Crypto-asset white paper
ATTO
Information about the ATTO digital-cash network
Contents
Table of contents
- 00–03General information and statements
- Part APart A — The offeror or person seeking admission to trading
- Part BPart B — Issuer information, if a separate issuer is selected
- Part CPart C — Trading-platform operator or other preparer
- Part DPart D — The crypto-asset project
- Part EPart E — Admission to trading
- Part FPart F — The crypto-asset
- Part GPart G — Rights and obligations attached to the crypto-asset
- Part HPart H — Underlying technology
- Part IPart I — Risks
- Part JPart J — Sustainability and environmental impacts
- Part SSustainability disclosure identifiers
General information
General information and statements
| No. | Field | Content |
|---|---|---|
| 00 | Table of content | Yes — a table of contents is provided. |
| 01 | Date of notification | 3 August 2026 |
| 02 | Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114 | This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The person seeking admission to trading of the crypto-asset is solely responsible for the content of this crypto-asset white paper. |
| 03 | Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114 | This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 and, to the best of the knowledge of the management body, the information presented in this 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 | Not applicable |
| 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 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. |
| 08 | Characteristics of the crypto-asset | ATTO is intended as digital cash for transfer and payment use. It does not grant issuer-supplied gated access: payment functionality and Open Representative Voting are protocol capabilities, not token utility. |
| 09 | Further information about utility tokens | Not applicable. Field 05 is false on the currently available facts: ATTO does not grant access to goods or services supplied by Atto B.V. |
| 10 | Key information about the offer to the public or admission to trading | ATTO is a digital-cash crypto-asset issued by Atto B.V. Atto B.V. is the person seeking admission to trading for the activities addressed in this white paper. This paper does not offer ATTO, collect subscription proceeds, or establish current venue access, formal admission or liquidity. Platform names and pairs are listed in E.33; access and costs are qualified in E.35 and E.36. |
Part A
Part A — The offeror or person seeking admission to trading
| No. | Field | Content |
|---|---|---|
| A.1 | Name | Atto B.V. |
| A.2 | Legal form | Not applicable — a current LEI is reported in A.6. |
| A.3 | Registered address | Not applicable — a current LEI is reported in A.6. |
| A.3 | Country | Not applicable — a current LEI is reported in A.6. |
| A.3 | Sub-division | Not applicable — a current LEI is reported in A.6. |
| A.4 | Head office | Not applicable — a current LEI is reported in A.6. |
| A.4 | Country | Not applicable — a current LEI is reported in A.6. |
| A.4 | Sub-division | Not applicable — a current LEI is reported in A.6. |
| A.5 | Registration date | 2024-12-12 |
| A.6 | Legal entity identifier | 6488ACA2HX03M49K4086 |
| A.7 | Another identifier required pursuant to applicable national law | N/A — no additional national identifier is reported. |
| A.8 | Contact telephone number | +31 85 505 5643 |
| A.9 | E-mail address | contact@atto.cash |
| A.10 | Response time (days) | within 10 calendar days |
| A.11 | Parent company | N/A — no parent-company identifier is separately reported under this item; A.14 records Rotilho B.V.’s business activity. |
| A.12 | Identity | Rotilho B.V. |
| A.12 | Business address | Winthontlaan 200, 3526 KV Utrecht, Netherlands |
| A.12 | Function | Sole legal-person director of Atto B.V.; solely and independently authorised. |
| A.13 | Business activity | Atto B.V. reports activity focused on developing, maintaining and operationally managing the cryptocurrency network. |
| A.14 | Parent company business activity | Rotilho B.V. carries out financial holding activities, including ownership of Atto B.V.; its principal market is the Netherlands. |
| A.15 | Newly established | No — Atto B.V. was not established for the preceding three years at the reference date. Its incorporation date is 10 December 2024 and its first Business Register entry is 12 December 2024. |
| A.16 | Financial condition for the past three years | No substantive statement is made for this item because the condition identified in A.15 is not met. |
| A.17 | Financial condition since registration | Atto B.V. was registered on 12 December 2024. This description is based on EUR-denominated management accounts prepared by the company’s accountant, issued on 28 May 2026 and covering information through 30 April 2026. The accounts are unaudited and have not been independently reviewed. The accounts do not permit a separate assessment of the short 2024 period and do not fully reconcile the accumulated deficit. In 2025, the company recorded no revenue and a loss, mainly from cost of sales and operating and office expenses; no year-end balance sheet or cash-flow statement is available. In January–April 2026, it again recorded no revenue and losses. At 30 April 2026, current liabilities materially exceeded current assets, equity was negative, and liabilities consisted almost entirely of related-party funding from Rotilho B.V. The funding terms are not stated, no commitment guaranteeing future support is reported, and the accounts do not establish sufficient runway, solvency or going-concern certainty. Atto B.V. reported on 19 July 2026 that no newer accountant report was available and that no material financial event had occurred since 30 April; later events are not reflected in this disclosure. |
Part B
Part B — Issuer information, if a separate issuer is selected
| No. | Field | Content |
|---|---|---|
| B.1 | Issuer different from offeror or person seeking admission to trading | No — Atto B.V. is the issuer and the person seeking admission to trading for the admission-to-trading activities addressed in this white paper. |
| B.2 | Name | |
| B.3 | Legal form | |
| B.4 | Registered address | |
| B.4 | Country | |
| B.4 | Sub-division | |
| B.5 | Head office | |
| B.5 | Country | |
| B.5 | Sub-division | |
| B.6 | Registration date | |
| B.7 | Legal entity identifier | |
| B.8 | Another identifier required pursuant to applicable national law | |
| B.9 | Parent company | |
| B.10 | Identity | |
| B.10 | Business address | |
| B.10 | Function | |
| B.11 | Business activity | |
| B.12 | Parent company business activity |
Part C
Part C — Trading-platform operator or other preparer
Part A is the selected actor branch: Atto B.V. is the person seeking admission to trading for the activities addressed in this white paper; no trading-platform operator is stated as drawing up this white paper.
| No. | Field | Content |
|---|---|---|
| C.1 | Name | |
| C.2 | Legal form | |
| C.3 | Registered address | |
| C.3 | Country | |
| C.3 | Sub-division | |
| C.4 | Head office | |
| C.4 | Country | |
| C.4 | Sub-division | |
| C.5 | Registration date | |
| C.6 | Legal entity identifier | |
| C.7 | Another identifier required pursuant to applicable national law | |
| C.8 | Parent company | |
| C.9 | Reason for crypto-asset white paper preparation | |
| C.10 | Identity | |
| C.10 | Business address | |
| C.10 | Function | |
| C.11 | Operator business activity | |
| C.12 | Parent company business activity | |
| C.13 | Other persons drawing up the crypto-asset white paper | |
| C.14 | Reason for drawing the white paper by a different person |
Part D
Part D — The crypto-asset project
| No. | Field | Content | ||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| D.1 | Crypto-asset project name | Atto | ||||||||||||||||
| D.2 | Crypto-asset name | Atto | ||||||||||||||||
| D.3 | Abbreviation | ATTO | ||||||||||||||||
| D.4 | Crypto-asset project description | Atto is a live standalone layer-1 digital-cash network. Its account-chain design supports direct ATTO transfers and Open Representative Voting consensus, while the project provides node software, a wallet, an explorer, distribution programmes and developer interfaces used to access and operate the network. ATTO is the network’s native fixed-supply crypto-asset; its payment and consensus functions do not provide token-gated access to goods or services. | ||||||||||||||||
| D.5 | Implementation persons: type, name, business address and company domicile | The following natural and legal persons are identified for the implementation of the ATTO project.
| ||||||||||||||||
| D.6 | Utility token classification | No. ATTO is not presented as a utility token; its digital-cash purpose and payment-enabling properties do not create a gated utility or access entitlement. | ||||||||||||||||
| D.7 | Key features of goods or services for utility token projects | N/A — ATTO is not a utility token. | ||||||||||||||||
| D.8 | Description of past milestones | In 2024, the Atto network, wallet and explorer became publicly usable; the fixed 18,000,000,000 ATTO supply was created at genesis on 23 November 2024. On 30 March 2025, the Folding@Home reward programme launched as a distribution path for contributed scientific-computing work; consensus remains Open Representative Voting. By 19 May 2026, the roadmap marked phases 0–6 complete, including developer APIs and infrastructure metrics, public discovery/listing work, the representative programme with wallet voter selection, and the web wallet as the main desktop/mobile wallet surface. | ||||||||||||||||
| D.8 | Description of future milestones | Roadmap status as at 19 May 2026: payment flows for small paid requests by software, APIs and agents were started without a target date, including a demonstration endpoint, replay protection, spending controls and developer documentation. Planned without target dates are a bounded atto.market beta catalog for paid APIs and tools; research into a small merchant/self-hosted payment integration; and later content-payment examples and website/publisher integrations. These are current work directions, not commitments to timing or completion; scope and order may change. | ||||||||||||||||
| D.9 | Resource allocation | Resources already allocated to the Atto project include the historical genesis token allocations of 6,300,000,000 ATTO for network incentives (35%), 7,200,000,000 ATTO for development (40%), 4,320,000,000 ATTO for community rewards (24%) and 180,000,000 ATTO for the founder allocation (1%); management and development capacity supplied through Atto B.V., Rotilho B.V. and the natural person identified in D.5; funding provided by Rotilho B.V.; live project software and operational infrastructure; external market-maker services; and Atto B.V.-owned liquidity supplied for market making. The genesis split is historical and is not a statement of current treasury balances, circulating supply or issuer-retained ATTO. No guaranteed future support from Rotilho B.V. or separately approved long-term staffing, infrastructure or milestone budget is represented. | ||||||||||||||||
| D.10 | Planned use of collected funds or other tokens | N/A — no funds or other tokens are collected in this admission-to-trading paper. |
Part E
Part E — Admission to trading
| No. | Field | Content |
|---|---|---|
| E.1 | Public offering or admission to trading | Admission to trading (ATTR) |
| E.2 | Reasons for public offer or admission to trading | The admission-to-trading activities addressed in this white paper are intended to support secondary-market exchange between independent buyers and sellers. They do not involve a sale of ATTO by Atto B.V. or collection of subscription proceeds. Platform names and pairs are listed in E.33; access and costs are qualified in E.35 and E.36. |
| E.3 | Target expressed in currency | N/A — this white paper concerns admission to trading, not a public offer; no fundraising target is set. |
| E.3 | Target expressed in units | — |
| E.3 | Target expressed in digital token identifier | — |
| E.4 | Goals expressed in currency | N/A — no public offer is made in this admission-to-trading white paper. |
| E.4 | Goals expressed in units | N/A — no public offer is made in this admission-to-trading white paper. |
| E.4 | Goals expressed in digital token identifier | N/A — no public offer is made in this admission-to-trading white paper. |
| E.5 | Goals expressed in currency | N/A — no public offer is made in this admission-to-trading white paper. |
| E.5 | Goals expressed in units | N/A — no public offer is made in this admission-to-trading white paper. |
| E.5 | Goals expressed in digital token identifier | N/A — no public offer is made in this admission-to-trading white paper. |
| E.6 | Oversubscription acceptance | N/A — no public offer is made in this admission-to-trading white paper. |
| E.7 | Oversubscription allocation | N/A — no public offer is made in this admission-to-trading white paper. |
| E.8 | Issue price | N/A — no public offer is made in this admission-to-trading white paper. |
| E.9 | Official currency determining issue price | N/A — no public offer is made in this admission-to-trading white paper. |
| E.9 | Any other tokens determining issue price | N/A — no public offer is made in this admission-to-trading white paper. |
| E.10 | Subscription fee - Fee expressed in currency | N/A — no public offer is made in this admission-to-trading white paper. |
| E.10 | Subscription fee - fee expressed in units | N/A — no public offer is made in this admission-to-trading white paper. |
| E.10 | Subscription fee - Fee expressed in digital token identifier | N/A — no public offer is made in this admission-to-trading white paper. |
| E.11 | Offer price determination method | N/A — no public offer is made in this admission-to-trading white paper. |
| E.12 | Total number of offered or traded other tokens | Not established — no fixed quantity admitted to trading is evidenced. |
| E.13 | Targeted holders | All types of investors. Individual access remains subject to E.35. |
| E.14 | Holder restrictions | No issuer-level restriction to a specified holder class is evidenced. Venue access depends on the relevant account, verified country of residence, KYC and jurisdictional eligibility; see E.35. |
| E.15 | Reimbursement notice | N/A — no public offer is made in this admission-to-trading white paper. |
| E.16 | Refund mechanism | N/A — no public offer is made in this admission-to-trading white paper. |
| E.17 | Refund timeline | N/A — no public offer is made in this admission-to-trading white paper. |
| E.18 | Offer phases | N/A — no public offer is made in this admission-to-trading white paper. |
| E.19 | Early purchase discount | N/A — no public offer is made in this admission-to-trading white paper. |
| E.20 | Time-limited offer | N/A — no public offer is made in this admission-to-trading white paper. |
| E.21 | Subscription period beginning | N/A — no public offer is made in this admission-to-trading white paper. |
| E.22 | Subscription period end | N/A — no public offer is made in this admission-to-trading white paper. |
| E.23 | Safeguarding arrangements for offered funds or other tokens | N/A — no public offer is made in this admission-to-trading white paper. |
| E.24 | Payment methods for other token purchase | Not reported — no route-specific payment method is established for this bounded admission activity. |
| E.25 | Value transfer methods for reimbursement | N/A — no public offer is made in this admission-to-trading white paper. |
| E.26 | Right of withdrawal | N/A — no public offer is made in this admission-to-trading white paper. |
| E.27 | Transfer of purchased other tokens | Not reported — no purchaser transfer route is established for this bounded admission activity. |
| E.28 | Transfer time schedule | Not reported — no purchaser transfer schedule is established for this bounded admission activity. |
| E.29 | Purchaser's technical requirements | Not reported — no purchaser technical requirement is established for this bounded admission activity. |
| E.30 | Other token service provider (CASP) name | N/A — no crypto-asset service provider is identified for this paper. |
| E.31 | CASP identifier | N/A — no crypto-asset service provider is identified for this paper. |
| E.32 | Placement form | N/A — no placing arrangement is described. |
| E.33 | Trading platforms name | LCX Exchange (LCX AG) — ATTO/EUR; XT.com — ATTO/USDT. |
| E.34 | Trading platforms market identifier code (MIC) | LCXE |
| E.35 | Trading platforms access | LCX stated on 17 July 2026 that affected EEA accounts were withdrawal-only while authorisation or passporting was pending; access depends on account, country, KYC, jurisdictional and route conditions. This is a dated country/account fact, not an assertion of current availability, formal admission, liquidity or a restart. XT’s public market/ticker presence does not establish individual account access, formal admission or liquidity. For E.34, LCXE is the active operating MIC for LCX AG; current official ISO 10383 data did not identify a segment MIC for LCX. LCXE is supplied as the fallback MIC, not as a segment MIC. A supported segment MIC has not been established for XT.com. |
| E.36 | Involved costs | Fees and costs vary by platform, account, country, network and transaction route. Consult current platform fee information and an authenticated route quote before a transaction. No XT fee, account or fiat-route amount is established in this white paper. |
| E.37 | Offer expenses | N/A — admission to trading; no public-offer expenses. |
| E.38 | Conflicts of interest | Potential conflicts arise from concentration of ownership and control through Rotilho B.V. and the natural person identified in D.5; related-party funding from Rotilho B.V.; Atto B.V.’s control over token allocations and distribution-programme parameters; Atto B.V.’s responsibility for venue-admission activities; and Atto B.V.’s provision of liquidity and payment of an external market maker during periods when trading is available. These are potential interests, not misconduct. GSI release pacing is operationally separate from market making and liquidity. |
| E.39 | Applicable law | Law of the Netherlands. |
| E.40 | Competent court | Courts of the Netherlands. |
Part F
Part F — The crypto-asset
| No. | Field | Content |
|---|---|---|
| F.1 | Crypto-asset type | Crypto-asset other than an asset-referenced token or e-money token (OTHR). ATTO is intended as digital cash. |
| F.2 | Crypto-asset functionality | ATTO is intended as digital cash. It grants no gated utility or access entitlement to a good or service supplied by Atto B.V. Payment-enabling properties and Open Representative Voting consensus are protocol capability/infrastructure, not token utility. |
| F.3 | Planned application of functionalities | ATTO's core transfer and consensus functionality, the web wallet, explorer and node/developer APIs already apply on the live network or current project services. The public faucet form was observed live on 21 July 2026. The Folding@Home reward programme was publicly launched on 30 March 2025. Public staking rules were introduced on 27–28 January 2026, followed by a source commit on 11 February 2026 under a 12 February dated article path announcing staking live; exact production activation and first payout are not established. Contribution rewards operate under a separate public policy. Micropayment rails for paid API/tool/agent requests are in progress. The atto.market beta, merchant/self-hosted payment integrations and content-payment functions are planned in that order, but no target application dates are committed. Those planned functions will apply only if and when their respective phases are implemented and released; scope, order and delivery may change. |
| F.4 | Type of crypto-asset white paper | Other crypto-asset white paper |
| F.5 | Type of submission | NEWT |
| F.6 | Other token characteristics | ATTO is the native crypto-asset of a standalone live layer-1 network. Its fixed maximum supply is 18,000,000,000 ATTO, with nine decimal places. All units were created at genesis and are distributed over time through allocation-based programmes. ATTO is intended as digital cash. It grants no gated utility or access entitlement; payment-enabling properties and Open Representative Voting consensus are protocol capabilities, not token utility. Holding ATTO does not give a holder shares, dividends, a right to redeem at par, a price floor or guaranteed value. |
| F.7 | Commercial name or trading name | |
| F.8 | Website of the issuer | Issuer/project website: https://atto.cash |
| F.9 | Starting date of offer to the public or admission to trading | 4 August 2025 |
| F.10 | Publication date | 1 September 2026 |
| F.11 | Any other services provided by the issuer | Atto B.V. reports work focused on developing, maintaining and operationally managing the cryptocurrency network. The described programmes are faucet, Folding@Home, staking and accepted contribution rewards, each with separate conditions. |
| F.12 | Language or languages of white paper | English |
| F.13 | Digital token identifier code | G3JQMFD76 |
| F.14 | Functionally fungible group digital token identifier | |
| F.15 | Voluntary data flag | No |
| F.16 | Personal data flag | Yes |
| F.17 | LEI eligibility | Yes |
| F.18 | Home member state | Netherlands |
| F.19 | Host member states | Liechtenstein — host Member State for the LCX admission instance. No host Member State is stated for XT.com. |
Part G
Part G — Rights and obligations attached to the crypto-asset
| No. | Field | Content |
|---|---|---|
| G.1 | Purchaser rights and obligations | Ordinary ATTO ownership does not give an issuer equity, vote, dividend, debt, redemption, backing, guaranteed price, guaranteed liquidity, return or compensation right. Programme rewards have separate conditions and are not guaranteed. ORV is protocol consensus, not corporate governance or token utility. |
| G.2 | Exercise of rights and obligations | Use and transfer follow applicable protocol and third-party service conditions. Programme rewards depend on their own eligibility and acceptance terms. Closing future participation does not by itself erase an accrued or accepted programme obligation. |
| G.3 | Conditions for modifications of rights and obligations | Reward availability, amount and conditions are mechanism-specific and may change under the applicable programme terms. A material change must not silently rewrite an accrued or accepted obligation. |
| G.4 | Future public offers | No future public offer is stated in this white paper. |
| G.5 | Issuer retained crypto-assets | 16,766,167,451 ATTO |
| G.6 | Utility token classification | No. ATTO grants no issuer-gated utility or access entitlement; payment-enabling properties and ORV consensus are not token utility. |
| G.7 | Key features of goods or services utility tokens | N/A — ATTO is not a utility token. |
| G.8 | Utility tokens redemption | N/A — ATTO is not a utility token. |
| G.9 | Non-trading request | Yes |
| G.10 | Crypto-assets purchase or sale modalities | N/A — no issuer sale is described in this admission-to-trading paper. |
| G.11 | Crypto-assets transfer restrictions | No universal issuer transfer restriction is reported here. Transfers can still be subject to applicable law, wallet or provider terms, and venue onboarding, KYC, jurisdiction and geographic restrictions. |
| G.12 | Supply adjustment protocols | Yes — the Growth Stability Index changes the rate at which pre-created ATTO is released from selected distribution allocations in response to market-price inputs. It does not mint or burn ATTO or change the fixed maximum supply of 18,000,000,000 ATTO. |
| G.13 | Supply adjustment mechanisms | ATTO has a fixed protocol maximum of 18,000,000,000 ATTO, all created at genesis. The Growth Stability Index does not mint or burn ATTO, change that maximum, reduce ATTO already in circulation or create new units. It affects only the pace at which pre-created ATTO is made available through selected distribution programmes. The intended response is to reduce outflow when market-price conditions are moving downward and increase outflow when those conditions are moving upward. The published formula uses a seven-day average ATTO market price, a one-month low and an all-time high, subject to a configured floor and rate-limited upward changes. Market prices are formula inputs only and do not determine a payment owed to holders. This disclosure does not establish the complete programme scope, update cadence, override rules, monitoring or payout reconciliation for the mechanism. |
| G.14 | Token value protection schemes | Yes — the Growth Stability Index is intended to reduce expected price volatility by changing the release rate of pre-created ATTO. It does not create a peg, redemption right, guaranteed price, floor or return. |
| G.15 | Token value protection schemes description | The Growth Stability Index is an emission-release pacing measure over pre-created ATTO. It is intended to reduce expected price volatility relative to a fixed release schedule by reducing outflow when market-price conditions are moving downward and allowing outflow to increase when those conditions are moving upward. It does not mint or burn ATTO or change the fixed maximum supply of 18,000,000,000 ATTO. It does not target or guarantee a stable value, floor, band, parity or peg and creates no reserve, redemption right, issuer repayment, guaranteed liquidity, compensation or holder claim. Market prices are formula inputs only and do not determine a payment owed to holders. Treasury, liquidity and market-making activities are separate from the Growth Stability Index. |
| G.16 | Compensation schemes | ATTO has no reported compensation scheme. Ordinary ownership carries no issuer compensation, return or guaranteed-liquidity right. |
| G.17 | Compensation schemes description | N/A — ATTO has no compensation scheme. |
| G.18 | Applicable law | Law of the Netherlands. |
| G.19 | Competent court | Courts of the Netherlands. |
Part H
Part H — Underlying technology
| No. | Field | Content |
|---|---|---|
| H.1 | Distributed ledger technology (DLT) | |
| H.2 | Protocols and technical standards | Open, Send, Receive and Change; BLAKE2b; Ed25519; 9 decimals; per-block anti-spam work; REST/NDJSON; WebSocket; Kotlin serialization/Protobuf; MySQL. |
| H.3 | Technology used | ATTO uses a standalone account-chain distributed ledger; each account maintains an ordered chain of signed blocks. The implementation uses a Kotlin/Spring WebFlux/Ktor node, MySQL, REST/NDJSON, WebSocket, a Kotlin Multiplatform wallet, commons libraries, and local or remote signer and work options. |
| H.4 | Consensus mechanism | ATTO uses Open Representative Voting (ORV) as its consensus mechanism. ORV is protocol consensus infrastructure, not a token-granted utility or gated access entitlement. |
| H.5 | Incentive mechanisms and applicable fees | ATTO has no protocol transaction fee. Each block carries lightweight anti-spam work. Open Representative Voting delegation supplies consensus voting weight. A separate staking/voter reward programme may apply under its own holding, delegation, activity, receipt and cap conditions and is not the consensus mechanism itself. The faucet, Folding@Home and contribution rewards are separate distribution programmes and are not consensus mining. Market-making and trading-venue charges, where any, are separate third-party charges; no current quoted amount is asserted here. |
| H.6 | Use of distributed ledger technology | Yes — Atto B.V. operates core ATTO distributed-ledger infrastructure, including representative nodes supporting propagation and consensus participation. |
| H.7 | DLT functionality description | ATTO is a public account-chain distributed-ledger network using Open Representative Voting (ORV). Atto B.V. operates core infrastructure, including representative nodes supporting block propagation and consensus participation. Independent community nodes and representatives may also participate; they are not stated to be Atto B.V. agents. Payment-enabling properties and ORV are protocol capabilities, not token utility, and ATTO grants no gated utility or access entitlement. |
| H.8 | Audit | Yes — internal agent-assisted code audits were completed for pinned source commits: node bea907de7097 (10 July 2026), wallet e8e6305bf0e2 (23 June 2026), and commons a3ccc6f625ca (fresh review completed 17 June 2026). H.9 states their scope, outcomes and limitations; these reviews are not independent assurance or release approval. |
| H.9 | Audit outcome | Internal agent-assisted code audits reviewed pinned node bea907de7097, wallet e8e6305bf0e2 and commons a3ccc6f625ca source versions in June and July 2026. The node review reported 1 Critical and 10 High findings; the wallet review reported 4 High findings; and the fresh commons review reported 1 High finding. Selected commons fixes received only a partial re-review to 0a745ddfcee0. The reviewed source commits have not been shown to be identical to every deployed version and production configuration. Open findings, remediation and deployment-evidence gaps, and residual technology risk remain; these reviews do not provide independent assurance or release approval. |
Part I
Part I — Risks
| No. | Field | Content |
|---|---|---|
| I.1 | Offer-related risks | Admission to trading or access through a venue may be delayed, restricted, suspended or unavailable; see E.35 for access qualifications. A holder may be unable to buy, sell, deposit or withdraw ATTO when expected, may face venue or third-party fees, or may suffer loss from thin liquidity or price volatility. No restart date, uninterrupted-trading period, price support or compensation is stated or guaranteed. |
| I.2 | Issuer-related risks | Not applicable — Atto B.V. is the same legal person as the Part A subject. Current-entity financial, project, continuity, treasury and conflict risks remain disclosed in A.17, E.38 and I.4. |
| I.3 | Crypto-assets-related risks | Ordinary ATTO ownership does not give an issuer equity, debt, redemption, backing, guaranteed price, guaranteed liquidity, return or compensation claim. ATTO is intended as digital cash, but payment capability and ORV consensus do not create a token utility entitlement. ATTO value, liquidity and transferability may change or be unavailable, and programme reward availability, amount and conditions are mechanism-specific and may change. |
| I.4 | Project implementation-related risks | The project may delay, change or cancel planned work because future milestones, budgets, staffing and infrastructure are not contractually committed. Dependencies on software repositories, build and package registries, hosting, databases, public interfaces, wallet backends and other providers can interrupt development or services. Historical progress does not guarantee future delivery, and no future ATTO value is represented. |
| I.5 | Technology-related risks | Technology risk includes the Critical and High matters identified in the pinned source-code audits and residual open findings after only a partial commons re-review. The audits reviewed source code, not every deployment or production configuration, and do not establish remediation completion. Described controls may reduce some risks but do not eliminate them. |
| I.6 | Mitigation measures | The audit records identify transaction-validation rules and P2P frame-size and type-validation controls before event publication. They also record remediation and regression-testing needs; selected commons fixes received only a partial re-review. These records do not establish a complete deployed production-control set, remediation completion, incident response, business continuity, disaster recovery or deployment provenance. Residual technology and operational risk remains. |
Part J
Part J — Sustainability and environmental impacts
| No. | Field | Content |
|---|---|---|
| J.1 | Adverse impacts on climate and other environment-related adverse impacts | The qualified 2026 energy-use estimate is 11388.00000 kWh, below the Article 4(2) 500000 kWh threshold. S.10-S.16 are not required and are not voluntarily provided. |
Part S
Sustainability disclosure identifiers
| No. | Field | Content |
|---|---|---|
| S.1 | Name | Atto B.V. |
| S.2 | Relevant legal entity identifier | 6488ACA2HX03M49K4086 |
| S.3 | Name of the crypto-asset | ATTO |
| S.4 | Consensus mechanism | ATTO uses Open Representative Voting over an account-chain ledger. Balance-weighted representatives vote on valid signed blocks; ORV is consensus infrastructure, not token utility. |
| S.5 | Incentive mechanisms and applicable fees | ATTO has no protocol transaction fee. Balance-weighted Open Representative Voting representatives secure transaction confirmation; delegated voting weight and operator reputation are consensus participation incentives. A separate staking/voter reward programme may apply under its own eligibility conditions and is not the consensus mechanism itself. Each block carries lightweight anti-spam work. The faucet, Folding@Home and contribution rewards are separate distribution programmes, not consensus mining. Market-making and trading-venue charges, where any, are separate third-party charges; no current quoted amount is asserted here. |
| S.6 | Beginning of the period to which the disclosed information relates | 1 January 2026 (proposed calendar-year estimate period). |
| S.7 | End of period to which disclosed information relates | 31 December 2026 (proposed calendar-year estimate period). |
| S.8 | Energy consumption | 11388.00000 kWh for 2026 (qualified unmetered estimate). This is below the Article 4(2) 500000 kWh threshold; it is not measured operating data or independently verified. |
| S.9 | Energy consumption sources and methodologies | Estimated, not metered. For the proposed 2026-01-01 to 2026-12-31 period, annual electricity is E = N × P_IT × 8760 × U × PUE / 1000. Base inputs are N=25 modelled node processes, P_IT=40 W, U=1.0 and PUE=1.3, yielding 11388.00000 kWh; sensitivity is 2365.20000-52560.00000 kWh. Public voter identities and configured seed endpoints are topology proxies, not process, host, operator or energy measurements. Assumptions include process count, attributed power, uptime and PUE. The boundary covers validating and ledger-maintaining node processes, node-integral database activity and attributed host/facility overhead; it excludes end-user devices, wallets, exchanges, websites, explorers and separately unmetered auxiliary services. Best efforts used supported project endpoint/configuration evidence; a precautionary high sensitivity informs the 500000 kWh test. The estimate has disclosed deviations from period-aligned primary energy evidence, no offsets are deducted, renewable allocation is not claimed, and no independent verification was performed. |
| S.10 | Renewable energy consumption | Not required and not voluntarily provided: the qualified S.8 estimate is 11388.00000 kWh, below the Article 4(2) 500000 kWh threshold. |
| S.11 | Energy intensity | Not required and not voluntarily provided: the qualified S.8 estimate is 11388.00000 kWh, below the Article 4(2) 500000 kWh threshold. |
| S.12 | Scope 1 DLT GHG emissions - supported | Not required and not voluntarily provided: the qualified S.8 estimate is 11388.00000 kWh, below the Article 4(2) 500000 kWh threshold. |
| S.13 | Scope 2 DLT GHG emissions - purchased | Not required and not voluntarily provided: the qualified S.8 estimate is 11388.00000 kWh, below the Article 4(2) 500000 kWh threshold. |
| S.14 | GHG intensity | Not required and not voluntarily provided: the qualified S.8 estimate is 11388.00000 kWh, below the Article 4(2) 500000 kWh threshold. |
| S.15 | Key energy sources and methodologies | Not required and not voluntarily provided: the qualified S.8 estimate is 11388.00000 kWh, below the Article 4(2) 500000 kWh threshold. |
| S.16 | Key GHG sources and methodologies | Not required and not voluntarily provided: the qualified S.8 estimate is 11388.00000 kWh, below the Article 4(2) 500000 kWh threshold. |
| S.17 | Energy mix | |
| S.18 | Energy use reduction target (absolute value) | |
| S.18 | Energy use reduction target (percentage) | |
| S.19 | Carbon intensity | |
| S.20 | Scope 3 DLT GHG emissions - value chain | |
| S.21 | GHG emissions reduction targets or commitments | |
| S.22 | Generation of waste electrical and electronic equipment (WEEE) | |
| S.23 | Non-recycled WEEE ratio | |
| S.24 | Generation of hazardous waste | |
| S.25 | Generation of waste (all types) | |
| S.26 | Non-recycled waste ratio (all types) | |
| S.27 | Waste intensity (all types) | |
| S.28 | Waste reduction targets or commitments (all types) | |
| S.29 | Impact of the use of equipment on natural resources | |
| S.30 | Natural resources use reduction targets or commitments | |
| S.31 | Water use | |
| S.32 | Non recycled water ratio | |
| S.33 | Other energy sources and methodologies | |
| S.34 | Other GHG sources and methodologies | |
| S.35 | Waste sources and methodologies | |
| S.36 | Natural resources sources and methodologies |