Ten years of white papers, each still answering.
Kilospring is a publication register. A white paper stays available for as long as the asset is held by the public, and every version it replaces has to stay reachable for ten years — with a warning that it no longer applies and a link to the one that does. That is a register, and a website is not one.
- Article 9
The white paper is published on a publicly accessible website before the offer to the public or the admission to trading, and stays available there for as long as the crypto-assets are held by the public.
- Article 12
A significant new factor, material mistake or material inaccuracy means the paper is modified. The modification is notified at least seven working days before it is published, every version is time-stamped, and the most recent is marked as the applicable one.
- Article 12(9)
Older versions stay publicly available for at least ten years, each carrying a prominent warning that it is no longer valid and a link to the version that is.
- Article 109
ESMA's own register holds white papers and their modified versions, and keeps out-of-date versions in a separate archive, clearly marked as out of date.
We do not read any of this for you, and we take no view on whether you have met it. What we provide is the addresses, the versions and the dates.
What hangs where
One paper per asset, and every version it replaced.
A crypto-asset is a product under a publisher, and an issuer carries several: the same firm offers a euro token and a dollar token, each with its own paper. What is published in the firm's own name hangs above them.
An asset you offer. The white paper you notified — or, for an asset-referenced token, had approved — its modifications, and the earlier versions that stay reachable.
/d/example-token-white-paper-en- Crypto-asset white paperone per language
- Modified white papera publication of its own
- Earlier versionsavailable for ten years
- Marketing communicationspublished with the paper
- Reserve figures for an asset-referenced tokenmonthly series
An asset you service. Somebody else issued it, and obligations of your own still attach to it.
/d/example-listed-asset-environmental-en- Hyperlinks to the issuer's white papergiven to your clients
- Adverse environmental impactson your own website
The firm. Published in your own name, on your own website, because the regulation says so.
/d/example-digital-assets-complaints-en- Complaints handling procedurewith its standard template
- Pricing, costs and fees policiesArticle 66(4)
- The nature and sources of conflicts of interestArticle 72(2)
Where the address ends up
Written down once, and quoted for years.
A modification is a publication, not a replacement. The paper that stops applying keeps its own dated address and carries a link forward to the one that applies now — which means the addresses have to keep working long after anyone is still editing them.
- The notification to your competent authority
The white paper is notified before it is published, and the website you name there is the one the register carries.
- ESMA's register
It holds white papers and their modified versions, and keeps out-of-date versions in a separate archive, clearly marked as such.
- The warning on every older version
Each superseded paper carries a link forward to the one that applies now. That link is an address, and it has to keep working.
- Your marketing communications
They state where the white paper is published, and they are published themselves.
- Your own app, website and support material
The places a link is written once and then left alone.
Format and identifiers
We store the file you notified. We never look inside it.
A white paper is prepared to a template and in a machine-readable format. We neither produce that file nor validate it: it arrives from you, is stored byte for byte, and its hash is recorded on arrival. If the file we hold differs from the one you notified, the hash says so.
What the register holds is the metadata around the file, and it holds more than one identifier per publisher and per product — a firm has an LEI whilst an asset is identified by a digital token identifier. Neither is the address, and neither is reused as one: an identifier that changes hands would otherwise take the address with it.
- LEI
the firm, in the register of its own name
- DTI
the crypto-asset, per ISO 24165
- FFG DTI
the functionally fungible group it belongs to
- Language
one document per language, each with its own address
- Valid from · valid to
the period this version was the one in force
Getting started
One asset, with the papers you have already published.
A good first step is a single crypto-asset: the white paper as it stands, the modifications it has been through, and the firm-level information published alongside it. How the setup runs, what the register records and where our responsibility ends is written out on the front page.