01. Date of notification to competent authority:
02. Statement Article 6(3):
03. Compliance Statement Article 6(6):
04. Warning Article 6(5)(a-c):
05. Utility Token Warning Article 6(5)(d):
06. No Deposit/Investor Guarantee Article 6(5)(e-f):
This summary should be read as an introduction to the crypto-asset white paper.
The prospective holder should base any decision to purchase this crypto-asset on the content of the crypto-asset white paper as a whole and not on the summary alone.
The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law.
This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.
Token Name: SDA (Sustainable Digital Assets)
Token Type: Utility Token (SPL Token-2022 on Solana blockchain)
Primary Utility: Access to renewable energy project data, governance voting rights, and platform services
Rights: Governance participation (1 token = 1 vote), access to sustainability metrics, and platform feature access
Obligations: Compliance with platform terms of service and applicable regulations
Procedures: Purchase through authorized channels, KYC/AML verification required, transfer via Solana blockchain
Conditions: Subject to regulatory approval, geographic restrictions may apply, minimum purchase thresholds
Goods/Services Provided:
Quality Standards: All data provided through ISO-certified processes, third-party verified ESG metrics
Quantity: Unlimited access to platform services for token holders
Transferability Restrictions: Tokens are freely transferable on Solana blockchain, subject to regulatory compliance and geographic restrictions. Some services may be region-specific.
Corporation Number: C 61288
Website: https://sdafintech.com
Group Structure: Sustainable Digital Assets Inc. is a standalone entity incorporated under the Nevis Business Corporation Ordinance (NBCO) and regulated by the Nevis Financial Services Regulatory Commission (NFSCR).
Subsidiaries: None
| Name | Function | Business Address |
|---|---|---|
| Mikko Rautiainen | Chief Technology Officer (CTO) | Helsinki, Finland |
| Antti Jussila | Chief Strategy Officer (CSO) | Vantaa, Finland |
| Robert Ramstedt | Chief Experience Officer (CXO) | Helsinki, Finland |
Mikko Rautiainen - Chief Technology Officer
Education: M.Sc. (Tech.) in Biomedical Engineering & Signal Analysis
Experience: A programming virtuoso and veteran entrepreneur combining a scientific career at the Ragnar Granit Institute, founding of Helsinki's Bitcoin-Corner in 2015, and more than two decades of delivering mission-critical software with five-nines reliability. Co-inventor on three international patents covering data-communication and short-range RF networking.
Antti Jussila - Chief Strategy Officer
Education: M.Sc. (Econ.)
Experience: Multi-decade background in the financial sector as capital manager and financial trader, with approximately 10 years of experience developing projects within the energy, mining and infrastructure sectors as CEO of a company founded in Colombia.
Robert Ramstedt - Chief Experience Officer
Experience: Visionary entrepreneur who pioneered Finland's plant-based fast-food movement with Vegemesta in 2007, notably receiving Finland's first commercial Bitcoin transaction. Later founded Reissujuna, transforming traditional rail travel into immersive adventures.
Summary Overview (as at 27 Oct 2025):
Fields B.2 through B.7 are not applicable. Issuer is the same as Offeror.
Part C applies only when third-party natural or legal persons provide information for the whitepaper that is different from the offeror or issuer.
Regulatory boundary. SDA is offered as an "other crypto-asset" (utility) under MiCA Title II. It does not reference an asset/currency (not ART/EMT) and does not grant financial rights (not a MiFID financial instrument). Any future regulated instrument would be separate and outside this document.
The management body members listed in Part A.12 are responsible for
project implementation:
Advisors:
None
Crypto-Asset Service Providers:
On-chain Actions (Non-Financial):
Delivery Mechanics:
Platform Development Roadmap (Phase 1 - Utility
Features):
The following roadmap describes the utility features to be developed
and deployed during the first 6-12 months:
Q1 2026: Platform Launch
Q2 2026: Feature Expansion
Q3-Q4 2026: Ecosystem Growth
Future Development Beyond Utility Token Scope:
Plans for the project exceed SDA utility token limits (as defined in
this white paper). In future phases we plan to have a security token
under securities legislation for further development of the project,
for details see Appendix E.
15% Operations expenses including:
85% Allocated to Project Development Fund including:
Note on Dependencies and Assumptions:
The project's success depends on several key factors:
Restrictions:
(1) Compliance with EU sanctions regimes
(2) KYC/AML verification requirements
(3) Jurisdictional restrictions where prohibited by
local law
Round 1: 15
September - 30 November 2025 | 30% discount | 0.70 USD per token
Round 2: 1 December - 28 December 2025 | 20%
discount | 0.80 USD per token
Round 3: 29
December 2025 - 11 January 2026 | 10% discount | 0.90 USD per
token
Public launch price: 1.00 USD per token (2
February 2026)
(1) Solana-compatible cryptocurrency wallet
with private key control,
(2) Basic
understanding of cryptocurrency wallet operations and security,
(3) Email address for communication and
verification purposes,
(4) Ability to
complete digital KYC/AML verification processes.
Technical
support will be available throughout the offer
period.
Breakdown:
• Legal & Administrative: EUR 2,792.51
•
Marketing & Promotion (fiat-paid): EUR 4,932.51
•
Marketing (BTC-funded, translated): EUR 1,369.61
• Web &
Digital Services: EUR 1,332.70
• Equipment & Supplies: EUR
346.95
• Preliminary listing fee (USD-settled, BTC-funded):
EUR 15,453.00
• Crypto conversion fees & slippage: EUR
32.35
Funding & Financial Position:
• Share capital: EUR 10,000.00
• Bitcoin-denominated
loan: EUR 23,000.00 (0.23200000 BTC @ EUR 99,138/BTC, dated 27
October 2025)
• Loan utilization: EUR 15,453.00 listing + EUR
1,369.61 marketing + EUR 32.35 fees = EUR 16,854.96 spent
•
Bitcoin reserve (unspent): 0.06198477 BTC (EUR 6,145.05
equivalent)
• Net loss for period: EUR 24,076.95 (after
crypto/FX remeasurement gain of EUR 2,182.68)
• Combined
closing liquidity: EUR 6,552.38 (cash EUR 407.33 + BTC reserve EUR
6,145.05)
For detailed financial statements, see
Annex C: Financial Statements.
Competent regulatory authorities: Nevis Financial Services Regulatory Commission (NFSRC) and relevant EU competent authorities as applicable
(1) Access to real-time renewable energy
project data and analytics through the SDA platform
(2) Governance participation rights in
project decisions
(3) Priority access
to future platform features and services related to Sustainable
Digital Assets
(1) Real-time renewable energy project data
and analytics
(2) Governance voting
rights for project decisions
(3)
Priority access to platform features
Additional functionalities may be added in subsequent phases subject
to governance approval.
Symbol: SDA
Standard: Solana
SPL Token-2022 (Advanced Token Extension)
Contract Address:
SDAmxfpgaGmtxTqcTcvr4yi2kBwEFxTLF2XU4oLFw4b
Blockchain Network: Solana Mainnet (Chain ID:
mainnet-beta)
Total Supply: 100 000 000
tokens (fixed)
Initial Price: 1.00 USD per
token
Supply Mechanism: Fixed supply cap with
no future inflation
Administrative Keys: Split-key cryptography (2 of 3
shares needed)
Transaction Fees: <0.001
USD
Par Value: No par value
Redemption Rights: No redemption rights against the
issuer
Stabilization Mechanism: None
Applicable Laws: Activities will be conducted in
accordance with the national laws and regulations of the country of
operation, including applicable energy and environmental
regulations, as well as applicable Union or national legal acts
should such projects be carried out within EU Member States in the
future.
Important notice: SDA tokens in Phase 1 confer only the utility rights described in G.1. Any future rights or benefits are hypothetical and subject to obtaining appropriate regulatory approvals and governance approval. See Appendix E for information about potential future phases, which may never be implemented.
For blockchain energy consumption calculations and technical standards, see Appendix G - Technical Calculation Standards.
Blockchain:
Consensus mechanism: Proof-of-Stake with Proof-of-History
Performance characteristics:
The SDA token ecosystem utilizes the following smart contract components:
Governance model: Multi-signature governance with time lock controls, on-chain voting
Upgrade process: Direct conversion or airdrop of security token
Emergency procedures: Halt trading and freeze funds, resolve outstanding emergency
Smart contract audits: Dual independent audits plus formal verification tooling
Operational security:
The token ecosystem depends on the following external components:
Access platform services and utilities
within the SDA ecosystem
Engage in
governance and decision-making processes within the ecosystem
Execute secure and efficient transactions
leveraging Solana's high throughput and low transaction costs
The token is fully digital, transferable, and storable
electronically using Solana's distributed ledger
technology.
Investment in crypto-assets carries significant risks. Potential purchasers should carefully consider the following risk factors before making any investment decision.
Note: The risks listed below apply to Phase 1 (Utility Token). Risks related to Phase 2 and Phase 3 (hypothetical future phases involving physical infrastructure and energy projects) are listed in Appendix J: Phase 2 & 3 Risk Factors (see end of document).
SDA is a utility token. Purchasers should have NO expectation of profit from holding SDA tokens.
The offer to the public of SDA tokens involves several significant
risks that prospective purchasers should carefully consider:
Smart Contract Vulnerabilities: Bugs
or exploits in smart contracts may lead to fund loss or manipulation
of token functionality. The immutable nature of blockchain
deployments means that critical vulnerabilities could result in
permanent loss of funds or compromise of the token ecosystem.
Private Key/Wallet Compromise: Theft
or loss of private keys can lead to significant and irreversible
token losses for individual token holders. Unlike traditional
financial systems, blockchain transactions cannot be reversed, and
there is no central authority that can restore access to lost or
stolen tokens.
Solana Network Dependencies: Network outages or
technical failures on the Solana blockchain could temporarily halt
token operations, preventing transfers, trades, or access to token
functionality. Historical network congestion and outages on Solana
have demonstrated this risk.
Phishing and Social Engineering: Deceptive
practices targeting token holders could result in unauthorized
access or token loss. Sophisticated phishing campaigns specifically
target cryptocurrency holders through fake websites, fraudulent
communications, and social engineering tactics.
Regulatory Uncertainty: The evolving regulatory
landscape for cryptocurrency offerings may impact the token's legal
status, tradability, or operational framework across different
jurisdictions.
Market Acceptance Risk: There is no guarantee that
the SDA token will achieve widespread market acceptance or maintain
liquidity on trading platforms.
As the issuer and offeror are the same entity (Sustainable Digital
Assets Inc.), the following issuer-related risks apply:
Token Price Volatility: Significant
fluctuations in token price due to cryptocurrency market dynamics
and speculation. The volatile nature of cryptocurrency markets means
that the value of SDA tokens may experience substantial price swings
that are independent of the underlying project fundamentals or
issuer performance.
Liquidity and Market Access Risks: Insufficient
market liquidity or exchange delisting could severely impact token
trading and token holder confidence. Despite planned listings on
multiple exchanges, there is no guarantee of sustained liquidity or
continued exchange support.
AML/KYC Compliance Risks: Compliance failures may
result in financial penalties, operational restrictions, or
regulatory enforcement actions. The evolving nature of
cryptocurrency regulation requires continuous adaptation of
compliance procedures.
Operational Risk: As a newly established entity
(June 2025), the issuer has limited operational history and may face
challenges in scaling operations, managing growth, or adapting to
market conditions.
Key Person Dependency: The issuer's success depends
significantly on its management team and key personnel. Loss of
critical team members could adversely affect project execution and
token value.
Financial Sustainability and Loan Repayment Risk:
The issuer's ability to continue operations depends on successful
fundraising and prudent financial management. As at 27 October 2025,
the issuer has a Bitcoin-denominated loan of €23,000.00 (0.232 BTC).
This loan creates a repayment obligation that must be satisfied
regardless of the issuer's operational performance or token sale
success. The loan is denominated in Bitcoin, which exposes the
issuer to cryptocurrency price volatility—if Bitcoin appreciates
significantly against EUR, the effective EUR value of the repayment
obligation will increase. Failure to meet loan repayment obligations
could result in default, legal action, or insolvency. Market
downturns, failed fundraising, or operational challenges could
impact the issuer's ability to service this debt and maintain
viability.
Risks specifically associated with the SDA token as a crypto-asset:
Governance Centralization Concerns: Excessive
centralization of decision-making could reduce token holder
confidence and limit democratic participation. During the initial
phases, governance control remains with the founding team, which may
not align with decentralized principles expected by token holders.
Token Utility Limitations: The value
proposition of SDA tokens depends on the utility features promised
in the whitepaper. If these features are not fully implemented,
delayed, or fail to achieve user adoption, the token's utility and
value may be significantly diminished.
Supply Concentration Risk: A significant portion of
tokens (60,000,000 out of 100,000,000) are retained by the issuer.
This concentration could lead to price manipulation concerns or
create selling pressure if the issuer liquidates large holdings.
Technological Obsolescence: The
token's design and functionality may become outdated as blockchain
technology evolves, potentially reducing its competitiveness and
utility compared to newer crypto-assets.
Interoperability Limitations: The token is built on
Solana, which may limit interoperability with other blockchain
ecosystems and restrict its utility in cross-chain applications.
Complete Loss of Value: Purchasers may
lose their entire investment. The token may become worthless if the
project fails, regulatory actions are taken, or market conditions
deteriorate. There is no guarantee of maintaining any residual
value.
Risks associated with the execution and delivery of the Phase 1
digital platform, token distribution infrastructure, and ecosystem
development:
Platform Development Delays: Technical
challenges, resource constraints, or unforeseen complications may
delay the launch or enhancement of planned platform features
including staking mechanisms, governance systems, and utility
functions. Delays in delivering promised platform functionality
could reduce token utility and negatively impact token holder
confidence and market value.
Third-Party Service Provider Dependencies: The
platform relies on multiple third-party service providers including
blockchain infrastructure providers, exchange platforms, wallet
services, and payment processors. Failure, discontinuation, or poor
performance of these services could disrupt token operations, limit
accessibility, or compromise user experience.
User Adoption and Engagement Challenges: The
platform may fail to achieve sufficient user adoption, engagement,
or transaction volume to sustain ecosystem growth. Low adoption
rates could reduce platform utility, limit network effects, and
negatively impact token value and liquidity.
Scalability and Performance Issues: As the user
base grows, the platform may experience performance degradation,
system outages, or inability to scale efficiently. Technical
limitations in handling increased transaction volumes or user
concurrency could compromise service quality and user satisfaction.
Integration and Interoperability Failures:
Challenges in integrating with external systems, wallets, exchanges,
or blockchain protocols could limit platform functionality and token
accessibility. Poor interoperability may restrict the token's
utility and limit its acceptance across the broader cryptocurrency
ecosystem.
Development Team and Key Personnel Risks: Loss of
key technical personnel, inadequate development resources, or
insufficient expertise in blockchain development and platform
architecture could compromise project execution quality and
timelines. As a newly established entity, the issuer may face
challenges in attracting and retaining top technical talent.
Governance Implementation Challenges: The
implementation of decentralized governance mechanisms may face
technical difficulties, low participation rates, or governance
attacks. Poorly designed or executed governance systems could lead
to contentious decisions, community fragmentation, or concentration
of voting power.
Regulatory Compliance System Failures: The
platform's KYC/AML systems, transaction monitoring, and compliance
infrastructure may fail to meet evolving regulatory requirements.
Compliance system failures could result in regulatory sanctions,
operational restrictions, or loss of exchange listings.
Risks associated with the blockchain technology, distributed ledger
infrastructure, and digital systems supporting the SDA token:
Blockchain Network Dependency & Downtime: The
SDA token operates on the Solana blockchain. Network outages,
congestion, or performance degradation on Solana can halt all SDA
transactions, impact token accessibility, and disrupt project
operations dependent on blockchain functionality. Solana has
experienced several network outages in its history, demonstrating
this is not merely a theoretical risk.
Smart Contract Vulnerabilities & Exploits:
Bugs, vulnerabilities, or design flaws in smart contracts governing
token distribution, staking, or other core functions may be
exploited by malicious actors, potentially leading to significant
token losses, fund drainage, or manipulation of token economics. The
cryptocurrency industry has witnessed numerous high-profile smart
contract exploits resulting in billions of dollars in losses.
Blockchain Platform Obsolescence: Rapid evolution
in blockchain technology could render the Solana platform less
competitive or technologically outdated, potentially impacting token
utility, transaction costs, and ecosystem attractiveness. Newer
blockchains with superior performance characteristics may emerge and
attract developers and users away from Solana.
Cross-Chain Bridge & Interoperability Risks: If
SDA tokens utilize cross-chain bridges for interoperability with
other blockchains, vulnerabilities in bridge protocols represent
significant security risks. Bridge exploits have historically
resulted in major fund losses across the cryptocurrency ecosystem,
with attacks on bridges accounting for some of the largest
cryptocurrency thefts.
Consensus Mechanism Vulnerabilities: Weaknesses in
the Solana Proof-of-Stake consensus mechanism, validator
centralization, or coordinated validator attacks could compromise
network security and token integrity. Excessive centralization of
validator power could enable censorship or manipulation of
transactions.
Protocol Upgrades & Hard Forks: Mandatory
protocol upgrades, contentious hard forks, or chain splits in the
underlying Solana blockchain could create uncertainty,
fragmentation, or incompatibility issues for SDA tokens and holders.
Token holders may need to take specific actions during upgrades or
risk loss of access to their tokens.
Wallet & Private Key Security: The security of
SDA tokens fundamentally depends on holders maintaining secure
custody of private keys. Loss, theft, or compromise of private keys
results in irreversible token loss with no recovery mechanism
available. This risk is particularly acute given the irreversible
nature of blockchain transactions.
Scalability & Transaction Cost Volatility:
Network congestion or increased usage could lead to higher
transaction fees or slower confirmation times, potentially impacting
token usability and holder experience. While Solana is designed for
high throughput, extreme network stress could still impact
performance.
The following mitigation measures have been implemented or are
planned to address the risks identified in Parts I.1-I.5, with
primary focus on technology-related risks:
Technology Risk Mitigations:
Smart Contract Security: Comprehensive
third-party security audits by reputable firms (CertiK, Trail of
Bits, OpenZeppelin) will be conducted before deployment; formal
verification methods for critical contract logic; establishment of
bug bounty programs to incentivize responsible disclosure;
implementation of emergency pause mechanisms; regular code reviews
and security assessments; maintenance of comprehensive cybersecurity
insurance coverage for smart contract risks.
Blockchain Infrastructure Resilience: Continuous
monitoring of Solana network health and validator performance;
maintaining relationships with validator operators; active
participation in Solana governance and security initiatives;
development of contingency plans for network outages; exploration of
multi-chain architecture for future implementation; implementation
of off-chain operational capabilities where feasible; maintenance of
technical capability to respond to protocol upgrades or forks.
Wallet & Key Management Security: Comprehensive
user education programs on wallet security best practices;
recommendation of hardware wallet usage for significant holdings;
promotion of multi-signature wallet adoption; provision of detailed
guidance on secure backup procedures; partnerships with reputable
custody providers for institutional investors; multi-signature
wallet requirements for treasury management; hardware security
module (HSM) usage for key management; maintenance of insurance
options for qualified investors.
Cross-Chain Security: Limitation of reliance on
bridge infrastructure; utilization only of thoroughly audited and
battle-tested bridge solutions; implementation of bridge transaction
limits; maintenance of insurance for bridge-held funds; continuous
monitoring of bridge security; development of native multi-chain
presence where possible.
Validator & Consensus Security: Monitoring of
validator decentralization metrics; diversification of staking
across multiple validators; participation in network governance to
promote decentralization; maintenance of awareness regarding
consensus-level vulnerabilities; support for Solana Foundation
security initiatives.
Protocol Upgrade Management: Establishment of clear
fork policy and communication strategy; active participation in
Solana governance; provision of timely guidance to token holders
during upgrade events; testing of smart contracts against proposed
upgrades.
Additional Risk Mitigations:
Market & Liquidity: Strategic
liquidity provision through CEX liquidity; partnerships with
professional market makers; pursuit of listings on reputable
cryptocurrency exchanges; transparent tokenomics communication;
gradual token vesting schedules to prevent supply shocks; clear
communication strategies during market volatility.
Regulatory Compliance: Engagement of specialized
cryptocurrency and securities legal counsel; implementation of
comprehensive KYC/AML procedures using industry-leading providers;
regular compliance audits; dedicated compliance officer and team;
active monitoring of regulatory developments across jurisdictions.
Platform Implementation & Development:
Engagement of experienced blockchain developers and platform
architects with proven track records; implementation of agile
development methodologies with iterative testing; establishment of
development contingency buffers; rigorous third-party code reviews
and security audits; comprehensive testing protocols including unit
testing, integration testing, and user acceptance testing;
maintenance of clear development roadmaps with milestone tracking;
establishment of service level agreements (SLAs) with critical
third-party providers; development of platform redundancy and
failover capabilities; regular user feedback collection and platform
optimization; dedicated technical support team for user assistance.
Financial Management: Phased funding
approach with milestone-based capital release; maintenance of
operational reserves (6-12 months); diversification of funding
sources; treasury diversification across multiple custodians;
regular financial audits by reputable accounting firms.
Governance & Transparency: Phased
decentralization roadmap with on-chain voting mechanisms; regular
transparency reports and project updates; clear decision-making
processes; active community engagement programs; progressive
transfer of control to token holder community.
Crisis Management: Detailed crisis management plans
covering technical, financial, and operational scenarios; defined
crisis response teams and communication protocols; business
continuity and disaster recovery plans; cybersecurity incident
response procedures.
Insurance Coverage: Professional indemnity
insurance; directors and officers (D&O) liability insurance;
cyber insurance covering smart contract risks and data breaches;
comprehensive property and business interruption insurance;
specialty cryptocurrency custody insurance where available.
Node operation: 100 W × 8,760 h = 876 kWh/year
Trading/support infrastructure: ≈ 52,000 kWh/year
Total project-level consumption: ≈ 52,876 kWh/year (< 500,000 kWh
threshold)
Energy per transaction: 1,000,000 transactions annually → 0.053 kWh
per transaction
Proportionality Note:
Disclosure is provided at project level, not network level, due to
low energy consumption.
2. Carbon Footprint
Direct emissions: 52,876 kWh × 0.5 kg CO₂/kWh ≈ 26.4 tCO₂e/year
Scope: Node operation and trading infrastructure only
Methodology: Standard conversion factors (kWh → CO₂e)
3. Consensus Mechanism Sustainability
Blockchain: Solana (Proof-of-Stake)
Energy efficiency: Significantly more efficient than Proof-of-Work
chains
Incremental impact: SDA Token operations add minimal environmental
impact
4. Mitigation Measures
Green hosting: Preference for renewable-energy-powered data
centers
Energy monitoring: Continuous tracking and optimization
Carbon accounting: Periodic reporting of emissions
Third-party verification: Periodic assurance by accredited ESG
auditor
5. Governance Pillar
On-chain voting, transparent smart contracts, and regular
reporting
Compliance with relevant MiCA regulations
Implementation Notes:
Disclosure focuses only on SDA Token operations, under 500,000
kWh/year.
Future changes in token activity will trigger updated disclosures as
required by Commission Delegated Regulation (EU)
2023/1114.
⚠️ YOU MAY LOSE ALL OR PART OF YOUR MONEY
Crypto-assets are high-risk investments. The value of crypto-assets
can fluctuate widely and you could lose your entire investment.
⚠️ NO DEPOSIT PROTECTION
Crypto-assets are not covered by deposit protection schemes. If
something goes wrong with the crypto-asset or the service provider,
you will not be protected by any compensation scheme.
⚠️ NO GUARANTEES
No competent authority has approved or guaranteed the accuracy or
completeness of this white paper. The crypto-asset described in this
white paper is not guaranteed by any competent authority.
⚠️ LIQUIDITY RISK
You may not be able to exchange your crypto-assets back into money
immediately. There is no guarantee that there will be a liquid market
for trading the crypto-assets.
⚠️ TAX OBLIGATIONS
You may have to pay taxes on any profits you make from crypto-assets.
Tax treatment depends on your individual circumstances and may change
in the future.
⚠️ REGULATORY RISK
The regulatory treatment of crypto-assets is developing and may change
in ways that could adversely affect the value or utility of your
crypto-assets.
For use with any marketing materials:
"This is a marketing communication. This document does not constitute investment advice, investment research, or a recommendation to buy, sell or hold any crypto-assets. This material is for informational purposes only and is not intended as an offer or solicitation for the purchase or sale of any crypto-asset. Please read the full white paper before making any investment decision. Past performance is not indicative of future results. Crypto-assets are volatile and high-risk investments."
You have the right to withdraw from your purchase of SDA tokens within 14 calendar days of purchase confirmation without giving any reason.
Withdrawal period: 14 calendar days from the date of purchase confirmation email
No penalty: You will receive a full refund with no penalty or additional charges
Refund method: Refunds will be processed using the same payment method used for the original purchase
To withdraw from your purchase, you must inform us of your decision by sending a clear statement to:
Processing time: Refunds will be processed within 5 working days of receiving your withdrawal request
Token return: You must return or destroy any tokens received (instructions will be provided)
Exceptions: Withdrawal rights may not apply if tokens have been admitted to trading on a regulated exchange before the end of the withdrawal period
For more information about your withdrawal rights or assistance with the withdrawal process, please contact our customer support team at support@sdafintech.com.
Legal opinion on token classification and regulatory compliance: https://sdafintech.com/documentation/audit-legal-opinion
Platform: Solana SPL Token-2022 standard
DTIF Registration: https://sdafintech.com/documentation/audit-dtif-registration
Smart contract addresses: SDAmxfpgaGmtxTqcTcvr4yi2kBwEFxTLF2XU4oLFw4b
Period: 1 Jun 2025 – 27 Oct 2025
Presentation currency: EUR (BTC disclosed separately)
BTC display rate used for white paper presentation: BTCEUR 99,138
| ASSETS | EUR |
|---|---|
| Cash and bank balance | 407.33 |
| Bitcoin reserve (EUR equivalent*) | 6,145.05 |
| Intangible assets | 2,023.72 |
| Equipment & supplies | 346.95 |
| TOTAL ASSETS | 8,923.05 |
*BTC on hand: 0.06198477 BTC. EUR equivalent uses BTCEUR 99,138 for presentation.
| EQUITY & LIABILITIES | EUR |
|---|---|
| Share capital | 10,000.00 |
| Retained earnings (loss) | (24,076.95) |
| Loan payable — BTC-funded | 23,000.00 |
| TOTAL EQUITY & LIABILITIES | 8,923.05 |
| CATEGORY | EUR |
|---|---|
| Revenue | 0.00 |
| Legal & Administrative | 2,792.51 |
| Marketing & Promotion (fiat-paid) | 4,932.51 |
| Web & Digital Services | 1,332.70 |
| Equipment & Supplies | 346.95 |
| Preliminary listing fee (USD-settled, BTC-funded) | 15,453.00 |
| Marketing (BTC-funded, translated) | 1,369.61 |
| Crypto conversion fees & slippage | 32.35 |
| Subtotal expenses | 26,259.63 |
| Crypto/FX remeasurement & timing variance (gain) | (2,182.68) |
| NET LOSS FOR THE PERIOD | (24,076.95) |
| DESCRIPTION | EUR |
|---|---|
| Net cash used in operating activities | (7,034.00) |
| Net cash from financing (share capital) | 10,000.00 |
| Payments for capitalized assets | (2,558.67) |
| CLOSING CASH BALANCE (27 OCT 2025) | 407.33 |
BTC movements (non-cash disclosure):
| INFLOWS | EUR |
|---|---|
| Share capital received | +10,000.00 |
| BTC loan received (0.23200000 BTC) | +23,000.00 |
| Total inflows | +33,000.00 |
| OUTFLOWS | EUR |
|---|---|
| Operating cash outflows (fiat) | –7,034.00 |
| Capitalized asset purchases (fiat) | –2,558.67 |
| Listing fee settled in BTC (27 Oct; €15,393.75 + €87.69) | –15,481.44 |
| BTC-funded marketing (translated) | –1,369.61 |
| BTC on-chain/conv. fees & slippage | –32.35 |
| Total outflows | –26,476.07 |
| NET CHANGE (transaction-date basis) | +6,523.93 |
| Translation adjustment to closing presentation rate* | +28.45 |
| ENDING CASH & CRYPTO EQUIVALENTS | 6,552.38 |
Breakdown at 27 Oct 2025
| Bank cash | 407.33 |
| BTC reserve: 0.06198477 BTC × 99,138 | 6,145.05 |
| Combined closing liquidity (display only) | 6,552.38 |
*Aligns BTC movements (booked at transaction-date rates) to the 27 Oct 2025 presentation of remaining BTC at BTCEUR 99,138. Non-cash bridge; not an extra expense.
Basis of preparation
Management-prepared, unaudited financial information for MiCA Title II disclosure. Presentation currency is EUR. BTC is disclosed separately and not commingled with "Cash and bank balance."
BTC measurement
BTC loan
CEX: Centralized Exchange
COD: Commercial Operation Date
EPC: Engineering, Procurement, and Construction
EBITDA: Earnings Before Interest, Taxes, Depreciation, and Amortization
FCF: Free Cash Flow
IRR: Internal Rate of Return
KYC/AML: Know Your Customer / Anti-Money Laundering
LTV: Loan-to-Value ratio
MiCA: Markets in Crypto-Assets Regulation (EU) 2023/1114
PPA: Power Purchase Agreement
RWA: Real World Assets
SPL: Solana Program Library
TPS: Transactions Per Second
Informational only: The following roadmap elements are conceptual and not part of this offer. They confer no rights on SDA holders. Any future regulated offering, if any, would have separate documentation and approvals.
Detailed Implementation Roadmap and Timeline:
Our development roadmap outlines detailed progression through strategic milestones, clearly defined phases, and measurable goals, guiding us towards building a decentralized renewable energy ecosystem powered by the SDA Token.
Up to 40 million tokens (up to 40% of supply) offered to public
Activated once 100 million USD realized capitalization is reached
Triggered once first physical project reaches commercial operation
| Phase | Primary Metric | Target Value | Timeline |
|---|---|---|---|
| Phase 1 | Market Capitalization | USD 100 million | Q4 2026 (estimated) |
| Phase 2 | Generation Capacity | 250 GWh annually | End-2027 |
| Phase 3 | Portfolio Expansion | 500 GWh annually | 2030 |
Future development (informative, non-binding). The issuer may in the future consider launching one or more regulated instruments related to real-world assets. Any such initiative would be separate from this utility token, optional for participants, and subject to regulatory approvals.
If market conditions and regulatory frameworks permit, the company may consider:
Important: These considerations are informational only and do not constitute commitments or obligations. For hypothetical project examples that may be considered in the future, see Appendix F: Hypothetical Projects to be Constructed in Phase 2.
Note: The following infrastructure projects are hypothetical examples that may be constructed in Phase 2 after regulatory and market milestones are achieved. Actual projects will be determined based on market conditions, regulatory approvals, and token holder governance.
Scope: Energy consumption attributable to SDA token operations on Solana blockchain
Calculation Method:
Token Energy Consumption = (Network Energy Consumption ÷ Total
Transactions) × SDA Transactions
Network Energy = Validator Energy Consumption × Number of
Validators
Per Transaction Energy = Network Energy ÷ Annual Transaction Volume
Data Sources:
Benchmarking:
| Network | Energy per Transaction | Relative Efficiency |
|---|---|---|
| Bitcoin | ~710 kWh | 1x (baseline) |
| Ethereum | ~60 kWh | 12x more efficient |
| Solana | ~0.00051 kWh | 1,390x more efficient |
Asset Backing Ratio:
Asset Backing Ratio = Fair Value of Renewable Assets ÷ (Outstanding
Tokens × Token Price)
Minimum Backing Target = 80% (Phase 2+)
Asset Revaluation Frequency = Quarterly (independent assessment)
Liquidity Reserve Calculation:
Liquidity Reserve = Max(5% of Market Cap, 6 Months Operating
Expenses)
Reserve Assets = Stablecoins (50%) + High-grade bonds (30%) + Cash
(20%)
Mandatory Energy Consumption Disclosure:
Annual Energy Consumption = Operational Energy + Blockchain Energy +
Infrastructure Energy
Operational Energy = Office facilities + Data centers + Direct
operations
Blockchain Energy = SDA transaction energy × Annual transaction
volume
Infrastructure Energy = Proportional renewable facility
construction/maintenance energy
Revenue Recognition Standards: IFRS 15 - Revenue from Contracts with Customers
Distribution Calculation Methodology:
Gross Revenue = Energy Sales + Capacity Payments + Ancillary
Services + Government Subsidies
Distributable Cash Flow = Net Operating Income - Debt Service -
Capital Reserves
Token Holder Distribution = Distributable Cash Flow Payments to be
decided by token holders in annual vote
Per Token Amount = Token Holder Distribution ÷ Outstanding Tokens at
Record Date
Distribution Frequency: Quarterly, with annual reconciliation
Minimum Distribution Threshold: USD 0.01 per token per quarter
ESG Data Verification:
Financial Data Verification:
Data Accuracy Standards:
Data Retention and Accessibility:
Important Notice: The risks listed in this appendix relate to hypothetical Phase 2 and Phase 3 activities (physical infrastructure development and energy operations). These phases are subject to regulatory approval, market conditions, and are NOT part of the current Phase 1 utility token offering described in this white paper.
Likelihood: Low | Impact: High | Rating: 5/10
Token sales may be insufficient to cover construction and operational costs of planned renewable energy projects.
Mitigation: Use phased funding rounds, diversify funding sources, and maintain adequate reserve capital.
Likelihood: Medium | Impact: Low | Rating: 4/10
Extensive EU regulatory compliance requirements may affect operational flexibility and increase costs.
Mitigation: Engage experienced regulatory advisors, automate compliance processes, and dedicate appropriate resources.
Likelihood: High | Impact: Low-Medium | Rating: 3-5/10
Fluctuations in wholesale energy prices and cryptocurrency market conditions impact project profitability.
Mitigation: Use hedge contracts, diversify projects across markets, and structure tokenomics for stability.
Likelihood: High | Impact: Low | Rating: 5/10
Contractor issues, supply chain disruptions, or unforeseen events may cause delays and increased project costs.
Mitigation: Enforce strict contracts, maintain robust project oversight, and allocate adequate contingency budgets.
Likelihood: Medium | Impact: Low-Medium | Rating: 3-4/10
Changes in government policies, subsidies, or energy regulations may affect project viability and returns.
Mitigation: Monitor policy landscapes actively, diversify project portfolio across jurisdictions, and maintain regulatory flexibility.
Likelihood: Medium | Impact: Medium | Rating: 4/10
Renewable energy technology underperformance, maintenance issues, or operational failures may reduce project output.
Mitigation: Select proven technologies, secure comprehensive warranties, and implement preventative maintenance schedules.
Likelihood: Low | Impact: Medium | Rating: 4/10
Severe weather events or natural disasters could damage renewable energy infrastructure and halt operations.
Mitigation: Design climate-resilient infrastructure, secure comprehensive insurance coverage, and develop disaster recovery plans.
Likelihood: Medium | Impact: Medium | Rating: 5/10
Potential lawsuits from competitors, partners, token holders, or regulators may cause financial strain or operational delays.
Mitigation: Maintain clear contractual relationships, perform regular legal risk assessments, and retain qualified advisory counsel.
Likelihood: Low | Impact: Medium | Rating: 5/10
Local community resistance could delay project approvals, construction timelines, or ongoing operations.
Mitigation: Initiate early community outreach, demonstrate clear local benefits, and maintain active stakeholder engagement channels.
Likelihood: Low | Impact: Low | Rating: 2/10
Supply chain ethics lapses or poor labor/environmental standards could harm reputation and cause project delays.
Mitigation: Enforce comprehensive supplier ESG codes, require third-party sustainability audits, and publish annual ESG disclosure reports.
Likelihood: High | Impact: Medium | Rating: 6/10
Renewable energy projects may experience significant delays or cost escalations due to contractor performance issues, unforeseen site conditions, permitting delays, or supply chain disruptions, directly impacting project timelines and profitability. Construction risks are particularly pronounced in renewable energy sectors due to weather dependencies, specialized equipment requirements, and complex regulatory environments.
Mitigation: Enforce strict contracts with performance guarantees, maintain robust project oversight with experienced project managers, allocate adequate contingency budgets (15-20% of project costs), and diversify contractor relationships to reduce dependency risks.
Likelihood: Medium | Impact: Medium | Rating: 5/10
Expansion of project requirements or changes to technical specifications during implementation can lead to timeline extensions, increased costs, and resource reallocation challenges. Evolving regulatory standards or technology improvements may necessitate costly mid-project modifications.
Mitigation: Establish rigorous change control processes, conduct comprehensive upfront planning and specifications development, build flexibility into project designs, and maintain clear stakeholder communication on scope boundaries.
Likelihood: Low | Impact: High | Rating: 5/10
Insufficient project management expertise or resources could result in poor coordination, missed milestones, budget overruns, and suboptimal project outcomes. As a newly established entity, the issuer may lack the organizational depth and experience required for complex multi-site renewable energy deployments.
Mitigation: Engage experienced renewable energy project managers with proven track records, invest in project management tools and methodologies, partner with established EPC (Engineering, Procurement, Construction) contractors, and build internal project management capabilities through training and hiring.
Likelihood: Medium | Impact: Medium | Rating: 5/10
Delays in obtaining necessary permits, licenses, and regulatory approvals from local, regional, or national authorities can significantly postpone project commencement and increase holding costs. Renewable energy projects often face complex multi-jurisdictional permitting requirements that can extend timelines by months or years.
Mitigation: Engage local permitting consultants with established relationships, initiate permitting processes early in project development, maintain proactive communication with regulatory authorities, and factor extended permitting timelines into project schedules.
Likelihood: Medium | Impact: Low | Rating: 4/10
Shortage of qualified personnel, specialized equipment, or technical expertise in renewable energy sectors may constrain project execution capacity and quality. Global demand for renewable energy installation capacity may create bottlenecks in accessing skilled labor and specialized equipment.
Mitigation: Establish early relationships with equipment suppliers and secure long-lead items in advance, develop partnerships with specialized subcontractors, invest in workforce training programs, and maintain flexible project schedules to accommodate resource availability.
Likelihood: Medium | Impact: Medium | Rating: 4/10
Poor coordination among multiple stakeholders including contractors, suppliers, local authorities, grid operators, and community representatives can lead to conflicts, delays, and suboptimal project outcomes.
Mitigation: Implement robust stakeholder engagement programs, establish clear communication protocols and escalation procedures, conduct regular coordination meetings with all key parties, and designate dedicated stakeholder liaison personnel.
Likelihood: Low | Impact: Medium | Rating: 4/10
Failure to meet technical specifications or quality standards during construction and installation could result in underperforming assets, warranty voidances, and costly remediation work.
Mitigation: Implement comprehensive quality assurance and quality control programs, conduct third-party inspections at critical project milestones, enforce strict adherence to technical specifications, and maintain detailed documentation of all installation procedures.
Likelihood: Low | Impact: Low | Rating: 3/10
Challenges in integrating completed renewable energy projects with grid infrastructure, energy markets, or operational management systems could delay revenue generation and impact projected returns.
Mitigation: Conduct thorough pre-commissioning testing and system integration validation, coordinate closely with grid operators and offtakers throughout project development, develop comprehensive commissioning plans, and allocate adequate time for system optimization and troubleshooting.
The following information describes hypothetical rights that may be associated with SDA tokens in future phases, subject to obtaining appropriate regulatory approvals and licenses. These are NOT current rights and there is no guarantee that such approvals will be obtained or that these rights will ever be implemented.
If regulatory approvals are obtained, tokens may acquire additional rights:
If governance rights are implemented, token holders may vote on:
Regulatory Requirements: Implementation of any of these rights requires:
This index maps each Annex I requirement to the corresponding section in this white paper:
| Annex I Item | Description | Section Reference | Page/Para |
|---|---|---|---|
| A | Offeror information | Part A | A.1-A.5 |
| A.1 | Corporate name and office | Part A.1 | A.1 |
| A.2 | Contact information | Part A.2 | A.2 |
| A.3 | LEI | Part A.3 | A.3 |
| A.4 | Group structure | Part A.4 | A.4 |
| A.5 | Auditors | Part A.5 | A.5 |
| B | Issuer information | Part B | B.1 |
| D | Project information | Part D | D.1-D.3 |
| E | Offer details | Part E | E.1-E.5 |
| F | Token description | Part F | F.1-F.3 |
| G | Rights and obligations | Part G | G.1-G.5 |
| H | Technology information | Part H | H.1-H.6 |
| I | Risk factors | Part I | I.1-I.3 |
| J | Sustainability indicators | Part J | J.1-J.4 |
Version: 1.0
Date: 27 October 2025
Language: English (EN)
This document has been prepared in accordance with Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA). For the most current version and any updates, please visit https://sdafintech.com/legal/mica/