MiCA Whitepaper Inline XBRL

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	2026-06-02
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	Bitcoin.ℏ (BTC.ℏ) is designed as a sustainable and secure digital asset that preserves the foundational principles of Bitcoin namely scarcity, decentralisation, and trust while addressing certain limitations related to efficiency, scalability, and environmental impact. Bitcoin.ℏ is a digital crypto-asset recorded and transferred on a distributed ledger network. The crypto-asset is divisible up to eight decimal places, allowing fractional holdings. BTC.ℏ operates as a settlement asset supporting direct, low-cost digital transactions. The total maximum supply of Bitcoin.ℏ is capped at 21,000,000 units. No further units may be created beyond this maximum supply. At the date of this white paper, 5,398,806 units are reported as circulating. Bitcoin.ℏ is designed to function as a transferable digital crypto-asset. Holders may acquire, hold and transfer the crypto-asset through compatible digital wallet infrastructure in accordance with the technical rules of the underlying network. Holding Bitcoin.ℏ does not confer ownership rights in any legal entity, equity participation, voting rights, dividend rights, profit-sharing rights, redemption rights, or claims against an issuer.
09		Not applicable, as 05 is false
10	Key information about the offer to the public or admission to trading	BITCOIN HT, LLC is now seeking its admission to trading within the EU enabling compliant secondary market liquidity. This admission would allow existing holders to trade BTC.ℏ on a regulated EU venue, including centralised exchanges where it may list in the future, ensuring transparent price discovery and stronger market depth. It also supports broader token distribution, which is essential for decentralised governance and wider stakeholder participation in ecosystem decisions.

N	Field	Content
B.1	Issuer different from offerror or person seeking admission to trading	FALSE
B.2	Name	N/A
B.3	Legal form	N/A
B.4	Registered address	N/A
B.5	Head office	N/A
B.6	Registration date	N/A
B.7	Legal entity identifier	N/A
B.8	Another identifier required pursuant to applicable national law	N/A
B.9	Parent company	N/A
B.10	Members of the management body	N/A
B.11	Business activity	N/A
B.12	Parent company business activity	N/A

N	Field	Content
C.1	Name	N/A
C.2	Legal form	N/A
C.3	Registered address	N/A
C.4	Head office	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	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

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 BTC.ℏ 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	5398806 The number of BTC.ℏ crypto-assets admitted to trading may vary over time depending on market conditions and trading activity. The upper limit of the quantity of BTC.ℏ is determined by its fixed maximum total supply of 21,000,000 crypto-assets. At the date of this white paper, the circulating supply is approximately 5,398,806 BTC.ℏ, with the remaining supply held in treasury, liquidity, locked or other non-circulating accounts in accordance with the project’s stated distribution and allocation framework.
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	N/A
E.28	Transfer time schedule	N/A
E.29	Purchaser's technical requirements	N/A
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	Payward Global Solutions Limited (Kraken)
E.34	Trading platforms Market identifier code (MIC)	PGSL
E.35	Trading platforms access	Admission to trading of the BTC.ℏ crypto-asset is sought on Kraken. Access to trading, once admission is granted, will be provided through Kraken’s trading platform, including its website and mobile applications, in accordance with Kraken’s terms of use and applicable regulatory requirements.
E.36	Involved costs	Exchanges may apply a service fee calculated as a percentage of each transaction, with the exact amount disclosed to the user prior to execution. Deposits and withdrawals involving fiat currency may also be subject to additional commissions imposed by external payment service providers. Kraken applies a fixed 1% trading fee for instant buy, sell, or convert transactions executed via its standard interface, with spreads incorporated into the quoted execution price. Additional payment processing fees may apply depending on the selected funding method (e.g. card payments, bank transfers), and deposit and withdrawal fees vary according to the currency and payment rail used.
E.37	Offer expenses	Not applicable.
E.38	Conflicts of interest	Not applicable
E.39	Applicable law	Ireland
E.40	Competent court	Ireland

N	Field	Content
F.1	Crypto-asset type	Crypto-assets other than asset-referenced tokens or e-money tokens
F.2	Crypto-asset functionality	Bitcoin.ℏ is designed to support a broad range of applications across digital and financial ecosystems, leveraging its low transaction costs, high efficiency, and fast settlement capabilities. BTC.ℏ may be held in compatible digital wallets and transferred between participants in accordance with the operational rules of the underlying network. The crypto-asset may be used for global payments, enabling users to conduct cross-border transactions in a timely and cost-efficient manner. Its low fees and rapid settlement characteristics support international trade and remittance use cases, reducing reliance on intermediaries and associated costs. Bitcoin.ℏ also facilitates microtransactions, allowing the transfer of very small denominations (e.g. 0.00000001 BTC.ℏ) at a fixed and minimal transaction cost. This functionality supports emerging digital business models, including pay-per-use services, granular content monetisation, and real-time payment structures. Within the digital entertainment sector, Bitcoin.ℏ can be integrated into online gaming platforms to enable secure and efficient in-game transactions. Its characteristics allow for near-instant transfers and minimal fees, supporting user interaction and digital asset exchange within gaming environments. In addition, Bitcoin.ℏ may be utilised for charitable donations, providing a transparent and cost-effective mechanism for transferring value. The low transaction costs associated with the network contribute to maximising the proportion of funds received by intended beneficiaries. BTC.ℏ is supported by various software and hardware wallets, enabling secure storage and transaction management.
F.3	Planned application of functionalities	All functionalities indicated in F.2 have already been implemented and are currently available.
F.4	Type of crypto-asset white paper	OTHR
F.5	The type of submission	NEWT
F.6	Crypto-asset characteristics	Bitcoin.ℏ (BTC.ℏ) is designed as a sustainable and secure digital asset that preserves the foundational principles of Bitcoin namely scarcity, decentralisation, and trust while addressing certain limitations related to efficiency, scalability, and environmental impact. Bitcoin.ℏ is a digital crypto-asset recorded and transferred on a distributed ledger network. The crypto-asset is divisible up to eight decimal places, allowing fractional holdings. BTC.ℏ operates as a settlement asset supporting direct, low-cost digital transactions. The total maximum supply of Bitcoin.ℏ is capped at 21,000,000 units. No further units may be created beyond this maximum supply. At the date of this white paper, 5,398,806 units are reported as circulating. Bitcoin.ℏ is designed to function as a transferable digital crypto-asset. Holders may acquire, hold and transfer the crypto-asset through compatible digital wallet infrastructure in accordance with the technical rules of the underlying network. Holding Bitcoin.ℏ does not confer ownership rights in any legal entity, equity participation, voting rights, dividend rights, profit-sharing rights, redemption rights, or claims against an issuer.
F.7	Commercial name or trading name	Bitcoin HT, LLC
F.8	Website of the issuer	https://bitcoin.org.ht/
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	Bitcoin HT, LLC is developing inkjug™, a cryptocurrency-based payment service provider (PSP) and monetisation infrastructure designed to support digital economies through micro-payment functionality. The platform is intended to operate as a fully crypto-native payment rail, optimised for low-value, high-frequency transactions. inkjug™ is positioned as the primary commercial and retail-facing gateway within the Bitcoin.ℏ ecosystem, facilitating the connection between businesses, developers, and end users. Through this infrastructure, the issuer aims to enable practical, real-world applications of BTC.ℏ across a variety of digital use cases. The platform is designed to provide developer-oriented tools that support content monetisation, service-based payments, and programmable transaction flows, while utilising cryptocurrency-based settlement mechanisms. In doing so, inkjug™ seeks to enable new economic models on the internet, including direct peer-to-peer payments, pay-per-use services, and integrated monetisation frameworks for digital platforms.
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	G623SB2VS
F.14	Functionally fungible group digital token identifier, where available	QJJ02KRR0
F.15	Voluntary data flag	FALSE
F.16	Personal data flag	TRUE
F.17	LEI eligibility	TRUE
F.18	Home Member State	Ireland
F.19	Host Member States	Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden

N	Field	Content
G.1	Purchaser rights and obligations	Holding BTC.ℏ does not confer ownership rights in any legal entity, equity interests, voting rights, dividend rights, profit participation rights, redemption rights.
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	15601194
G.6	Utility Token Classification	FALSE
G.7	Key features of goods/services of utility tokens	N/A
G.8	Utility tokens redemption	N/A
G.9	Non-trading request	TRUE
G.10	Crypto-assets purchase or sale modalities	Not applicable
G.11	Crypto-assets transfer restrictions	This admission to trading does not outline any restrictions on the transferability of the crypto-assets.
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.

N	Field	Content
H.1	Distributed ledger technology	BTC.ℏ is a native fungible token issued on the Hedera Hashgraph public distributed ledger via the Hedera Token Service (HTS). It is not a fork, derivative, or synthetic equivalent of the original Bitcoin protocol. BTC.ℏ is an independently created digital asset with a supply of 21,000,000 units. Each unit is divisible to eight decimal places. The smallest unit (0.00000001 BTC.ℏ) represents the minimum transferable denomination. The full supply was minted in a single genesis event on 8 March 2024 and is recorded under HTS identifier 0.0.4873177. The Hedera network employs a directed acyclic graph (DAG) architecture rather than a sequentially-linked blockchain. Transactions are recorded as cryptographically linked events that capture the full inter-node communication history, enabling fair transaction ordering and deterministic finality without mining or proof-of-work computation. Hedera's consensus algorithm is aBFT, the highest available security grade for distributed consensus, preserving correctness under completely asynchronous network conditions in the presence of malicious actors controlling up to one-third of network weight. The network supports over 10,000 token transfers per second with finality in two to five seconds. Transaction fees are fixed and non-congestion-dependent at approximately USD 0.001 per transfer.
H.2	Protocols and technical standards	Ledger and State Model BTC.ℏ is managed directly at the Hedera protocol level. Unlike ERC-20 tokens, it requires no bespoke smart contract for transfer logic. Token state, including total supply, account balances, and lifecycle configuration, is maintained as part of the Hedera ledger's canonical state and processed by consensus nodes with the same throughput and finality guarantees as native HBAR transactions. No Supply Key was assigned to token 0.0.4873177 at creation. Under HTS, the Supply Key is the sole credential authorising minting and burning operations; its absence permanently fixes the total supply at 21,000,000 units. No party, including the issuer, can increase or decrease this figure. As of April 2026, the circulating supply stood at 5,398,806 BTC. The remainder was held across issuer-controlled accounts described in Issuer-Controlled Accounts and Key Management in field H.3. Cryptographic Foundations Hedera employs SHA-384 throughout its protocol, an algorithm from the Commercial National Security Algorithm (CNSA) Suite assessed as post-quantum resilient. All transaction and event hashes within the hashgraph DAG are computed using SHA-384, providing a substantially larger security margin than the SHA-256 used by the original Bitcoin protocol. Account and node authentication use elliptic-curve cryptography, with migration pathways to post-quantum signature schemes contemplated as NIST standards are finalised. Network Architecture The Hedera mainnet comprises two structurally distinct node types. Consensus nodes are permissioned participants operated exclusively by members of the Hedera Governing Council; they receive client transactions, apply network fees, execute the hashgraph consensus protocol, and maintain the canonical ledger state. Mirror nodes are permissionless participants that replicate the full transaction history for query purposes; they do not submit transactions and do not participate in consensus. The definitive list of active consensus nodes, including account identifiers and network endpoints, is recorded in the network address book at file 0.0.102 on the Hedera mainnet, accessible via the mirror node REST API and the Hashscan block explorer. Application Layer BTC.ℏ is positioned primarily as a payments asset. Its principal integration is HashGate, a non-custodial payment gateway that routes consumer payments directly to merchant wallets without holding funds at any point, with settlement within seconds and a 1% gateway fee. HashGate supports over 125 fiat currency conversions and provides a WooCommerce plugin and an API-and-webhooks integration path for e-commerce and custom applications. Further confirmed application-layer integrations include Ledger Live hardware wallet support (1 October 2025), the Tangem hardware wallet and ring (2 June 2025), the DCENT biometric wallet (19 May 2025), a native cross-chain exchange (15 December 2024), and the Skellybets gaming platform. BTC.ℏ is listed on the Biconomy and CoinEx centralised exchanges and on the SaucerSwap decentralised exchange, amongst other venues.
H.3	Technology used	Network Infrastructure BTC.ℏ transactions are settled on the Hedera mainnet. The active consensus node list, including account identifiers and network endpoints is maintained on-ledger at file 0.0.102 and is publicly queryable via the mirror node REST API and the Hashscan block explorer. Issuer operations have no dependency on any specific node and Bitcoin HT, LLC operates no consensus infrastructure. Technology Integrations As a native HTS fungible token, BTC.ℏ is accessible in any HTS-compatible wallet without additional integration effort. Confirmed integrations as of the date of this white paper extend the token's accessibility across hardware custody, fiat access, and DEX liquidity as follows. Hardware custody Three hardware wallet platforms have been formally integrated: a Ledger Live desktop and mobile interface integration (1 October 2025); a Tangem NFC card and ring integration (2 June 2025); and a D'Cent biometric hardware wallet and companion mobile app integration (19 May 2025), covering users across more than 220 countries. Each integration enables air-gapped private key storage and transaction signing without the key leaving the device. Fiat on-ramps Two independent fiat-to-crypto conversion channels are active. AhoraCrypto provides credit and debit card purchases of BTC.ℏ with fiat. C14.money, integrated on 25 July 2024, offers a second credit and debit card on-ramp. Both channels operate as third-party services and are not operated by Bitcoin HT, LLC. DEX liquidity Three active liquidity pools on SaucerSwap provide on-chain depth: an HBAR/BTC.ℏ pool (live since 9 March 2024), a SAUCE/BTC.ℏ pool, and a SUITE/BTC.ℏ pool (live since 2 January 2025). BTC.ℏ is additionally listed on SilkSwap and EtaSwap. All venues operate as independent decentralised protocols on the Hedera network. Issuer-Controlled Accounts and Key Management Five Hedera accounts govern the management and distribution of the BTC.ℏ supply. Key storage and access controls for each are set out below. Treasury Working account 0.0.4872589: Ecosystem distributions, grants, and gifts; individual disbursements capped at 0.1% of current FDV. Cold-storage backup account 0.0.9648817. Liquidity Working account 0.0.4650349: Exchange liquidity provisioning; individual transactions capped at 0.2% of current FDV. Cold-storage backup account 0.0.9639155. Team Account 0.0.4650602: Governed by an on-chain time-lock via DaVinciGraph smart contract 0.0.8215492. No transfer is executable until BTC.ℏ reaches a minimum FDV of USD 250,000,000; post-threshold releases are capped at 0.01% of current FDV per transaction. FDV as of 23 February 2026: approximately USD 8,388,618. Key storage controls Private keys for all accounts are held offline in a purpose-built location protected against fire and theft. A separate printed key backup is stored in a physically independent cold-storage location, also fire and theft protected. Account access is restricted to authorised members; two-factor authentication is in place for all systems interacting with project assets. The team account is subject to the DaVinciGraph on-chain lock, which enforces the FDV threshold independently of any administrative action by the issuer. Security Controls Security for BTC.ℏ is distributed across independent layers. Protocol-level security, including consensus finality guarantees and cryptographic integrity, is governed by the Hedera network; full technical descriptions are provided in H.2 and H.4. No independent audit of the BTC.ℏ token or associated smart contracts has been commissioned; see H.8 and H.9. At the project level, the following operational controls are in force for issuer-held accounts and off-chain assets: continuous monitoring for security threats and periodic vulnerability assessments; role-based access restrictions, staff security training, and audit tooling; mandatory pre-integration security assessments for all third-party vendors; and an incident-response framework providing for user notification via the project website and social media channels in the event of a breach. No security framework provides complete immunity from breach or loss, and this limitation is explicitly acknowledged.
H.4	Consensus Mechanism	BTC.ℏ implements no independent consensus mechanism. As a native HTS token, all transactions, including transfers and account associations, are submitted to and finalised by Hedera consensus nodes using the hashgraph algorithm without modification. There are no BTC.ℏ-specific alterations to the consensus configuration or to the node set. Hashgraph Consensus Mechanics The hashgraph algorithm operates on a directed acyclic graph of events, where each event contains one or more transactions and two cryptographic hash references: one to the creating node's preceding event, and one to the most recent event received from the peer with whom the node last synchronised. This dual-reference structure encodes the complete causal and chronological history of all inter-node communications into a shared, append-only DAG. Nodes propagate transactions through a continuous gossip process in which each node periodically selects a random peer and exchanges its complete event history, a technique termed gossip about gossip. Each synchronisation adds to the shared DAG, from which each node independently computes the consensus ordering using virtual voting: by analysing the DAG topology, specifically which events are visible to a supermajority of nodes, each node determines how every other node would vote without transmitting any vote messages. Every node converges on an identical result independently. This eliminates the round-trip communication overhead of classical Byzantine Fault Tolerant voting rounds and is the mechanism by which Hedera simultaneously achieves high throughput and aBFT security. Finality and Fair Ordering BTC.ℏ transactions reach absolute, deterministic finality within two to five seconds of submission. Finality is not probabilistic: there are no block-depth requirements, no confirmation counts, and no chain-reorganisation risk. Once finalised, a transaction is permanently and irreversibly recorded. Consensus timestamps are assigned as the median of first-receipt times across a supermajority of nodes. No individual node can shift an assigned timestamp beyond the range established by the global median, providing structural resistance to front-running and transaction-ordering manipulation. Node Governance and Decentralisation Each Council member operates one consensus node under a formal council agreement, is subject to term limits, and bears accountability under the council governance framework. The Council governs network parameter changes and protocol upgrades. Neither BTC.ℏ holders nor Bitcoin HT, LLC hold any governance rights within this framework. The permissioned node set reflects Hedera's current governance model, with progressive decentralisation of the node set contemplated in the network's design roadmap.
H.5	Incentive Mechanisms and Applicable Fees	Network-Level Transaction Fees BTC.ℏ transactions on the Hedera mainnet incur standard network fees denominated in HBAR, calibrated by the Governing Council to maintain a stable USD-equivalent cost of approximately USD 0.001 per token transfer. Fees are fixed and non-congestion-dependent and do not increase under high network utilisation, contrasting directly with Ethereum's gas-market mechanism. Token-Level Fee Configuration HTS supports configurable token-level fees, including fixed charges, fractional fees, and royalty structures, each enforceable at the protocol level through a Fee Schedule Key role. Whether any custom fee schedule has been configured on token 0.0.4873177, or whether a Fee Schedule Key exists, has not been disclosed and represents an open disclosure gap. Node Operator Incentives Consensus node operators are compensated through HBAR transaction fees collected automatically by the protocol. There are no mining rewards, block subsidies, or inflationary emissions. Virtual voting's elimination of additional inter-node message exchange reduces bandwidth and computational requirements relative to classical BFT protocols and proof-of-work designs, lowering the operational cost basis for node operators. Governance of Fee Parameters Hedera network-level fee schedules are adjusted by the Governing Council to maintain stable USD-equivalent costs as HBAR market prices change. Token-level fee parameters, to the extent any are configured, would be governed by the holder of the Fee Schedule Key for token 0.0.4873177. Treasury distribution policy, including the per-transaction caps of 0.1% FDV for gifts, 0.2% FDV for liquidity transactions, and 0.01% FDV for team liquidations, is set by Bitcoin HT, LLC, with team allocations enforced on-chain by the DaVinciGraph lock.
H.6	Use of distributed ledger technology	FALSE
H.7	DLT functionality description	N/A
H.8	Audit	TRUE
H.9	Audit outcome	BTC.ℏ has not itself been audited. The relevant public audit is of the Hedera Token Service, the native token infrastructure on which a Hedera-issued token such as BTC.ℏ relies. That is not an audit of BTC.ℏ’s own token configuration, treasury controls, wallet design, or application-layer systems. FP Complete, February 2021, Hedera Token Service Audit Report Object: External-distribution audit of the Hedera Token Service for Hedera Hashgraph. FP Complete reviewed HTS-related public documentation and the Hedera services repository up to commit feab04af3f4e8c18915fb42ca2cb3395c43bd885. The scope excluded non-HTS code, test code, generated code, infrastructure and network architecture, and business-use-case assessment. Results: 0 red flag issues and 3 yellow flag issues. The findings concerned misuse of builder design patterns in HTS fee and usage code, insufficient source-code documentation, and inconsistencies in token transaction validation logic. The documentation review noted 165 PMD documentation violations in hapi-fees and 20,073 across Hedera services in a broader non-test scan. Actions: Previously fixed issues were omitted from the report. For the remaining findings, FP Complete recommended refactoring builder-style APIs, improving code documentation, and standardising validation logic. The report does not state final closure of these remaining issues and expressly says it was incomplete and a work in progress.

Part I - Information on risks

N	Field	Content
I.1	Offer-related risks	Market Volatility and Liquidity Risk BTC.ℏ may experience significant price volatility and periods of limited liquidity. Trading is currently concentrated across a small number of venues, which may widen spreads and increase slippage. Investment can lead to partial or total loss of capital. Exchange Access, Listing, and Delisting Risk Admission to trading on any venue is at that venue's sole discretion. Policy changes, including KYC and AML updates, geo-restrictions, or delistings can restrict access to BTC.ℏ and impair exit liquidity without prior notice. Third-Party Dependency Risk Bitcoin.ℏ's utility, market visibility, and fiat accessibility depend substantially on third-party service providers that operate independently of Bitcoin HT, LLC. These include fiat on-ramp providers, centralised exchanges, decentralised exchange protocols, hardware wallet manufacturers, and the HashGate payment gateway. Changes in their policies, technical updates, service discontinuation, or regulatory action against them could impair holders' ability to trade, store, convert, or use BTC.ℏ without prior notice.
I.2	Issuer-related risks	Key Custody and Concentration Risk Bitcoin HT, LLC holds the private keys to treasury, liquidity, and team accounts. This concentrates control over a significant portion of the BTC.ℏ supply in a single entity. Compromise, misuse, or internal control failure affecting any of these accounts could adversely affect distributions, liquidity support, and market confidence. Insider Threat Risk Members of Bitcoin HT, LLC with access to private keys or operational systems could, intentionally or unintentionally, compromise security protocols. Unauthorised access or operational error by an insider could result in asset loss, disruption to distributions or liquidity operations, and reputational damage. Operational Sustainability and Funding Risk Bitcoin HT, LLC does not generate revenue from commercial operations. Its activities are funded through member capital contributions and the management of BTC.ℏ treasury and liquidity holdings. A sustained decline in BTC.ℏ market value could impair the project's ability to fund exchange listings, legal compliance, and developer engagement. No external investor or committed funding facility provides financial resilience independent of BTC.ℏ market performance.
I.3	Crypto-assets-related risks	Volatility Risk The price of BTC.ℏ is subject to sharp and unpredictable movements driven by sentiment, macro conditions, and crypto-sector events outside the issuer's control. Holders should expect and be prepared for sustained periods of significant price decline. Liquidity Risk Trading in BTC.ℏ is currently supported on a limited number of venues. While liquidity is available, order book depth may vary, and the public float represents approximately 25.71% of the total supply. As a result, execution at desired prices may be more challenging during periods of market volatility or lower activity. Supply Concentration and Float Risk A substantial proportion of the 21,000,000-unit supply is held in issuer-controlled accounts. Large issuer-initiated transfers or swaps may affect market depth and price dynamics regardless of per-transaction caps. Private Key Custody and Irreversible Loss Risk Control over BTC.ℏ depends on the secure management of private keys by each holder or their chosen wallet provider. Loss or compromise of keys results in permanent, irrecoverable loss with no recourse to the issuer or to any third party. Macroeconomic and Market Cycle Risk Demand for BTC.ℏ may decline materially during periods of global economic contraction, rising interest rates, or broad financial market stress. Economic downturns may reduce retail and developer appetite for digital assets generally, lowering trading volumes and slowing integration adoption. Bitcoin HT, LLC's operational capacity may also be constrained if treasury and liquidity holdings decline in value during risk-off conditions. Jurisdictional and Regulatory Risk Access to BTC.ℏ information and services may be restricted where contrary to local law or regulation. Each user is solely responsible for compliance with their own jurisdictional obligations. Discretionary Distribution and Swap Risk Treasury gift distributions and liquidity account swaps are exercisable at the issuer's sole discretion within stated FDV-based caps. Recipients of distributed tokens may sell promptly, exerting downward price pressure. Sustained distributions, while individually capped, may have a cumulative market impact.
I.4	Project implementation-related risks	Integration and Feature Adoption Risk Bitcoin.ℏ's roadmap depends on third-party developers, merchants, and platforms choosing to integrate BTC.ℏ into their products and services. The inkjug™ monetisation platform, which is intended to function as the primary real-world utility layer for the token, remains under development with no confirmed launch date. Existing integrations, including the Skellybets gaming platform and the ibird.io social platform, operate at limited scale. There is no guarantee that current or future integrations will achieve meaningful transaction volumes or commercial traction. Ecosystem Traction Risk The long-term value of BTC.ℏ depends on achieving a critical mass of active users, liquidity providers, and developers operating within its ecosystem. At the date of this white paper, the project is in an early stage of adoption. If ecosystem participation remains limited, market depth remains thin, and no substantial payment or utility use cases emerge, demand for the token may be insufficient to support continued ecosystem development, and the long-term viability of the project cannot be assured. Third-Party Dependency and Delivery Risk Execution of the project roadmap, including exchange listings, wallet integrations, and cross-chain deployments, depends on the sustained cooperation of third-party venues and protocol operators. Outages, policy changes, or discontinuation of any integration can impair user access and market functioning without the issuer being able to compel restoration. Compliance and Operational Scaling Risk As distribution expands, AML and KYC obligations require proportionally increasing resourcing. Current staffing and systems may not remain adequate as the project scales. Operator Access and Service Risk The operator may restrict or terminate access to project services, including by IP blocking, without prior notice. On-chain BTC.ℏ holdings are unaffected by such administrative actions, but information and interface access may be curtailed. Service Availability Risk Access to the project's online services may be interrupted or discontinued. Holders' ability to access information or perform non-custodial interactions may be affected accordingly. Reputational Risk BTC.ℏ deliberately adopts Bitcoin branding and nomenclature. The cryptocurrency market has experienced numerous fraudulent projects exploiting Bitcoin's name recognition. Prospective holders, exchanges, and integrators may conflate BTC.ℏ with such projects regardless of its independent technical and legal standing. This may impede exchange listings, limit partnerships, and constrain ecosystem growth. Competitive Market Risk BTC.ℏ competes for liquidity and adoption with HBAR and other Hedera-native tokens, with Bitcoin-derivative products on larger networks, and with established low-cost payment protocols. Competing assets may offer greater liquidity, wider exchange availability, or stronger network effects. There is no assurance that BTC.ℏ's distinctive features will sustain a competitive position as the market evolves.
I.5	Technology-related risks	Base-Chain Dependancy Risk BTC.ℏ is a native token on the Hedera network and, as with any asset issued on a public distributed ledger, protocol updates, governance decisions, or technical incidents at the base-layer level may affect transaction processing, token functionality, or service availability. Smart Contract and Token Lock Risk Team allocation tokens are governed by a DaVinciGraph on-chain time-lock. Misconfiguration or undiscovered vulnerabilities in this contract could affect the enforceability of the lock or access to tokens following threshold attainment. No independent audit of this specific contract has been published. Token-Level Administrative Controls Risk HTS supports optional administrative key roles including Admin, Freeze, Wipe, Pause, and KYC keys that could materially affect token holders if active. The configuration of these keys for token 0.0.4873177 has not been publicly disclosed beyond the confirmed absence of a Supply Key. Cybersecurity Risk The project's digital infrastructure and issuer-controlled accounts are potential targets for cyberattacks including hacking, phishing, and malware. A successful attack could result in financial loss, unauthorised BTC.ℏ transfers, or exposure of operational data, with potential reputational and market consequences.
I.6	Mitigation measures	Offer-Related Risks Market Risk: Prospective purchasers are warned at the point of access that investment can lead to loss and that significant price fluctuations are expected. No assurance of capital preservation is given. Exchange Access, Listing, and Delisting Risk: Reliance on third-party venues is publicly disclosed through dated milestone records. Venue availability is presented as externally determined and subject to change without notice. Third-Party Service and Content Risk: All confirmed third-party service relationships are documented in D.8 milestone records and H.3 technology integrations. No contractual continuity obligations are held over any third-party integration, and this is explicitly disclosed. Issuer-Related Risks Key Custody and Concentration Risk: Private keys for all issuer-controlled accounts are held in offline cold storage with physically separate printed backups. Access is restricted to authorised members with two-factor authentication. Continuous monitoring and periodic vulnerability assessments are maintained. In the event of a security breach, holders will be notified through the project's official website and social media channels, and corrective measures will be implemented. Insider Threat Risk: Access to project assets is restricted to authorised members on a need-to-access basis. Two-factor authentication is applied to all systems interacting with project assets. Monitoring and audit tools are in place to detect and respond to suspicious internal activity. Security practices are reviewed regularly. Operational Sustainability: Domain assets (bitcoin.org.ht and bitcoin.com.ht) constitute non-crypto-denominated holdings with independent value. Liquidity account swaps may be used to convert BTC.ℏ into stablecoins for operational purposes within the disclosed 0.2% FDV cap. Crypto-Asset-Related Risks Market Volatility Risk: Investment risk warnings are displayed at the point of access. To protect the operational value of treasury and liquidity holdings against BTC.ℏ price fluctuations, Bitcoin HT, LLC may employ hedging strategies and maintain diversified holdings including stablecoin positions within disclosed liquidity account parameters. No assurance of capital preservation is given to holders. Market Liquidity Risk: The project is actively seeking Tier 1 exchange listings including EU-regulated trading platforms to broaden venue access and deepen order book liquidity over time. Supply Concentration and Float Risk: All treasury, liquidity, and team-controlled Hedera account addresses are publicly disclosed. Issuer-initiated supply events are subject to FDV-based per-transaction caps: treasury gifts ≤ 0.1%, liquidity swaps ≤ 0.2%, team releases ≤ 0.01% (additionally locked on-chain until USD 250,000,000 FDV via DaVinciGraph smart contract 0.0.8215492). These caps limit the impact of any single supply event; cumulative distributions may nonetheless affect price over time. Private Key Custody and Irreversible Loss Risk: The non-custodial boundary is established: the project website does not store or transmit BTC.ℏ. Holders are directed to rely on their own wallet security practices and are encouraged to use supported hardware wallet solutions (Ledger, Tangem, D'Cent). Jurisdictional and Regulatory Risk: Access to BTC.ℏ services is restricted where contrary to local law. Each user is assigned responsibility for their own jurisdictional compliance. Bitcoin HT, LLC monitors regulatory developments and engages legal expertise to ensure timely adaptation to evolving requirements. The project's operational model is designed to accommodate regulatory change with minimal disruption. Project Implementation Risks Third-Party Dependency and Delivery Risk: Prior to integration, Bitcoin HT, LLC conducts security assessments of third-party vendors and partners. Service level agreements including security requirements and breach response protocols are established where applicable. Contingency and backup arrangements are maintained to support continued operations in the event of third-party service disruption or discontinuation. Compliance and Operational Scaling Risk: A designated compliance officer, risk-based AML and KYC framework, mandatory reporting obligations, and five-year record retention are operational. Ecosystem Traction Risk: The project is pursuing structured distribution initiatives including the "1 Free BTC.ℏ Program" launched March 2026, developer and business outreach programmes, and Tier 1 exchange listings (D.8 Future Milestones) to broaden the holder base and stimulate usage. Reputational Risk: Bitcoin HT, LLC maintains public disclosure of governance, token distribution, and on-chain account identifiers. The AML/KYC and security policies are publicly available. MiCA compliance serves as an additional credibility mechanism within the EU. Competitive Market Risk: BTC.ℏ's fixed 21,000,000-unit supply, Bitcoin-compatible nomenclature, Hedera-native aBFT settlement, and the inkjug™ payment infrastructure under development constitute its primary differentiators. Listing on exchanges is targeted as a means of improving liquidity depth relative to competing assets. Technology-related risks Base-Chain Dependency Risk: Hedera publishes a real-time public network status page (status.hedera.com) covering mainnet, testnet, and mirror node API availability, enabling incident monitoring without reliance on issuer communication. Smart Contract and Token Lock Risk: The DaVinciGraph time-lock enforces the USD 250,000,000 FDV access threshold on-chain independently of any action by Bitcoin HT, LLC. Smart contracts used in project operations are subject to security review prior to deployment. Ongoing monitoring is conducted to identify and address newly discovered vulnerabilities. Cybersecurity Risk: Bitcoin HT, LLC implements encryption, multi-factor authentication, and periodic security audits across systems interacting with project assets. In the event of a security breach, holders will be notified through the project's website and social media channels, and corrective measures will be implemented to prevent recurrence.

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

Index

General information

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

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

Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

Part D - Information about the crypto-asset project

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

Part F - Information about the crypto-assets

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

Part H – Information on 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