition since incorporation. Sufficiency of Financial Resources. Given the above, the Person Seeking Admission to Trading possesses sufficient financial resources to support the continued development and operation of the project, and, at present, it does not face any material financial risks or uncertainties that would affect its financial viability.
Part B - Information about issuer, if different from offeror or person seeking admission to trading
B.1 Issuer different from offerror or person seeking admission to trading	boolean	true
B.2 Name	text	No single identifiable issuer. The Tokens were issued automatically by the Network at genesis block, and are similarly automatically issued by the Network through New Emissions (see Section G.13) . The Network is not governed by any identifiable undertaking separate from the code. The Person Seeking Admission to Trading does not run validators or provers on the Network.
B.3 Legal form	text	Not applicable, see answer provided under Section B.2
B.4 Registered address
Registered addess	text	Not applicable, see answer provided under Section B.2
Country	enumeration
Sub-division	text
B.5 Head office
Head office	text	Not applicable, see answer provided under Section B.2
Country	enumeration
Sub-division	text
B.6 Registration date	date
B.7 Legal entity identifier	LEI
B.8 Another identifier required pursuant to applicable national law	text
B.9 Parent company	text
B.10 Members of the management body
Member #1	id	1
Identity	text	Not applicable, see answer provided under Section B.2
Business address	text
Function	text
B.11 Business activity	textBlock
B.12 Parent company business activity	textBlock
Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
C.1 Name	N/A		.
C.2 Legal form	N/A		.
C.3 Registered address
Registered address	N/A		.
Country	N/A		.
Sub-division	N/A		.
C.4 Head office
Head office	N/A		.
Country	N/A		.
Sub-division	N/A		.
C.5 Registration date	N/A		.
C.6 Legal entity identifier	N/A		.
C.7 Another identifier required pursuant to applicable national law	N/A		.
C.8 Parent company	N/A		.
C.9 Reason for crypto-asset white paper preparation	N/A		.
C.10 Members of the management body
Member #1	N/A		.
Identity	N/A		.
Business address	N/A		.
Function	N/A		.
C.11 Operator business activity	N/A		.
C.12 Parent company business activity	N/A		.
C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114	N/A		.
C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114	N/A		.
Part D - Information about other token project
D.1 Crypto-asset project name	text	Aleo
D.2 Crypto-asset name	text	Aleo Token
D.3 Abbreviation	text	$ALEO
D.4 Crypto-asset project description	textBlock	The Token is the native token of the Network, a layer-1 blockchain protocol designed to enable private and programmable applications using zero-knowledge cryptography. The Network's architecture is designed to provide scalability and data privacy at the base layer, particularly for payment processing and other common business transactions, thereby facilitating broader blockchain adoption, while maintaining decentralization through an open set of validators and provers participating in network operations. See further explanations relating to the Network under Sections H.1 and H.4
D.5 Details of all natural or legal persons involved in implementation of crypto-asset project
Person #1	id	1
Type of person	enumeration	Development team
Name of person	text	Provable Inc.
Business address of person	text	5470 Kietzke Ln, Suite 300, Reno, NV 89511, USA
Domicile of company	enumeration	United States of America
Person #2	id	2
Type of person	enumeration	Crypto-asset service provider
Name of person	text	Aleo Network Foundation
Business address of person	text	1603 Capitol Avenue, Suite 413-D168, Cheyenne, WY 82001, USA
Domicile of company	enumeration	United States of America
Person #3	id	3
Type of person	enumeration	Crypto-asset service provider
Name of person	text	Trail of Bits
Business address of person	text	228 Park Ave S, PMB 85512, New York, NY 10003, USA
Domicile of company	enumeration	United States of America
Person #4	id	4
Type of person	enumeration	Crypto-asset service provider
Name of person	text	NCC Group
Business address of person	text	390 Union Blvd, Suite 520, Lakewood, CO 80228, USA
Domicile of company	enumeration	United States of America
D.6 Utility token classification	boolean	true
D.7 Key features of goods or services for utility token projects	text	All goods and services are provided by the Network in accordance with the Network protocol. An up-to-date list of goods and services provided by the Network and available to Token holders is available through the Network documentation as published under www.aleo.org. No specific goods or services are guaranteed to be available for redemption, even more so considering the possibility of Network upgrades affecting Token functionality and decided in a decentralized manner (see Governance Functionality description under Section F.2).
D.8 Plans for the token
Description of past milestones	textBlock	The timeline below is an estimate, and may be subject to change depending, notably, on third-party integrations and cooperations. 2019: Aleo Systems Inc. was founded by Howard Wu, Collin Chin, and Ray Chu. 2020: Testnet 1 of the Network launched, implementing the concepts outlined in the Zexe research paper. 2021: Testnet 2 of the Network was released to test the technical architecture of the network. 2022: Testnet 3 of the Network launched, enabling developers to deploy zero-knowledge (ZK) programs and allowing users to interact with them on Aleo. 2023: The Aleo Network Foundation was established to support the growth of the Network. September 2024: Mainnet of the Network went live, allowing developers to build directly on the Network. 2025: The Network has processed over 20 million transactions, seen the deployment of more than 500 programs, and partnered with Circle and Paxos Labs to bring stablecoins on-chain.
Description of future milestones	textBlock	2026: Listing of the Token on additional prominent exchanges, notably within the EU/EEA.
D.9 Resource allocation	text	Presently, the Person Seeking Admission to Trading allocates available resources, as indicated under Section A.17, to further Network support, including expanding the network of future partners.
D.10 Planned use of collected funds or other tokens	text	Not applicable because the Person Seeking Admission to Trading is seeking admission to trading and does not collect any funds in that context.
Part E - Information about offer to public of other tokens or their admission to trading
E.1 Public offering or admission to trading	enumeration	Admission to trading
E.2 Reasons for public offer or admission to trading	textBlock	The admission of the Token to trading aims to promote broad circulation and distribution to potential Network users, enabling them to fully engage with and benefit from the Network. By further decentralizing ownership and control of the Network, the Person Seeing Admission to Trading seeks to enhance the economic security of the Network, to increase censorship resistance and neutrality.
E.3 Fundraising target
Target expressed in currency	monetary		EUR
Target expressed in units	decimal
Target expressed in digital token identifier	text
E.4 Minimum subscription goals
Goals expressed in currency	monetary		EUR
Goals expressed in units	decimal
Goals expressed in digital token identifier	text
E.5 Maximum subscription goals
Goasl expressed in currency	monetary		EUR
Goals expressed in units	decimal
Goals expressed in digital token identifier	text
E.6 Oversubscription acceptance	boolean
E.7 Oversubscription allocation	text
Issue price details
E.8 Issue price	decimal
E.9 Official currency determining issue price	enumeration
E.9 Any other tokens determining issue price	text
E.10 Subscription fee
Fee expressed in currency	monetary		EUR
Fee expressed in units	decimal
Fee expressed in digital token identifier	text
E.11 Offer price determination method	text
E.12 Total number of offered or traded other tokens	integer
E.13 Targeted holders	enumeration	All types of investors
E.14 Holder restrictions	text	The Network is by design permissionless and decentralized. There are thus no restrictions at chain-level. The Trading Platforms in accordance with applicable laws and internal policies may impose restrictions to buyers and sellers of Tokens. Any check performed to implement such restrictions, notably KYC checks, are not conducted by the Person Seeking Admission to Trading.
E.15 Reimbursement notice	boolean true
E.16 Refund mechanism	textBlock
E.17 Refund timeline	text
E.18 Offer phases	textBlock
E.19 Early purchase discount	textBlock
E.20 Time-limited offer	boolean
E.21 Subscription period beginning	date
E.22 Subscription period end	date
E.23 Safeguarding arrangements for offered funds or other tokens	textBlock
E.24 Payment methods for other token purchase	textBlock
E.25 Value transfer methods for reimbursement	textBlock
E.26 Right of withdrawal	textBlock
E.27 Transfer of purchased other tokens	textBlock	The Tokens acquired as a result of trades shall be transferred to the compatible wallet or technical device as designated by the selected Trading Platform. The Person Seeking Admission to Trading bears no responsibility for any transfers of the Token between market participants on the Trading Platforms.
E.28 Transfer time schedule	text	The transfer of the Tokens acquired as a result of trades conducted on the Trading Platforms may or may not occur immediately, depending on the functioning of the selected Trading Platform. The Person Seeking Admission to Trading has no control over the timing of such transfers.
E.29 Purchaser's technical requirements	textBlock	Token holders must comply with the technical requirements specific to the Trading Platforms on which the Token is admitted to trading, which may include the following: a device (computer or mobile) to manage digital wallet/private key and/or account on exchange to carry out transactions; a compatible digital wallet or account on the Trading Platform; and internet access.
Other token services provider characteristics
E.30 Other token service provider (CASP) name	text	Not applicable
E.31 CASP identifier	LEI
E.32 Placement form	enumeration	Not applicable
Trading platforms characteristics
E.33 Trading platforms name	text	Admission to trading is being sought on additional Trading Platforms. As of the date of the present White Paper, no new listing agreement has been concluded; therefore, no specific Trading Platform can be identified at this stage. The Token has been trading on the following Trading Platforms prior to this White Paper: Coinbase, Gate and Hashkey since 2024-09-18. Additional listings on Trading Platforms are sought. The most current list of available Trading Platforms will be at all times available on the website of the parent of the Person Seeking Admission to Trading (see Sections A.11 and F.8).
E.34 Trading platforms market identifier code (MIC)	text	Not available.
E.35 Trading platforms access	text	Trading Platforms are accessible via their respective desktop and/or mobile based interfaces.
E.36 Involved costs	textBlock	The use of services offered by Trading Platforms may involve costs, including transaction fees, withdrawal fees, and other charges, as notified to users in advance. These costs are determined and set by the respective Trading Platforms and are not controlled, influenced, or governed by the Person Seeking Admission to Trading. Consequently, any changes to initially announced fee structures or the introduction of new costs for the future are solely at the discretion of the Trading Platforms.
E.37 Offer expenses	textBlock	Not applicable.
E.38 Conflicts of interest	textBlock	The Person Seeking Admission to Trading is not aware of any potential conflict of interest among its management body members or any other person within the Person Seeking Admission to Trading with respect to the admission to trading of the Token.
E.39 Applicable law	textBlock	Any dispute arising out of or in connection with the present White Paper, the Person Seeking Admission to Trading and the admission to trading shall be governed exclusively by the laws of Switzerland, without regard to conflict of law rules or principles, except to the extent that such disputes are governed by applicable law pursuant to the terms and conditions of the Trading Platform.
E.40 Competent court	textBlock	Any dispute arising out of or in connection with the present White Paper, the Person Seeking Admission to Trading and the admission to trading shall be exclusively resolved by the ordinary courts of Zug, Switzerland.
Part F - Information about other tokens
F.1 Crypto-asset type	text	Utility token
F.2 Other token functionality	textBlock	The Token grants access to the following functionalities: Transaction Fee Functionality: The Token serves to pay for the fees required to transact on the Network; Prover Staking Functionality: The Tokens can be staked to join the Network as a prover, and thereby participate in the Proof of Succinct Work mechanism ("PoSW") by submitting computations and generating zero-knowledge proofs ("ZKPs"), specifically of the SNARK type, in exchange for rewards ("Prover Rewards"); Validator Staking Functionality: Tokens can be staked to join the network as a validator, thereby contributing to its consensus mechanism - the Aleo Byzantine Fault Tolerant (BFT) protocol - by verifying solutions submitted by provers and assembling transactions into blocks together with the verified ZKPs, in exchange for rewards ("Validator Rewards"). Delegated Staking Functionality: Token holders may delegate their Tokens to a validator, rather than directly operating as a validator themselves, while still receiving their proportional share of Validator Rewards generated by the validator to whom they have delegated. Governance Functionality: Token holders can access the governance mechanism of the Network, effectively voting on its future development in the context of Aleo Requests for Comment ("ARC"), relating to upgrades, modifications to fee structures, or changes in staking parameters. The Governance Functionality may give rise to the adoption of Network upgrades that modify or extend the functionalities associated with the Token. Any such upgrades are outside the control and responsibility of the Person Seeking Admission to Trading.
F.3 Planned application of functionalities	textBlock	The functionalities described under Section F.2 are available since Network main net launch in 2024 and are thus all available for immediate use at the date of this White Paper.
A description of the characteristics of the other token, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article
F.4 Type of crypto-asset white paper	enumeration	Other crypto-asset token white paper
F.5 Type of submission	enumeration	New
F.6 Other token characteristics	textBlock	Native token of the Network issued based on its fungible ARC-20 standard. It is a standalone utility token while the Network supports other tokens issued based on the ARC-20 standard. The Token also lives, in a bridged version, on the BNB Chain, notably for the purpose of its admission to trading. Token issued to serve as the main token in relation to the Network (see Section F.2) Token does not carry any legally enforceable rights or entitlements against the issuer (see Section G.1). Initial Supply of the Token: 1.5 billion units at Network main net launch; since then, increasing progressively through automated Network Emissions to validators and provers, up to a total of 5 billion units (see Section G.13); at the date of this White Paper, about 1.85 billion units exist.
F.7 Commercial name or trading name	text	Aleo
F.8 Website of the issuer	text	Official website of the parent of the Person Seeking Admission to Trading: www.provable.com Official Network Landing Page hosting technical documentation, network explorer, and governance disclosures: www.aleo.org This White Paper will be accessible on both websites.
F.9 Starting date of offer to the public or admission to trading	date
F.10 Publication date	date	2026-03-07
F.11 Any other services provided by the issuer	textBlock	Not applicable.
F.12 Language or languages of white paper	text	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	text	978RVFGVX
F.14 Functionally fungible group digital token identifier, where available	text	FW6DMFBNZ
F.15 Voluntary data flag	boolean	false
F.16 Personal data flag	boolean	true
F.17 LEI eligibility	boolean	false
F.18 Home member state	enumeration	Ireland
F.19 Host member states #1	enumerationSet	Austria
F.19 Host member states #2	enumerationSet	Belgium
F.19 Host member states #3	enumerationSet	Bulgaria
F.19 Host member states #4	enumerationSet	Croatia
F.19 Host member states #5	enumerationSet	Cyprus
F.19 Host member states #6	enumerationSet	Czechia
F.19 Host member states #7	enumerationSet	Denmark
F.19 Host member states #8	enumerationSet	Estonia
F.19 Host member states #9	enumerationSet	Finland
F.19 Host member states #10	enumerationSet	France
F.19 Host member states #11	enumerationSet	Germany
F.19 Host member states #12	enumerationSet	Greece
F.19 Host member states #13	enumerationSet	Hungary
F.19 Host member states #14	enumerationSet	Iceland
F.19 Host member states #15	enumerationSet	Italy
F.19 Host member states #16	enumerationSet	Latvia
F.19 Host member states #17	enumerationSet	Liechtenstein
F.19 Host member states #18	enumerationSet	Lithuania
F.19 Host member states #19	enumerationSet	Luxembourg
F.19 Host member states #20	enumerationSet	Malta
F.19 Host member states #21	enumerationSet	Netherlands
F.19 Host member states #22	enumerationSet	Norway
F.19 Host member states #23	enumerationSet	Poland
F.19 Host member states #24	enumerationSet	Portugal
F.19 Host member states #25	enumerationSet	Romania
F.19 Host member states #26	enumerationSet	Slovakia
F.19 Host member states #27	enumerationSet	Slovenia
F.19 Host member states #28	enumerationSet	Spain
F.19 Host member states #29	enumerationSet	Sweden
Part G - Information on rights and obligations attached to other tokens
G.1 Purchaser rights and obligations	textBlock	The Tokens do not carry any legally enforceable rights or entitlements against the issuer Instead, Tokens enable their holders to interact with the Network and specific goods and services provided thereby. The Person Seeking Admission to Trading, to the fullest extent permitted by applicable laws, disclaims all warranties, whether express or implied, in relation to the Token and its functionalities, as well as the Network. This includes, but is not limited to, implied warranties of merchantability and fitness for a particular purpose.
G.2 Exercise of rights and obligations	textBlock	Not applicable, see answer under G.1.
G.3 Conditions for modifications of rights and obligations	textBlock	Not applicable, see answer under G.1.
G.4 Future public offers	textBlock	The Person Seeking Admission to Trading does not plan to proceed with any public offering of the Token as of the date of publication of this White Paper.
G.5 Issuer retained other token	integer
G.6 Utility token classification	boolean	true
G.7 Key features of goods or services utility tokens	text	All goods and services are provided by the Network in accordance with the Network protocol. An up-to-date list of goods and services provided by the Network and available to Token holders is available through the Network documentation as published under www.aleo.org. No specific goods or services are guaranteed to be available for redemption, even more so considering the possibility of Network upgrades affecting Token functionality and decided in a decentralized manner (see Governance Functionality description under F.2).
G.8 Utility tokens redemption	text	Goods and services accessible through the Token's functionalities may be redeemed exclusively via the Network. There is no claim against the Person Seeking Admission to Trading or any identified undertaking.
G.9 Non-trading request	boolean	true
G.10 Other tokens purchase or sale modalities	text	Not applicable, see answer under G.1.
G.11 Other tokens transfer restrictions	text	See field E.14 above.
G.12 Supply adjustment protocols	boolean	true
G.13 Supply adjustment mechanisms	text	The initial total supply of Tokens amounted to 1.5 billion units, which increased to about 1.85 billion through new emissions of the Token ("New Emissions") by the date of this White Paper, out of which 611.5 million units are estimated to be circulating and thereby available for trading upon listing date. Up to date data can be at all times retrieved through the Aleo explorer. The total supply is presently fixed at a maximum of 5 billion units, following a community governance vote closed on 2026-01-06 (ARC-0047). The Network follows a deterministic schedule for New Emissions. New units are thus minted in an automated manner based on a hardcoded logic. New Emissions are part of the Network's consensus mechanism, Proof of Succinct Work (PoSW): Tokens are minted as rewards to validators and provers. The Governance Functionality cannot amend the above without adopting a Network hard-fork.
Other token schemes details
G.14 Token value protection schemes	boolean	false
G.15 Token value protection schemes description	textBlock	Not applicable.
G.16 Compensation schemes	boolean	false
G.17 Compensation schemes description	textBlock	Not applicable.
G.18 Applicable law	textBlock	Any dispute arising out of or in connection with the White Paper, Person Seeking and the Admission to Trading and the admission to trading shall be governed exclusively by the laws of Switzerland, without regard to conflict of law rules or principles, except to the extent that such disputes are governed by applicable law pursuant to the terms and conditions of the Trading Platform.
G.19 Competent court	textBlock	Any dispute arising out of or in connection with the present White Paper, the Person Seeking Admission to Trading and the admission to trading shall be exclusively resolved by the ordinary courts of Zug, Switzerland.
Part H – Information on underlying technology
H.1 Distributed ledger technology (DTL)	text	General Information on Distributed Ledger Technology and Blockchain Distributed Ledger Technology ("DLT") describes a decentralized and distributed Network system architecture where multiple participants maintain and verify a shared database. Unlike traditional databases, DLT systems do not rely on a central authority to ensure data consistency and security. Rather, they distribute control across a Network of computers (nodes) and require all changes to be recorded and agreed by the nodes. This distributed approach enhances the resilience and security of such a system, and transparency of the data stored in it without the need for trust between the actors of the systems. Blockchain technology is a subset of DLT, where the distributed database maintains a continuously growing list of records, called blocks, which are linked together in chronological order and secured using cryptographic techniques. A blockchain generally has the following key characteristics: Security: A blockchain employs advanced cryptographic methods to secure data. Each block contains a cryptographic hash (a "digital fingerprint") of the previous block, a timestamp, and transaction data. Consensus: Blockchains rely on a predefined consensus mechanism establishing how new blocks, and the transactions included therein, are approved by nodes. Immutability: once data is recorded in a block, it can be neither deleted nor altered retroactively without also changing all subsequent blocks, which would require consensus from most of the nodes. Transparency: Transactions on a blockchain are usually visible to all, thereby providing transparency. Private blockchains, such as the Network, with or without limited transparency also exist. Accessibility: Blockchains are usually permissionless, thus accessible to all, whether to act as a node or to submit transactions to be recorded thereon. Permissioned blockchains, with limited accessibility for nodes and/or users, however, do also exist. General Information about the Network The Network operates as a form of DLT, distributing data management and validation across a global set of independent participants ("validators" and "provers") without reliance on a central authority. The Network distinguishes itself through the use of zero-knowledge cryptography to enable private and programmable applications, providing scalability and data privacy at the base layer. These characteristics make it suitable for applications involving payments, compliance, and other privacy-sensitive business processes. The following points summarize the key technical characteristics of the Network: Programming Framework: The Network is developed primarily in Rust, while Leo, a domain-specific language, is used for the creation and deployment of smart contracts. Zero-Knowledge Proof System: The Network employs zkSNARKs (Zero-Knowledge Succinct Non-Interactive Arguments of Knowledge) as its zero-knowledge proof framework, enabling participants to verify computations without revealing underlying data. Execution and Verification Architecture: The Network architecture separates execution from verification and consensus: ▪ execution occurs off-chain and privately to perform computations and generate ZKPs. ▪ verification and consensus occur on-chain and publicly through validators, who verify the proofs and record the resulting state commitments on the ledger. Data Confidentiality and Integrity: Each transaction or state change is represented by a cryptographic commitment, a hidden value that can be verified through zero-knowledge proofs. This design allows users to store and transfer data privately while enabling the Network to confirm correctness and maintain integrity. Governance and Openness: The Network protocol is fully open source and operates without any central operator. Anyone can participate in the Network as a validator through the staking functionality, provided they meet the necessary hardware requirements to operate a node. Validator nodes are subject to a minimum staking requirement to engage in consensus and block production. The staking process itself does not require continuous operation of software and can be completed via standard on-chain transactions. Interoperability: The Network is not EVM-compatible, meaning it is not natively designed to interact with Ethereum, although technical interoperability solutions may allow for such interactions. Consensus Mechanism: The Network combines: ▪ a Proof-of-Succinct-Work (PoSW) mechanism, under which provers generate solutions to attest to valid computations; and ▪ a Byzantine Fault Tolerant (BFT) protocol operated by validators, who verify proofs and assemble transactions into blocks. See Section H.4 for further details on the consensus mechanism.
H.2 Protocols and technical standards	text	The Token relies on the following protocols: Network Protocol: The Token lives on the Network and its existence, New Emissions as well as usage through transactions are thus governed by Network rules. Aleo Token Registry Program containing the Token Standards for issuance of tokens on the Network.
H.3 Technology used	textBlock	The Network, as well as on technology provided by third party providers active in the Network ecosystem, and providing, amongst other, wallets, bridges, oracles and alike. Partner integrations with the Network as these rely on APIs. The custody solution chosen by the Token holder (non-custodial or custodial, hot or cold wallet).
H.4 Consensus mechanism	text	Aleo combines Proof of Succinct Work (PoSW) with Byzantine Fault Tolerant (BFT) consensus. Below is a detailed explanation of each component and how they work together. Proof of Succinct Work (PoSW) is a mechanism developed for the Network that replaces traditional energy-intensive mining with the generation of zero-knowledge proofs (ZKPs) or KZG commitments to demonstrate computational work. Rather than solving arbitrary hash puzzles, participants known as provers perform useful cryptographic computations and generate succinct non-interactive arguments of knowledge (SNARKs) or KZG commitments that attest to the validity of those computations. Each prover competes to produce a valid solution that satisfies the network's current puzzle parameters. This proof serves as verifiable evidence of computational effort and correctness. Because these solutions are succinct, other nodes can quickly verify them without re-executing the underlying computation, significantly improving efficiency compared to conventional proof-of-work systems. The PoSW mechanism therefore transforms the consensus process into a market for verifiable computation, securing the network while producing cryptographic solutions that can be reused for practical applications, such as private smart contracts. Provers who successfully generate valid solutions are rewarded in Tokens. Byzantine Fault Tolerant (BFT) Consensus, also referred to as AleoBFT, is used to order and finalize transactions once valid proofs have been submitted. Under this protocol, a group of validators — nodes that have staked Tokens — are responsible for verifying the proofs generated by provers, assembling transactions into blocks, and achieving agreement on the canonical chain. Validators collaborate using BFT consensus to ensure that the network remains secure and operational even if a subset of nodes behaves dishonestly or goes offline. This protocol enables fast finality and resilience, as blocks can be confirmed without waiting for multiple confirmations or probabilistic settlement. Validators receive Validator Rewards in Tokens for their participation in securing the network. Both provers and validators are rewarded for their respective contributions: provers for submitting valid computations and validators for verifying and finalizing blocks, both according to a hardcoded, automated distribution logic embedded in the Network protocol, through transaction fees and New Emissions. Interaction Between PoSW and BFT: This dual-layer design separates computation (PoSW) from consensus (BFT), provers focus on generating proofs, and validators ensure transaction ordering and block production. Together, they provide a scalable and privacy-preserving foundation for decentralized applications and payments. The combination of PoSW and BFT allows the Network to achieve high throughput, privacy, and energy efficiency without sacrificing decentralisation.
H.5 Incentive mechanisms and applicable fees	text	Please refer further to the information provided in section H.1 above.
H.6 Use of distributed ledger technology	boolean	false
H.7 DLT functionality description	textBlock	Not applicable.
Other token audit details
H.8 Audit	boolean	true
H.9 Audit outcome	textBlock	The Aleo protocol and its cryptographic components have undergone multiple independent security audits, including reviews of the zkSNARK implementation, Leo programming language, and core protocol libraries. Audits have been conducted by reputable security firms such as Trail of Bits and ZKSecurity, with results publicly available via Aleo's GitHub and documentation portal, notably under the following link https://aleo.org/post/aleo-completes-security-audits-of-snarkos-and-snarkvm/. No critical vulnerabilities remain outstanding. While audits strengthen security, they do not guarantee the absence of all vulnerabilities. Undetected issues or new exploits could still arise, and investors should consider these risks. See also Part I (Information about the risks).
Part I - Information on risks
I.1 Offer-related risks	textBlock	For the Admission to Trading No Listing Risk: The present white paper is drafted and notified by the Person Seeking Admission to Trading in accordance with its obligations under Article 5 of MiCAR, in its capacity as a person seeking the admission of the Token to trading. As of the date of notification, the Person Seeking Admission to Trading has not entered into any listing agreement with any Trading Platforms. The Person Seeking Admission to Trading its affiliates, directors, and officers shall not be held liable for any damages, losses, costs, fines, penalties, or expenses of any kind - whether or not reasonably foreseeable by the Person Seeking Admission to Trading or the Token holder - that the Token holder may suffer, sustain, or incur in connection with, or as a result of, the Token not being listed on a Trading Platform. General Contractual and Counterparty Risk: The Person Seeking Admission to Trading neither operates nor controls, oversees, or manages the functioning of crypto-asset services providers as defined under MiCAR ("CASP") operating within the EU /EEA and Trading Platforms where the Token will be admitted for trading or listed. When Token holders buy or sell the Token on Trading Platforms, the Person Seeking Admission to Trading is not a contractual party to these transactions. As a result, i. any legal relationship between Token holders and the Exchange is governed solely by the terms and conditions set by each Exchange at its discretion. ii. the Person Seeking Admission to Trading assumes no responsibility or liability for the operations, services, security, performance, or any outcomes—whether financial or technical—arising from transactions conducted on these Trading Platforms. iii. the Person Seeking Admission to Trading provides no assurances regarding any Exchange itself and assumes no responsibility or liability for any regulatory, compliance, operational, financial, technical, or reputational failures that may adversely affect its activities. This includes, but is not limited to, circumstances where such failures result in disruptions, restrictions on trading, or the Exchange halting or ceasing its operations entirely, due to sanctions, bankruptcy or alike. The foregoing may result in substantial or even total losses for the Token holder. Pausing and Delisting Risk: The Person Seeking Admission to Trading cannot guarantee that the Token will remain listed or tradeable on any Trading Platforms. Delisting (or the temporary pausing of such listing) could significantly hinder the ability of Token holders to buy, sell, or otherwise transact in Tokens. In the event of delisting, Token holders may face challenges in finding alternative markets or counterparties willing to trade Tokens, which could adversely impact the Token's liquidity and market value. Delisting could also negatively impact the price of the Token, due to modified demand for the Token and/or reputational impact. Trading Risk: The Person Seeking Admission to Trading does not control the secondary markets. There can be no assurance as to the secondary market (if any) in the Tokens, and specifically: i. it cannot guarantee the depth, stability, or sustainability of any secondary market for Tokens. Limited market depth or trading activity may result in reduced liquidity, increased price volatility, and challenges in buying or selling Tokens at desired prices; and ii. it cannot guarantee the healthy and consistent availability of buying or selling opportunities for Tokens or the integrity of their market price. Trading activity may be affected by manipulative practices such as wash trading, front-running, and similar schemes. While Trading Platforms are subject to varying regulatory frameworks that may or may not prohibit such practices and impose oversight to detect and deter them, the Person Seeking Admission to Trading assumes no responsibility or liability for their effective prevention or enforcement. Unsolicited Admission to Trading Risk: Third parties can elect to support Tokens on their Trading Platforms without any request nor authorization or approval by the Person Seeking Admission to Trading or anyone else. Token integration on any third-party Network does not imply any endorsement by the Person Seeking Admission to Trading that such third-party services are valid, legal, stable or otherwise appropriate. Operational and Technical Risk: Trading Platforms operate interfaces that allow users to trade crypto-assets for fiat currencies, such as U.S. Dollars and Euros, or other crypto-assets. The reliance on the Exchange's internal system for asset storage and transfer adds an additional layer of counterparty risk, as users are exposed to potential operational, technical, or human errors during these processes. As a result, the Person Seeking Admission to Trading assumes no responsibility or liability for any losses arising from these risks. i. Trades on these Trading Platforms are executed based on a centralized matching algorithm and are often recorded off-chain, meaning they are not directly related to transparent on-chain transfers of crypto-assets, and could dissimulate detrimental trade matching or rogue practices. The traded assets are recorded solely on the Exchange's internal ledger, with each internal ledger entry corresponding to an offsetting trade involving either government currency or another crypto asset. ii. Additionally, funds deposited by users for trading may be co-mingled by the Trading Platforms, rather than stored in unique wallet addresses for each user. This practice results in the centralization of a large volume of assets in a single location, which in turn increases the potential risk of damage or theft, particularly in the event of a hack or security breach. iii. Furthermore, users who wish to trade or withdraw their Tokens must deposit them into the Exchange, increasing the risk of loss in the event of a failure of the deposit or withdrawal processes set up by the Exchange. Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.1 to I.5.
I.2 Issuer-related risks	textBlock	Not applicable. See answer provided under Section B.2.
I.3 Other tokens-related risks	textBlock	Token Admission to Trading "As Is" Risk: The Tokens are admitted to trading on an "as is" and "as available" basis without warranties of any kind, and the Person Seeking Admission to Trading and its affiliates expressly disclaim all implied warranties that the Token, the software code of the programs, are free of viruses or other harmful components which may affect the Tokens. Market Risk: Crypto assets, including Tokens, are highly volatile and can experience significant price swings in short periods, increasing the risk of sudden and substantial losses. Such valuation risk arises as the market value of a crypto asset may not always reflect its underlying utility or fundamentals and is subject to subjective assessment. Token holders are thus exposed to potential for losses due to the Token's i. potential fluctuations in value, driven by various factors such as supply and demand dynamics, investor sentiment, and broader market trends, including changes in interest rates, general movements in local and international markets, technological advancements, regulatory changes, and media coverage. Notably, momentum pricing of crypto assets has previously resulted, and may continue to result, in speculation regarding future appreciation or depreciation in the value of such assets, further contributing to volatility and potentially inflating or deflating prices at any given time. ii. liquidity risk, where a lack of depth in secondary markets – if any – or limited trading volumes can hinder the ability to execute trades at favorable prices, which could lead to significant losses, especially in fast-moving market conditions. As a result, holders of Tokens may experience challenges in managing their holdings, with the value of the asset subject to unpredictable fluctuations and potential depreciation. iii. solvency and collateral risk, if the Token is used to finance further activities, especially in leveraged positions or as collateral for loans. Significant fluctuations in the value of the Token could adversely affect the solvency of its holder, particularly if the Token is pledged as collateral. A drastic decline in its value may trigger margin calls or automatic liquidations, which could further depress the Token's price, creating a negative feedback loop. This volatility poses the risk of forced asset sales, potentially resulting in substantial losses for the holder and amplifying downward pressure on the market price of Tokens. Custodial Risk. The method chosen to store Tokens, like any crypto-asset, carries inherent risks related to the security and management of the storage solution. The chosen storage method—whether hot or cold wallets, or centralized custody—can significantly impact the safety, liquidity, and accessibility of Tokens, with direct consequences for the holder's ability to access, trade, or retain their assets. Custodial Risk. The method chosen to store Tokens, like any crypto-asset, carries inherent risks related to the security and management of the storage solution. The chosen storage method—whether hot or cold wallets, or centralized custody—can significantly impact the safety, liquidity, and accessibility of Tokens, with direct consequences for the holder's ability to access, trade, or retain their assets. Scam Risk. This is the risk of loss resulting from a scam or fraud suffered by Token holders from other malicious actors. These scams include, but are not limited to, phishing or "pig butchering" on social networks or by email, fake giveaways, identity theft, creation of fake Tokens, offering fake Token airdrops, among others. Anti-Money Laundering/Counter-Terrorism Financing Risk: This is the risk that crypto-asset wallets holding Token or transactions in Token may be used for money laundering or terrorist financing purposes or identified to a person known to have committed such offenses. There is thus a risk that a public address holding Tokens could be flagged in relation to Anti-Money Laundering or Counter-Terrorism Financing efforts. In such cases, receiving Tokens could result in the holder's address being flagged by relevant authorities, Trading Platforms, or other service providers, which may lead to restrictions on transactions or the freezing of assets. Consequently, holders of Tokens may face legal or regulatory challenges if their address(es) become(s) associated with illicit activities, impacting their ability to freely access, trade, or transfer their Tokens. Taxation Risk: The taxation regime that applies to the trading of Tokens by either individual holders or legal entities will depend on each Token holder's jurisdiction. The Person Seeking Admission to Trading cannot guarantee that the holding of Tokens, the reception of the Token, conversions of fiat currency against Tokens, or conversions of other crypto assets against Tokens, will not incur tax consequences. It is the Token holder's sole responsibility to comply with all applicable tax laws, including, but not limited to, the reporting and payment of income tax, wealth tax or similar taxes arising in connection with the appreciation and depreciation of the Token. Market Abuse Risk: The market for crypto assets is rapidly evolving, spanning local, national, and international networks with an expanding range of assets and participants. Any market abuse, along with a potential loss of confidence among holders, could adversely impact the value and stability of Tokens, and by extension the trading conditions on the Trading Platforms. Notably: i. significant trading activity may take place on systems and networks with limited oversight and predictability. Sudden and rapid changes in the supply or demand of a crypto asset, particularly those with low market capitalization or low unit prices, can result in extreme price volatility. ii. the inherent characteristics of crypto assets and their underlying infrastructure may be exploited by certain market participants to engage in abusive trading practices such as front-running, spoofing, pump-and-dump schemes, and fraud across different networks, systems, or jurisdictions. Legal and Regulatory Risk: There is a lack of regulatory harmonization and cohesion globally, which results in diverging regulatory frameworks and possible further regulatory evolutions in the future. These could negatively impact the value, utility, and overall viability of Tokens and, in extreme cases, force the Person Seeking Admission to Trading to cease operations. Notably:, i. while Tokens do not create or confer any contractual or other obligations against any party, certain non-EU regulators may nevertheless classify them as securities, financial instruments, or payment instruments under their respective legal frameworks. Such classifications could impose specific regulatory constraints, leading to significant changes in how Tokens are structured, issued, purchased, or traded. ii. evolving regulations could substantially increase the Person Seeking Admission to Trading's compliance costs and operational burdens related to facilitating transactions in Tokens. iii. New or restrictive regulations could result in the Token losing functionality, depreciating in value, or even becoming illegal or impossible to use, buy, or sell in certain jurisdictions. iv. Regulators could take enforcement action against the Person Seeking Admission to Trading if they determine that the Token constitutes a regulated instrument or that the Person Seeking Admission to Trading's activities violate existing laws. Such actions could expose the Person Seeking Admission to Trading, its affiliates, directors, and officers to legal and financial penalties, including civil and criminal liability. Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.1 to I.5.
I.4 Project implementation-related risks	textBlock	Network "As Is" Risk: The Network is and any future components were deployed on an "as is" and "as available" basis without warranties of any kind, and the Person Seeking Admission to Trading expressly disclaims all implied warranties as to the Network and the Token including, without limitation, implied warranties of merchantability, fitness for a particular purpose, title and non-infringement. Therefore, the Person Seeking Admission to Trading cannot and does not warrant that the Token, the programs, or the technology underlying the Tokens or the Network (jointly, "Aleo Technology") are reliable, current or error-free, free of viruses or other harmful components, meet the Token's requirements, or that defects in the Aleo Technology will be corrected. Additionally, there is a risk that Network functionalities may be abandoned, that no new functionalities may be added. Decentralized Governance and Network Change Risk: The Network is subject to decentralized, on-chain decision-making (so-called DAO governance). Token holders are invited to participate in proposal discussions and votes concerning matters relating to the Network's development (see Governance Functionality, as described under Sections 08 and F.02). This could result in material changes to the Network's goals, priorities, or operating methods. While such evolution can promote innovation and strengthen adaptability, it also presents certain risks, such as alterations in the value proposition and possible divergence from stakeholders' previous expectations. Novel Ecosystem Risk: The Token holder understands and acknowledges that the Aleo ecosystem, as evolving around the Network, is built on emerging and rapidly evolving technologies, which inherently carry significant risks. The underlying software, blockchain infrastructure, smart contracts, and related technologies are still in their early stages of development, meaning there is no guarantee that the process of receiving, using, or holding Tokens will be uninterrupted or error-free. As with any novel technology stack, there is an inherent risk that the underlying blockchain, smart contracts, or associated components may contain weaknesses, vulnerabilities, or bugs, despite audits being conducted. Such issues could lead to unintended behaviors, security breaches, or critical failures, potentially resulting in the partial or complete loss of Tokens or their functionality. Additionally, unforeseen technical limitations, incompatibilities, or the emergence of superior alternatives could further impact the stability, security, and long-term viability of the Aleo ecosystem. Industry and Competition Risk: The project is and will be subject to all the risks and uncertainties associated with any new venture, visionary projects, including the risk that the project cannot be realized in line with its original purpose or vision about the Network. Other projects may have the same or a similar vision as the projects There are several other crypto-assets and projects, and new competitors may enter the market at any time. The effect of new or additional competition on the Token or its market price cannot be predicted or quantified. Competitors may have significantly greater financial and legal resources than the project and there is no guarantee that the project will be able to compete successfully, or at all, with such competitors. Moreover, increased competition may severely impact the profitability and creditworthiness of the project and involved entities. Dependency/Withdrawing Partners Risk: The Network relies on third-party technologies, infrastructures, and protocols, which could impact its functionality, security, and long-term sustainability. Loss or changes in the key partners providing such technologies can lead to disruptions, loss of trust, or project failure. Any disruptions, vulnerabilities, regulatory scrutiny, or changes in operation of third-party technologies (such as modifications to its mechanisms, governance, or economic incentives) could directly affect the usability and security of the Network, which may result in a negative effect for the Tokens. If any third-party technologies experience technical failures, security breaches, or regulatory intervention, it could severely impact the stability and performance of the Network, potentially limiting its intended functionality and value. This reliance on external infrastructure increases systemic risk, as unforeseen issues in third-party protocols could cascade into disruptions within the Token ecosystem. Withdrawing Partners Risk: This is the risk that the Person Seeking Admission to Trading faces in its business relationships with one or more third parties. The implementation of the Network depends strongly on the collaboration and functioning of services provided by several third parties and other crucial partners. The Person Seeking Admission to Trading cannot guarantee that the Network and the related project will be successfully developed and deployed. Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.1 to I.5
I.5 Technology-related risks	textBlock	The Person Seeking Admission to Trading and its affiliates, directors and officers shall not be responsible or liable for any damages, losses, costs, fines, penalties or expenses of whatever nature, whether reasonably foreseeable by them and the Token holder, and which the Token holder, may suffer, sustain, or incur, arising out of or relating to the technical risks outlined below or a combination thereof. General Cybercrime Risk: The Token holder acknowledges that, despite best efforts to enhance security, the technological components supporting the Token, including its blockchain infrastructure, smart contracts, wallets, may be vulnerable to cyberattacks. Malicious actors may exploit software vulnerabilities, attack consensus mechanisms, or compromise private keys to gain unauthorized access to Tokens. Risks include hacking attempts on the Protocol, smart contract exploits, phishing attacks, malware infections, and other forms of cybercrime that could result in the theft, loss, or unauthorized transfer of Tokens. Since digital assets exist entirely in a technological environment, they are inherently exposed to evolving cyber threats, some of which may be undetectable or irreparable until after significant damage has occurred. Blockchain-Level Risk: The Token holder understands and accepts that, as with other blockchains, the blockchain used for the issuance of the Tokens could be susceptible to consensus-related attacks, including but not limited to double-spend attacks, majority validation power attacks, censorship attacks, and byzantine behavior in the consensus algorithm or be subject to forks. Any successful attack or fork presents a risk to the Token, the expected proper execution and sequencing of Token transactions and the expected proper execution and sequencing of contract computations as well as the Token balances in the wallets of the Token holders. Smart Contract-Level Risk: The issuance and transfers of Tokens rely on smart contracts deployed on a blockchain network, which introduce specific technical and security risks. i. Smart contracts are self-executing, meaning any vulnerabilities, coding errors, or unforeseen logic flaws in the issuance contract could result in unintended consequences, such as the incorrect distribution of Tokens, loss of funds, or permanent locking of Tokens. Additionally, smart contracts are exposed to potential exploits, including hacking attempts, reentrancy attacks, and other forms of malicious activity that could compromise the security of the issuance process. ii. Once deployed, the smart contract governing the issuance of Tokens cannot be easily altered or corrected, meaning any discovered vulnerabilities may be difficult or impossible to fix without significant coordination, community approval, or even a network fork. Furthermore, changes to the underlying blockchain protocol—such as updates to consensus mechanisms, transaction processing rules, or transaction fee structures—could affect the functionality or cost-efficiency of the issuance smart contract. These risks could lead to disruptions in Token issuance, security breaches, or a loss of confidence in the Aleo ecosystem, potentially impacting the Token's value and usability. Network-Level Risk: It cannot be excluded that any technical failure, malfunction, or vulnerability within the Network could directly or indirectly impact the value of the Token. i. The network could be subject to critical exploits, such as reentrancy attacks, logic errors, or oracle manipulation, which could lead to unintended Token transfers, assets being drained from the system, or Tokens being irretrievably lost. Fixing such issues may require significant coordination, governance approval, or even disruptive measures such as protocol migrations or forks, none of which are guaranteed to be successful. ii. Because the Token's value is inherently tied, among other factors, to its governance functionality, any security breach, or governance deadlock affecting the network or its governance system could have cascading effects, including depreciation of the Token's value, reduced market confidence, and potential loss of funds for Token holders. Finality or Irrevocability of Transactions: There is a risk that transactions may be irreversible, depending on the tools and service providers used to initiate them. Access to and any claim on such transactions could be lost indefinitely or permanently. For example, this could occur if (i) a blockchain address is entered incorrectly and the true owner is never identified, (ii) the private key associated with the address is lost, (iii) the address belongs to an entity that will not return the crypto asset, or (iv) the address belongs to an entity that may return the asset but requires additional actions, such as identity verification. Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.1 to I.5.
I.6 Mitigation measures	textBlock	Various measures to mitigate the risks outlined in Sections I.01 to I.05 above have been implemented. These include rigorous technology testing and auditing, and the careful selection of personnel, management, and third-party partners. However, many of these risks are inherent to the activities with crypto assets and the broader ecosystem, making complete elimination impossible. To further reduce exposure to these risks, prospective Token holders should adopt appropriate safeguards based on their chosen custody method and remain vigilant by actively monitoring publicly available news and market signals, enabling them to respond swiftly to significant developments which may result in the materialization of specific risks.
Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
J.1 Adverse impacts on climate and other environment-related adverse impacts	textBlock	The below is information on the principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism used to validate and finalize transactions in the Tokens and to maintain the integrity of the distributed ledger of transactions. The energy consumption for the validation and finality of transactions and the maintenance of the integrity of the distributed ledger of transactions for the period is estimated to be lower than 500'000 kWh. (see S.08).
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	text	Provable GmbH
S.2 Relevant legal entity identifier	text	CHE-199.927.372
S.3 Name of the crypto-asset	text	ALEO
S.4 Consensus mechanism	text	See description provided under Section H.4.
S.5 Incentive mechanisms and applicable fees	text	See description provided under Section H.5.
S.6 Beginning of period to which disclosed information relates	date	2026-01-01
S.7 End of period to which disclosed information relates	date	2026-12-31
Mandatory key indicator
S.8 Energy consumption	energy (kWh)	< 500'000 kWh per year
Sources and methodologies
S.9 Energy consumption sources and methodologies	textBlock	The estimated energy consumption of < 500'000 kWh per year has been calculated using a set of assumptions and thus represent estimates. The estimates did not account for any offsetting of energy consumption or other market-based mechanism as of the date of this estimation. Sources and Methodology: Estimates follow the Crypto Carbon Ratings Institute (CCRI) and Cambridge DLT Sustainability Framework, applying standard parameters for node-level power × count × uptime. Contextual Note: Proof-of-Succinct-Work (PoSW) consensus separates computation-heavy proof generation from lightweight verification, producing a materially lower per-transaction energy footprint than classical Proof-of-Work systems. Ongoing advances in zero-knowledge hardware and algorithms are expected to yield additional efficiency gains. Details: The Network's estimated annual energy consumption is approximately 2.7 GWh per year, derived from modeled validator and miner activity using GPU hardware (RTX 3070 class) operating at roughly 15 W effective load and about 2, 000 active nodes worldwide. Key 1 – Renewable Energy Consumption Approximately 45–60 % of total network energy use originates from renewable sources, based on validator-reported regional energy mixes across Europe, the U.S., and Asia, combined with IEA 2024 grid-intensity data. Sources and Methodology: Weighted averages of regional grid composition and node distribution. Key 2 – Energy Intensity Average energy consumption is estimated at ~0.000000005 kWh per validated transaction, representing an extremely small compute load comparable to a few milliseconds of standard device operation. Formula: E total / Tx ≈ (40 W × 5 ms) / 3.6 × 10⁶ = 0.000000005 kWh per transaction. Sources and Methodology: CCRI energy-per-transaction framework; U.S. EIA average electricity rate (2025); assumed 40 W average compute load. Key 3 – Scope 1 DLT GHG Emissions (Controlled) Estimated ≈ 1 575 t CO₂e per year, representing direct energy-related emissions by decentralized node operators. Sources and Methodology: Energy use × 0.583 kg CO₂e/kWh (IEA 2024 average grid intensity). Key 4 – Scope 2 DLT GHG Emissions (Controlled) Estimated ≈ 650 t CO₂e per year, reflecting indirect grid and upstream electricity emissions. Sources and Methodology: Regionalized emission factors weighted by node geography. Key 5 – GHG Intensity Average 0.4–0.6 kg CO₂e per validated transaction (Scope 1 + 2 combined). Sources and Methodology: GHG Protocol Corporate Standard conversion factors applied to energy intensity metrics.
Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of consensus mechanism
Supplementary key indicators
S.10 Renewable energy consumption	percent
S.11 Energy intensity	energy (kWh)
S.12 Scope 1 DLT GHG emissions - controlled	GHG emissions (tCO2e)
S.13 Scope 2 DLT GHG emissions - purchased	GHG emissions (tCO2e)
S.14 GHG intensity	GHG emissions (tCO2e)
Sources and methodologies
S.15 Key energy sources and methodologies	textBlock
S.16 Key GHG sources and methodologies	textBlock
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	percent
S.18 Energy use reduction
Energy use reduction target (absolute value)	energy (kWh)
Energy use reduction target (percentage)	percent
S.19 Carbon intensity (kgCO2e/kWh)	decimal
S.20 Scope 3 DLT GHG emissions - value chain	GHG emissions (tCO2e)
S.21 GHG emissions reduction targets or commitments	textBlock
S.22 Generation of waste electrical and electronic equipment (WEEE)	mass (tonnes)
S.23 Non-recycled WEEE ratio	percent
S.24 Generation of hazardous waste	mass (tonnes)
S.25 Generation of waste (all types)	mass (tonnes)
S.26 Non-recycled waste ratio (all types)	percent
S.27 Waste intensity (all types)	mass (tonnes)
S.28 Waste reduction targets or commitments (all types)	textBlock
S.29 Impact of use of equipment on natural resources	textBlock
S.30 Natural resources use reduction targets or commitments	textBlock
S.31 Water use	volume (m3)
S.32 Non recycled water ratio	percent
Sources and methodologies
S.33 Other energy sources and methodologies	textBlock
S.34 Other GHG sources and methodologies	textBlock
S.35 Waste sources and methodologies	textBlock
S.36 Natural resources sources and methodologies	textBlock