Legal Compliance (MiCA — The Netherlands)

Regulatory posture (today)

Yawnie Doo is a fungible, non-stable, non-asset-referenced, non-e-money crypto-asset (i.e., not an ART or EMT). It therefore sits in MiCA’s “other crypto-assets” bucket. ESMA

No staking, yield, or rights are offered at present. The token does not confer claims on the issuer or any profit rights that could push it toward financial-instrument treatment under MiFID II. (ESMA has issued guidance on where utility tokens could drift into financial-instrument territory; we remain outside that scope.) Skadden

Issuer obligations (offers/marketing)

Public offerings or admissions to trading of “other crypto-assets” generally require a MiCA-compliant crypto-asset white paper (CAWP) and related disclosures, unless an exemption applies (e.g., offers to <150 persons per Member State, or total consideration ≤ €1,000,000 in 12 months, or tokens given for free). We will evaluate and apply the correct route (exempt vs. notified CAWP) based on the actual scope of distribution. White & Case, Finance, InnReg, brightnode.io

Marketing communications must be fair, clear and not misleading, and consistent with the (notified or exempt) white paper position. We align our external channels (site, X, docs) with AFM guidance. AFM +1

Service-provider licensing (CASP)

We do not currently operate as a Crypto-Asset Service Provider (CASP) (e.g., no custody, trading platform, exchange, execution, or portfolio services). Therefore, no CASP license is triggered at this stage. From 1 July 2025, any entity offering CASP services in NL requires MiCA authorization with the AFM (with DNB involvement for certain tokens); this is noted for future planning but not applicable to Yawnie Doo today. Global Regulation Tomorrow

Transparency controls

We maintain on-chain transparency and clear public disclosures. These are additive to MiCA’s fairness/clarity standards for marketing and do not substitute for any required CAWP or notifications if/when applicable. AFM

Planned Update for Staking (effective Q3 2026)

When staking functionality is introduced, the legal position can change depending on design:

• MiCA & staking per ESMA: MiCA has no article dedicated to “staking” itself, but staking-as-a-service typically falls under custody/administration of crypto-assets on behalf of clients if a provider holds users’ keys or intermediates participation—meaning CASP authorization will be required. ESMA’s materials/Q&A and practitioner analyses align on this treatment. ESMA, Lawyers Week, Osborne Clarke
• Custodial vs. non-custodial:
  • If staking is custodial/intermediated (we or a partner hold user assets/keys), we will seek MiCA CASP authorization with the AFM for the relevant service(s) before launch and implement client-asset protections (e.g., prohibition on using client assets for our own account). Global Regulation Tomorrow, Osborne Clarke
  • If staking is purely non-custodial (users delegate directly from self-custody and we do not hold keys), CASP custody may not be triggered; however, we will still assess any other MiCA touchpoints (marketing, disclosures, platform features) and update the legal section and user terms accordingly. www.hoganlovells.com

What we’ll publish before launch (Q3 2026)

• Updated white paper/technical annex describing staking mechanics, risks, and rights (no profit rights unless explicitly designed and analyzed under MiFID tests). Skadden
• If applicable, CASP authorization details (license scope, client-asset safeguards) and updated risk factors & marketing disclosures aligned with AFM/ESMA expectations. AFM, ESMA

TL;DR for investors (now vs. later)

• Now: Utility/meme token, no staking, no CASP services — comply with MiCA offer/marketing rules (use exemptions or notify CAWP as required), maintain AFM-standard communications. White & Case, AFM
• Q3 2026 staking: If custodial/intermediated, CASP license needed before go-live; if non-custodial, reassess but likely lighter MiCA impact. Either way, we’ll publish an updated legal section and disclosures before activation. Global Regulation Tomorrow, ESMA, Lawyers Week