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	2026-03-19
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 operator of the trading platform 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	SKY is a crypto-asset used within the Sky Protocol, a decentralised blockchain-based financial system that evolved from the MakerDAO ecosystem. The Sky Protocol operates on the Ethereum Blockchain and provides infrastructure for decentralised governance and on-chain financial mechanisms. SKY primarily functions as a governance crypto-asset. Holders of SKY may participate in governance processes relating to the operation, parameters and evolution of the Sky Protocol. Governance participation is typically exercised through voting mechanisms in accordance with the rules and procedures defined by the protocol. Participation in governance may require holders to stake or otherwise commit their SKY holdings in line with the applicable governance framework. In addition to governance participation, SKY may be used within ecosystem mechanisms, including staking, incentive programmes and other protocol modules made available through the Sky Protocol. The availability and conditions of such mechanisms are determined by the protocol rules and may change over time. Holding SKY does not confer ownership, profit participation, repayment or redemption rights against a central issuer. SKY does not represent a claim on assets or revenues and does not provide holders with a guaranteed right to compensation or value protection. The value of SKY is determined by market conditions and may fluctuate.
09	Further information about utility tokens	This field does not apply, as 05 is False.
10	Key information about the offer to the public or admission to trading	Bitstamp Europe S.A. is now seeking its admission to trading of SKY tokens within the EU enabling compliant secondary market liquidity. This admission would allow existing holders to trade SKY on a regulated EU venue 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
A.1	Name	N/A
A.2	Legal form	N/A
A.3	Registered address	N/A
A.4	Head office	N/A
A.5	Registration date	N/A
A.6	Legal entity identifier	N/A
A.7	Another identifier required pursuant to applicable national law	N/A
A.8	Contact telephone number	N/A
A.9	E-mail address	N/A
A.10	Response time (Days)	N/A
A.11	Parent company	N/A
A.12	Members of the management body	N/A
A.13	Business activity	N/A
A.14	Parent company business activity	N/A
A.15	Newly established	N/A
A.16	Financial condition for the past three years	N/A
A.17	Financial condition since registration	N/A

N	Field	Content
B.1	Issuer different from offerror or person seeking admission to trading	TRUE
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
E.1	Public offering or admission to trading	ATTR
E.2	Reasons for public offer or admission to trading	By admitting the SKY 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	Target expressed in currency	N/A
E.3	Target expressed in units	N/A
E.3	Target expressed in digital token identifier	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.9	Official currency or any other crypto-assets determining the issue price	N/A
E.10	Fee expressed in currency	N/A
E.10	Fee expressed in units	N/A
E.10	Fee expressed in digital token identifier	N/A
E.11	Offer price determination method	N/A
E.12	Total number of offered/traded crypto-assets	23462665147 The number of SKY admitted to trading may vary over time due to changes in circulating supply resulting from governance controlled mechanisms, including staking, treasury holdings, token migration status, and protocol directed buybacks executed through the Smart Burn Engine. As of the date of this white paper, the circulating supply is approximately 23 billion SKY, with the remaining tokens not in circulation in accordance with the Sky Protocol’s supply and governance 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	The token will be available for trading on Bitstamp Europe S.A. trading platform. The token can be purchased there by using deposited funds or any other valid form of payment available on the trading platform.
E.25	Value transfer methods for reimbursement	N/A
E.26	Right of withdrawal	N/A
E.27	Transfer of purchased crypto-assets	When a client purchases a token on the Bitstamp Europe S.A.'s trading platform, the crypto-asset will be credited to their Bitstamp account. If a client wants to hold the token in their own wallet, they will need to (i) provide an external blockchain wallet address, where the crypto-assets will be sent if a withdrawal is initiated and (ii) satisfy all other requirements applicable to a withdrawal in line with the Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets.
E.28	Transfer time schedule	N/A
E.29	Purchaser's technical requirements	When a client purchases a token on the Bitstamp Europe S.A.'s trading platform, the crypto-asset will be credited to their Bitstamp account and a client does not need to fulfill any other technical requirement to hold the crypto-assets on their Bitstamp account, apart from have either a computer or phone with an internet connection and appropriate software in order to interact with the Bitstamp services.
E.30	Crypto-asset service provider (CASP) name	Not Available
E.31	CASP identifier	N/A
E.32	Placement form	N/A
E.33	Trading platforms name	Bitstamp Europe S.A.
E.34	Trading platforms Market identifier code (MIC)	BESA
E.35	Trading platforms access	Admission to trading of the SKY crypto-asset is sought on Bitstamp. Access to trading, once admission is granted, will be provided through Bitstamp’s trading platform, including its website and mobile applications, in accordance with Bitstamp’s terms of use and applicable regulatory requirements.
E.36	Involved costs	There are no costs involved in creating an account on the trading platform, however trading fees and other costs apply in accordance with the fee schedule available at https://www.bitstamp.net/fee-schedule.
E.37	Offer expenses	This field does not apply, as there is no offer to the public.
E.38	Conflicts of interest	There are no conflicts of interest of the persons involved in the admission to trading. Bitstamp Group has a strict Code of Conduct and Trading Policy in place. They both mitigate the possibility of conflicts of interest. In accordance with the Code of Conduct all officers, directors, employees, agents, representatives, contractors and consultants (and other persons, regardless of job or position), are required to report any situation where there is the potential for conflict of interest between their interests and interests of Bitstamp. The Trading Policy that is in place within the Bitstamp Group prohibits all forms of market manipulation and has been designed to prevent insider trading.
E.39	Applicable law	Luxembourg
E.40	Competent court	Luxembourg

N	Field	Content
F.1	Crypto-asset type	Crypto-assets other than asset-referenced tokens or e-money tokens
F.2	Crypto-asset functionality	The primary functionality of SKY is governance participation. Holders of SKY may participate in the Sky Protocol’s governance processes, including voting on proposals relating to protocol parameters, system upgrades, risk management frameworks and ecosystem development. Governance participation is exercised in accordance with the protocol’s governance rules and procedures and may require holders to stake or delegate their SKY holdings as specified by the governance framework in force at the relevant time. SKY is also used within protocol-level economic and incentive mechanisms, including staking-based participation and reward structures made available through the Sky Protocol. These mechanisms are designed to support protocol operation and governance participation rather than to provide access to a discrete good or service supplied by a central issuer. The Sky Protocol incorporates mechanisms for managing both surplus and deficit within its stablecoin system. Excess stablecoin proceeds including net revenue and stability fees may accumulate in the protocol’s internal buffer. When the buffer exceeds a governance determined threshold, surplus stablecoins are put into surplus auctions, where they are exchanged for SKY governance tokens that are subsequently removed from circulation, thereby helping to balance overall economic conditions within the protocol. Conversely, if the protocol incurs uncovered debt that cannot be covered by available surplus, debt auctions may be triggered, in which newly minted governance tokens are sold for stablecoins to recapitalise the system. These auction-based mechanisms surplus auctions to retire governance tokens and debt auctions to address shortfalls form core elements of the protocol’s financial stability framework, directly supporting the integrity of the stablecoin and broader ecosystem operations. USDS is the native stablecoin of the Sky Protocol., and governance decisions taken by SKY holders may influence parameters and mechanisms relating to stablecoin operation, savings modules and other on-chain financial components of the ecosystem.
F.3	Planned application of functionalities	Not applicable
F.4	Type of crypto-asset white paper	OTHR
F.5	The type of submission	NEWT
F.6	Crypto-asset characteristics	SKY is a fungible crypto-asset that is transferable between compatible blockchain addresses without the involvement of a central intermediary. It does not represent ownership, equity, a claim on assets or revenues, nor does it confer any right to repayment or redemption against a central issuer. The primary characteristic of SKY is its governance function. Holders of SKY may participate in governance processes relating to the operation, parameters and evolution of the Sky Protocol, subject to the applicable governance rules and procedures. Governance participation may require delegation, staking or other procedural steps defined by the protocol at the relevant time. MakerDAO rebranded to Sky in 2024 and introduced SKY as the new native governance token. MKR and SKY coexist, with conversion available from MKR to SKY. Sky Ecosystem governance has been transitioning governance from MKR to SKY, with SKY becoming the governance token for on-chain voting on the new governance system. The protocol conversion rate is 1 MKR to 24 thousand SKY. However, governance can apply a Delayed Upgrade Penalty over time that reduces the net SKY received for later upgrades.
F.7	Commercial name or trading name	N/A as DTI is provided in F.13
F.8	Website of the issuer	This field does not apply as SKY is not issued by an identifiable legal entity.
F.9	Starting date of offer to the public or admission to trading	2026-04-21
F.10	Publication date	2026-04-20
F.11	Any other services provided by the issuer	This field does not apply as SKY is not issued by an identifiable legal entity.
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	70LZN86TK
F.14	Functionally fungible group digital token identifier, where available	G4GDNF84C
F.15	Voluntary data flag	FALSE
F.16	Personal data flag	TRUE
F.17	LEI eligibility	FALSE
F.18	Home Member State	Luxembourg
F.19	Host Member States	Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden

N	Field	Content
G.1	Purchaser rights and obligations	There is no legal or smart contract that confers to the SKY crypto-asset purchasers any ownership, equity, profit participation, repayment or redemption rights against a central issuer or the Sky Protocol. Holding SKY does not give rise to contractual claims or entitlements against any natural or legal person. As reflected in the governance documentation available on the Sky.money website (https://vote.sky.money/), at the time of this white paper, SKY holders are granted only limited functional rights within the ecosystem,which are further described as crypto-asset functionalities in F.2.
G.2	Exercise of rights and obligations	SKY does not confer ownership or financial claims and does not impose any legal obligations.
G.3	Conditions for modifications of rights and obligations	SKY does not confer ownership or financial claims and does not impose any legal obligations.
G.4	Future public offers	There are no future public offers planned at this stage.
G.5	Issuer retained crypto-assets	0
G.6	Utility Token Classification	FALSE
G.7	Key features of goods/services of utility tokens	This field does not apply as G.6 is false.
G.8	Utility tokens redemption	This field does not apply as G.6 is false.
G.9	Non-trading request	TRUE
G.10	Crypto-assets purchase or sale modalities	N/A
G.11	Crypto-assets transfer restrictions	While the SKY crypto-asset itself has no native restrictions, the main user interface sky.money, which is maintained by Skybase International, restricts access to certain services and transactions for users located in jurisdictions where use would violate applicable laws or sanctions. Users are prohibited from accessing specific features, including trading, savings and rewards modules, if they reside in Afghanistan, Belarus, Burma, Burundi, Central African Republic, China, Crimea, Cuba, Democratic Republic of the Congo, Donetsk, Ethiopia, Guinea, Guinea-Bissau, Haiti, Hong Kong, Iran, Iraq, Kherson, Lebanon, Libya, Luhansk, Mali, Nicaragua, Niger, North Korea (DPRK), Russia, Somalia, South Sudan, Sudan and Darfur, Syria, United Kingdom, Venezuela, Yemen, Zaporizhzhia, and Zimbabwe. Users in these locations are prohibited from accessing certain features such as trading, Sky Savings Rate, and token rewards. Additionally, users must ensure that transfers do not involve individuals sanctioned under OFAC, EU, or UK regulations, and are responsible for complying with all local laws and sanctions. Failure to comply may result in service restrictions, blocked access, or reporting to authorities.
G.12	Supply adjustment protocols	FALSE
G.13	Supply adjustment mechanisms	This field does not apply, as G.12 is false.
G.14	Token value protection schemes	FALSE
G.15	Token value protection schemes description	This field does not apply, as G.14 is false.
G.16	Compensation schemes	FALSE
G.17	Compensation schemes description	This field does not apply, as G.16 is false.
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 (to the extent that can be identified) 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 that competent court will depend on the location of the issuer and the given token-holder and characteristic performance of the legal relationship, and any agreed intention of the issuer and crypto asset holder.

Part H – Information on underlying technology

N	Field	Content
H.1	Distributed ledger technology	N/A as DTI is provided in F.13
H.2	Protocols and technical standards	Networking layer Ethereum operates a permissionless peer-to-peer network using DevP2P protocol suite for node communication. Nodes discover peers through discv5 (discovery version 5), implementing Kademlia-based distributed hash table for decentralised peer location without central coordination. Full nodes maintain connections to approximately 50-100 peers, propagating transactions and blocks through gossip protocols ensuring network-wide distribution within seconds. Transaction Propagation User-signed SKY transactions broadcast from wallet software reach connected Ethereum nodes entering local mempools (pending transaction pools). Nodes validate transaction signatures, nonce sequencing, and gas parameters before relaying to peers. Gossip propagation ensures transaction distribution across the network, reaching validator mempools where they await inclusion in proposed blocks. Transaction replacement follows EIP-1559 priority fee mechanics, with higher-fee transactions displacing lower-fee equivalents in resource-constrained mempools. Interface Layer Non-custodial interfaces such as sky.money serve as transaction construction interfaces, submitting signed transactions to the Ethereum network without holding user funds or operating intermediary infrastructure. SkyLink components facilitate asset bridging between Ethereum mainnet and layer-2 networks including Base, Arbitrum, Optimism and Unichain, maintaining canonical state records on mainnet while enabling cross-chain interoperability. Application layer The application layer implements protocol functionality through interconnected smart contract modules: Core accounting system: The vat contract serves as the central accounting ledger, recording all collateralised debt positions, tracking vaultspecific collateral ratios, and enforcing systemwide solvency constraints. USDS token balances directly correspond to internal vat accounting entries, ensuring that stablecoin issuance remains fully collateralised. Vault mechanics: The LockstakeEngine contract manages SKYcollateralised positions, enabling users to lock SKY for governance participation while borrowing USDS against locked collateral. Users create non-custodial urns (vault structures) by depositing SKY, generating voting weight and borrowing capacity simultaneously. Vault closure requires USDS debt repayment plus accrued stability fees, with exit fees applied on SKY withdrawal. Other collateral types utilise separate vault modules; LockstakeEngine specifically handles SKY governance token collateralisation. Multiurn architecture: LockstakeEngine enables multiple independent urns per Ethereum address, each maintaining isolated VoteDelegate assignments, farming module selections, and debt positions. SKY cannot transfer between urns without exit fees, enforcing position separation. Liquidation triggers affect individual undercollateralised urns without impacting other positions held by the same address. Liquidation system: Vaults falling below governancedefined liquidation ratios enter automated collateral auctions. Auction proceeds cover outstanding debt, liquidation penalties and system obligations, with any remaining collateral returned to the vault owner. This mechanism maintains protocol solvency during adverse market conditions. Surplus management: Protocol revenues exceeding the governanceset buffer threshold trigger surplus auctions, where excess USDS is exchanged for SKY tokens. Acquired SKY tokens are permanently destroyed through burn operations, creating deflationary pressure on governance token supply proportional to protocol profitability. Real-world asset integration: RWA vaults extend the collateral framework to offchain assets through specialised smart contract components: RWA urns (vault structures), RWA tokens (collateral representations) and RWA liquidation oracles (price and valuation feeds). Governance exclusively authorises RWA vault creation and approves counterparties operating these structures. Oracle infrastructure: Decentralised price feeds supply collateral valuations, selected through governance processes. The Oracle Security Module introduces a mandatory one-hour delay before price updates activate in protocol logic, mitigating flash crash and oracle manipulation risks. Emergency oracles possess authority to freeze compromised price feeds and initiate global emergency shutdown procedures, subject to governance oversight.
H.3	Technology used	Execution environment SKY operates within the Ethereum Virtual Machine executing Solidity-compiled bytecode at contract address 0x56072C95FAA701256059aa122697B133aDEd9279. Transaction validation occurs through Ethereum validator clients (Geth, Nethermind, Besu, Erigon) with gas metering constraining computational resources. Core software components The protocol employs modular smart contract architecture. Vat contract provides central accounting, tracking collateralised positions through normalised debt (art) and collateral units (ink) with 18-decimal precision. Fee accrual operates via rate accumulation variables, calculating stability fees as time-weighted obligations. Collateral handling coordinates across Vat (accounting), Spot (collateralisation enforcement), and Clipper (auction execution) modules. Chief aggregates voting weight through SKY token deposits, implementing continuous approval voting. Pause enforces mandatory time delays on governance actions. Spell contracts execute parameter changes as atomic bundles. Smart Burn Engine coordinates surplus auctions with automated token destruction. Wallet technologies SKY requires standard Ethereum wallets supporting ERC-20 interactions and contract calls. Non-custodial implementations (MetaMask, Ledger, Trezor) enable direct protocol access. SKY implements EIP-2612 permit for gasless approvals via off-chain signatures and EIP-1271 for smart contract wallet authorisation. Protocol interactions (Lockstake staking, VoteDelegate delegation, farming rewards) execute through wallet-initiated contract calls creating non-custodial positions owned by user addresses. Key management Users maintain exclusive private key control with no issuer-managed keys or custodial solutions. Private keys generate Ethereum addresses via ECDSA (secp256k1) public key derivation and Keccak-256 hashing. Hardware wallets isolate keys in security chips requiring physical confirmation. Software wallets encrypt key material using passwords or biometrics. BIP-39 seed phrases enable cross-wallet recovery. Multi-signature and account abstraction (ERC-4337) support distributed control and programmable authorisation while maintaining non-custodial architecture. Oracle infrastructure Price feed oracles supply collateral valuations with Oracle Security Module enforcing one-hour delay before activation, mitigating flash crashes and manipulation. Governance-selected providers push updates to OSM storage. Emergency oracles can freeze compromised feeds and initiate global settlement. Keeper infrastructure Independent economic actors monitor vault ratios triggering liquidations when undercollateralised, and surplus levels initiating auctions when reserves exceed buffers. Keepers operate without protocol infrastructure, incentivised through liquidation penalties and auction participation. Supporting systems Protocol interfaces with Ethereum's peer-to-peer network for transaction propagation. IPFS hosts governance documentation via content-addressing. SkyLink bridges coordinate cross-chain transfers to Base, Arbitrum, Optimism, and Unichain through lock-and-mint mechanisms.
H.4	Consensus Mechanism	Ethereum's proof-of-stake consensus secures all SKY protocol state transitions. Validators deposit 32 ETH into the Ethereum staking contract, gaining block proposal privileges and attestation responsibilities. Time progresses in 12-second slots aggregated into 32-slot epochs. Each slot features one randomly selected proposer and a validator committee providing attestations. Validators deterministically order transactions within proposed blocks based on priority fee bidding and position within mempool queues. This ordering mechanism ensures consistent execution sequence for interdependent SKY operations, preventing front-running of governance votes. This is achieved through transaction reordering and maintaining fairness in liquidation auctions where multiple keepers compete for collateral. Block proposals occur every 12 seconds, with validators randomly selected via RANDAO, distributing proposal opportunities across the validator set and preventing predictable censorship windows. SKY transfers, Chief voting weight updates, and vault state modifications execute in their included block's sequence, with finalisation guaranteeing irreversible ordering after checkpoint epochs. Finality derives from checkpoint-based voting: when two checkpoint epochs form a supermajority link (votes representing ≥66.67% of total staked ETH), all transactions in the finalised epoch become irreversible. Reverting finalised blocks requires destroying substantial validator stake through slashing mechanisms, creating economic barriers to chain reorganisation attacks. SKY transfers, mint/burn operations and governance executions inherit Ethereum's finality guarantees. Once transactions settle in finalised blocks, state changes become economically irreversible, backed by the aggregate value of staked ETH securing the network.
H.5	Incentive Mechanisms and Applicable Fees	Network-level fees All Ethereum transactions incur gas fees denominated in ETH, calculated as gas_used × gas_price. Users pay gas fees for SKY transfers, MKR-to-SKY conversions, vault operations and governance votes. These fees compensate validators for block inclusion and execution, flowing entirely to Ethereum network participants rather than Sky Protocol. SkyLink bridging operations between the Ethereum mainnet and layer-2 networks (Base, Arbitrum, Optimism, Unichain) involve separate fee structures depending on the target network's gas model and bridge architecture. Protocol-level fees Stability fees: Vault owners accumulate timebased stability fees on generated USDS, calculated as interest on outstanding debt. Fee rates vary by collateral type and are set through governance processes. Stability fees must be paid in USDS alongside principal repayment to withdraw collateral. Liquidation penalties: Undercollateralised vaults incur fixed percentage penalties added to debt obligations during liquidation. Penalty revenue contributes to protocol surplus. Surplus auctions: USDS holdings exceeding the governancedefined buffer threshold enter surplus auctions, where USDS is exchanged for SKY at marketdetermined rates. Acquired SKY tokens are immediately burned, permanently reducing governance token supply. Delayed Upgrade Penalty: The MkrSky Converter V2 contract implements a timebased penalty fee on MKR-to-SKY conversions activated September 18, 2025 at an initial rate of 1%. The penalty increases by one percentage point every three months until reaching 100% in 25 years. Validator incentives Ethereum validators receive block rewards comprising base issuance and priority fees from included transactions. Validators face slashing penalties for protocol violations including double-signing, incorrect attestations and prolonged offline periods. Slashed ETH is partially burned and partially awarded to whistleblower validators. SKY protocol activity contributes transaction fees to Ethereum validators through gas payments on all protocol interactions. The protocol itself does not operate validator infrastructure or distribute staking rewards. Governance of parameters SKY holders exercise parameter control through executive voting, adjusting: Stability fee rates per collateral type Liquidation ratios and penalties Surplus buffer levels triggering auctions Oracle feed selections and emergency authorities RWA vault configurations and operator authorisations Sky Savings Rate percentages Parameter changes require proposal submission, voting period completion and time-delayed execution through the Pause module, providing transparency and reaction windows for parameter adjustments.
H.6	Use of distributed ledger technology	FALSE
H.7	DLT functionality description	N/A
H.8	Audit	TRUE
H.9	Audit outcome	Cantina \| June 2024 - Lockstake Engine Object: Security review of LockstakeEngine contracts enabling SKY locking for governance, multiurn vault management, USDS farming rewards, vault collateralisation, exit fees, and liquidation procedures. Review covered lockstake/src directory and deployment scripts on commit 735e1e85. Results: Identified 14 findings: one lowseverity issue (debt ceiling timing via AutoLine), three gas optimisations (reentrancy lock inefficiency, unnecessary validation checks), and ten informational items (input sanitisation, vote delegate selection delays, farm token compatibility, operator privileges). Actions: All issues resolved on commit de66d6fc. Protocol team acknowledged AutoLine timing issue as acceptable tradeoff for consistency with existing patterns. Cantina \| April 2025 - VoteDelegate Object: Security review of VoteDelegate contracts managing governance delegation, examining authorisation patterns, Chief integration, and flash loan protections. Focused on gas efficiency and code quality improvements on commit ca1f2fb9. Results: Single informational finding recommending calldata over memory for vote function's yays parameter to improve gas efficiency and maintain consistency with Chief contract. Actions: Fix implemented on commit ab978364 and verified through followup review with no new vulnerabilities identified. Cantina \| July 2024 - Surplus Auction Flappers Object: Security audit of surplus auction contracts managing excess USDS through automated auctions, examining SKY acquisition and burn mechanisms, Splitter fund distribution, and UniswapV2 integrations. Covered Splitter, FlapperUniV2, OracleWrapper contracts on commit 4b0cb1f5. Results: Identified five findings: two gas optimisations (OracleWrapper contract structure, pair token detection) and three informational items (rewards duration alignment, initialisation validation, sandwich attack considerations). Actions: Findings documented for protocol evaluation with no critical remediation required. Sherlock \| July-August 2024 - Endgame Launch Contest Object: Public audit contest examining eight Endgame repositories (USDS, SKY, stUSDS, flappers, VoteDelegate, Lockstake, toolkit, pool migrator) with USD 1.38 million prize pool. Contest ran July 8 through August 5, 2024, evaluating functional correctness, economic security, and governance integrity. Results: Two informational findings were identified with zero critical/high/medium issues. Primary finding documented theoretical LSUrn address collision attack requiring more than USD 1.5 million computational investment to exploit create2 mechanism for governance manipulation. Actions: Protocol team acknowledged collision risk as economically infeasible at current costs with declining threat as network security improves. No immediate remediation implemented given informational severity classification. ChainSecurity \| 2024 - Chief Smart Contracts Object: Security review of continuous approval voting system implementing SKY governance token, examining vote aggregation, frontrunning protection, and governance suitability. Results: Codebase demonstrated high security level across evaluated dimensions with issues identified and addressed collaboratively. Actions: All findings remediated and verified. Immunefi \| Ongoing - Bug Bounty Program Object: Continuous vulnerability disclosure program covering all deployed Sky Protocol contracts with rewards from USD 1 thousand to USD 10 million. Critical bugs rewarded at 10% of funds at risk (minimum USD 150 thousand), temporary freezing doubled per 300 blocks (cap USD 100 thousand), governance manipulation fixed at USD 100 thousand. Results: Submissions and payouts confidential under coordinated disclosure model. Programme operates with immediate assessment, fix development, governance approval, and deployment protocols. Actions: Programme active as of February 2026 processing ongoing submissions per published policies.

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

N	Field	Content
I.1	Offer-related risks	Market price volatility and valuation risk SKY may experience material price volatility, including abrupt price changes that are not correlated with protocol fundamentals. This risk is amplified during the MKR-to-SKY transition, as liquidity and price discovery shift across venues and routes. Liquidity and conversion-route concentration risk Secondary-market liquidity for the SKY token may be limited or fragmented across various platforms and venues. During transition from MKR to SKY, the Converter contract could be viewed as the most reliable route for converting MKR to SKY. This preference may lead to effective liquidity concentrating in this single on-chain contract, potentially amplifying certain market dynamics or execution risks for users. Trading and access restriction risk SKY token trading and liquidity access rely on external platforms, including decentralised exchanges, centralised exchanges, DEX aggregators, and web-based front-end interfaces who implement their own operational policies and jurisdictional restrictions, policy changes, or delisting decisions. Lack of Intrinsic Value The token does not possess inherent utility, functioning solely as a speculative asset. Its valuation is predominantly influenced by community engagement, speculative activities, and overall market sentiment, which presents considerable challenges to sustaining long-term value stability. Delisting Risks Bitstamp Europe S.A. might remove the token from trading in line with Bitstamp Markets Trading Rules.
I.2	Issuer-related risks	Not applicable, as SKY does not have an identifiable issuer under MiCA; SKY tokens are generated and governed through a fully decentralised, permissionless smart contract protocol on Ethereum, with no centralised legal entity controlling issuance or distribution.
I.3	Crypto-assets-related risks	Token contract privileged-role risk The SKY token contract is controlled by “wards” with privileged access, including the ability to add/remove wards and mint SKY. Compromise or misuse of privileged access could affect supply and holder interests. Transaction finality and execution risk SKY transfers and interactions occur on Ethereum and are therefore subject to congestion, fee volatility, execution delays/failures, and other network conditions. Converter mechanics and rounding risk The bidirectional conversion path uses a fixed rate, and the SKY-to-MKR path rounds down when the SKY amount is not a multiple of the rate, which can result in small conversion losses. Allowance/signature validation risk SKY supports permit-based approvals and EIP-1271 contract signature validation. User error or integration mistakes in approval/signature flows can lead to unintended approvals or failed transactions. Transfer restriction edge-case risk The audited design of SKY includes restrictions such as disallowing transfers to the zero address or to the token contract itself, which may cause unexpected transfer failures for some operational workflows. Scams Due to the irreversible execution of blockchain transactions and the limited ability to identify counterparties in decentralised environments, crypto-asset markets are particularly exposed to fraudulent activity. Once assets are transferred, recovery is typically not possible. Investors should therefore exercise heightened caution when acquiring or transferring crypto-assets. Fraudulent schemes may include, among others, the issuance of counterfeit tokens bearing similar names, phishing attempts via email or social media, fake promotions or airdrops, and impersonation or identity theft. Market Abuse Crypto-asset markets may be particularly vulnerable to market abuse due to the characteristics of the underlying blockchain infrastructure and the fragmented nature of trading across platforms and jurisdictions. Practices such as front-running, spoofing, pump-and-dump schemes, wash trading, and other forms of manipulation may occur across different systems, trading venues, or geographic locations. These risks may be amplified for crypto-assets with low market capitalisation, limited liquidity, or a small number of trading venues. Such conditions can increase price volatility and susceptibility to manipulation, potentially resulting in significant losses, including the total loss of the invested funds
I.4	Project implementation-related risks	Migration and upgrade execution risk Integrators are required to support both MKR and SKY during transition, highlighting operational steps and timelines. Failures or delays by integrators (wallets, DEXes, exchanges, lending protocols) may cause user disruption and liquidity issues. Dependency and third-party service provider risk Availability depends on third-party service providers and vendors; outages or failures can degrade or interrupt access to protocol interactions through the official interface. Third-party subdomain / ecosystem site risk Certain sky.money subdomains accessible through the interface are controlled by independent third parties and may have different governing terms. This can create user confusion and inconsistent risk controls.
I.5	Technology-related risks	Smart contract vulnerability risk Sky’s codebases have undergone multiple audits, but both the audit summary and the audit report emphasise that audits are time-boxed and cannot uncover all vulnerabilities; exploitation could cause loss of assets or protocol malfunction. Governance-module technical risk The Pause design relies on scheduled plans, delegatecall via proxy, and constraints (plot/exec/drop); flaws in these invariants or misconfiguration could enable harmful governance actions or prevent corrective action. Oracle and external data risk Oracle failures, including price data manipulation, incorrect valuations, delayed updates, or complete feed downtime, may directly compromise vault safety calculations and liquidation trigger thresholds. Malfunctioning oracles can cause premature liquidations during flash crashes, delayed liquidations allowing protocol undercollateralisation, or incorrect collateral ratio calculations enabling unauthorised USDS generation against insufficient backing. Front-end integrity / phishing and signing risk Interface compromises may attempt to trick users into signing malicious transactions or display incorrect information; users remain responsible for wallet security and signing decisions. Bug bounty scope limitation risk The bug bounty is managed by Immunefi and is subject to its scope and rules; exclusions or scope gaps may leave some issues undiscovered by the programme.
I.6	Mitigation measures	Offer-related risks Market price volatility and valuation risk: The MKR-to-SKY conversion mechanism applies a fixed 1:24000 exchange rate and uses mint/burn logic for conversions, providing a deterministic conversion path that is not subject to DEX price slippage along that route. Liquidity and conversionroute concentration risk: The converter deployment is described as assessing no fees, and as not allowing fees to be enabled for that route, limiting discretionary cost changes in the converter path itself. Trading and access restriction risk: The official web applications implement geoblocking and VPN blocking controls (including sanctionsrelated enforcement), providing an operational mechanism to restrict access in line with eligibility constraints. Crypto-asset-related risks Token contract privileged-role risk: System changes are executed through a governance process that uses spells (immutable change payloads) and a governance security delay enforced via the Pause proxy, reducing the ability to execute certain governanceapproved changes instantly. Converter mechanics and rounding risk: The conversion ratio is fixed at 1:24000, reducing conversion ambiguity and enabling predictable migration calculations (while preserving rounding effects where applicable). Allowance/signature validation risk: The token supports permit functionality and EIP-1271 contract signature validation, enabling standardised approval and signature verification flows for EOAs and contract wallets (reducing bespoke integration patterns). Project implementation-related risks Migration and upgrade execution risk: A converter contract is specified to support MKR-to-SKY conversion using fixedrate mechanics, providing an onchain primitive for migration that does not depend on market liquidity at the moment of conversion. Dependency and thirdparty service provider risk: The interface is described as non-custodial, and protocol interactions occur via onchain smart contracts rather than through the interface operator's custody, reducing exposure to interface operator custody risk (while not eliminating UI availability risk). Technology-related risks Smart contract vulnerability risk: A bug bounty program operated through ImmuneFi offers a structured mechanism for vulnerability disclosure and rewards. The Pause timelock adds a delay between scheduling and executing governance actions, allowing for possible intervention before execution. Governance-module technical risk: Governance actions follow a lifecycle of scheduling, execution after a timelock, and potential cancellation, ensuring preconditions for execution and operational control. Change payloads are implemented as immutable spell contracts, preventing post-approval changes to the executed code. Oracle and external data risk: Oracle values are enforced after a configured delay, with the OSM implementing a one-hour delay on collateral price updates to mitigate sudden deviations. A price freeze mechanism prevents malicious queued prices from becoming active. Additionally, oracle read interfaces require whitelisting for contract access, creating a control boundary around oracle value consumption. Bug bounty scope limitation risks: Scope and rules are defined via the ImmuneFi portal process referenced by the bug bounty programme, providing a structured intake and triage path (subject to scope constraints).

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