MiCA Whitepaper
Table of contents
Date of notification
Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114
Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114
Statement in accordance with Article 6(5), points (a), (b), (c) of Regulation (EU) 2023/1114
Statement in accordance with Article 6(5), point (d) of Regulation (EU) 2023/1114
Statement in accordance with Article 6(5), points (e) and (f) of Regulation (EU) 2023/1114
SUMMARY
Warning in accordance with Article 6(7), second subparagraph of Regulation (EU) 2023/1114
Characteristics of the crypto-asset Key information about the offer to the public or admission to trading
Part A - Information about the offeror or the person seeking admission to trading
Name
Legal form
Registered address
Head office
Registration Date
Legal entity identifier
Another identifier required pursuant to applicable
national law
Contact telephone number
E-mail address
Response Time (Days)
Parent Company
Members of the Management body
Business Activity
Parent Company Business Activity
Newly Established
Financial condition for the past three years
Financial condition since registration
Part B - Information about the issuer, if different from the offeror or person seeking admission to trading Issuer different from offeror or person seeking admission to trading
Name
Legal form
Registered address
Head office
Registration Date
Legal entity identifier
Another identifier required pursuant to applicable
national law
Parent Company
Members of the Management body
Business Activity
Parent Company Business Activity
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
Name
Legal form
Registered address
Head office
Registration Date
Legal entity identifier of the operator of the trading
platform
Another identifier required pursuant to applicable
national law
Parent Company
Reason for Crypto-Asset White Paper Preparation
Members of the Management body
Operator Business Activity
Parent Company Business Activity
other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114 Reason for drawing the white paper by persons referred
to in Article 6(1), second subparagraph, of Regulation (EU)
2023/1114
Part D - Information about the crypto-asset project
Crypto-asset project name
Crypto-assets name
Abbreviation
Crypto-asset project description
Details of all natural or legal persons involved in the
implementation of the crypto-asset project
Utility Token Classification
Key Features of Goods/Services for Utility Token Projects
Plans for the token
Resource Allocation
Planned Use of Collected Funds or Crypto-Assets
Part E - Information about the offer to the public of crypto- assets or their admission to trading
Public Offering or Admission to trading
Reasons for Public Offer or Admission to trading
Fundraising Target
Minimum Subscription Goals
Maximum Subscription Goal
Oversubscription Acceptance
Oversubscription Allocation
Issue Price
Official currency or any other crypto- assets determining
the issue price
Subscription fee
Offer Price Determination Method
Total Number of Offered/Traded Crypto- Assets
Targeted Holders
Holder restrictions
Reimbursement Notice
Refund Mechanism
Refund Timeline
Offer Phases
Early Purchase Discount
Time-limited offer
Subscription period beginning
Subscription period end
Safeguarding Arrangements for Offered Funds/Crypto-
Assets
Payment Methods for Crypto-Asset Purchase
Value Transfer Methods for Reimbursement
Right of Withdrawal
Transfer of Purchased Crypto-Assets
Transfer Time Schedule
Purchaser's Technical Requirements
Crypto-asset service provider (CASP) name
CASP identifier
Placement form
Trading Platforms name
Trading Platforms Market Identifier Code (MIC)
Trading Platforms Access
Involved costs
Offer Expenses
Conflicts of Interest
Applicable law
Competent court
Part F - Information about the crypto-assets
Crypto-Asset Type
Crypto-Asset Functionality
Planned Application of Functionalities
Type of white paper
The type of submission
Crypto-Asset Characteristics
Commercial name or trading name
Website of the issuer
Starting date of offer to the public or admission to trading
Publication date
Any other services provided by the issuer
Identifier of operator of the trading platform
Language or languages of the white paper
Digital Token Identifier Code
Functionally Fungible Group Digital Token Identifier
Voluntary data flag
Personal data flag
LEI eligibility
Home Member State
Host Member States
Part G - Information on the rights and obligations attached to the crypto-assets
Purchaser rights and obligations
Exercise of rights and obligations
Conditions for modifications of rights and obligations
Future Public Offers
Issuer Retained Crypto-Assets
Utility Token Classification
Key Features of Goods/Services of Utility Tokens
Utility Tokens Redemption
Non-Trading request
Crypto-Assets purchase or sale modalities
Crypto-Assets Transfer Restrictions
Supply Adjustment Protocols
Supply Adjustment Mechanisms
Token Value Protection Schemes
Token Value Protection Schemes Description
Compensation Schemes
Compensation Schemes Description
Applicable law
Competent court
Part H - Information on the underlying technology
Distributed ledger technology
Protocols and technical standards
Technology Used
Consensus Mechanism
Incentive Mechanisms and Applicable Fees
Use of Distributed Ledger Technology
DLT Functionality Description
Audit
Audit outcome
Part I - Information on risks
Offer-Related Risks
Issuer-Related Risks
Crypto-Assets-related Risks
Project Implementation-Related Risks
Technology-Related Risks
Mitigation measures
Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other
environment-related adverse impacts
Adverse impacts on climate and other environment-
related adverse impacts
Part S - Mandatory information on principal adverse impacts on the climate and other environmental-related adverse impacts of the consensus mechanism
Name
Relevant legal entity identifier
Name of the crypto-asset
Consensus Mechanism
Incentive Mechanisms and Applicable Fees
Beginning of the period to which the disclosed informatior relates
End of the period to which the disclosed informatior relates
Mandatory key indicator on energy consumption
Energy Consumption
Sources and methodologies
Energy Consumption Sources and Methodologies
Supplementary key indicators on energy and GHG emissions
Renewable energy consumption
Energy intensity
Scope 1 DLT GHG emissions - Controlled
Scope 2 DLT GHG emissions - Purchased
GHG intensity
Sources and methodologies
Key energy sources and methodologies
Key GHG sources and methodologies
1
Date of notification
2025-10-20
2
Statement in accordancewith Article 6(3) ofRegulation (EU) 2023/1114
This crypto-asset white paper has not been approved by anycompetent authority in any Member State of the EuropeanUnion. The person seeking admission to trading of thecrypto-asset is solely responsible for the content of thiscrypto-asset white paper.
3
Compliance statement inaccordance with Article6(6) of Regulation (EU)2023/1114
This crypto-asset white paper complies with Title II ofRegulation (EU) 2023/1114 and, to the best of the know ledgeof 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 toaffect its import.
4
Statement in accordancewith 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.
5
Statement in accordancewith Article 6(5), point (d)of Regulation (EU)2023/1114
FALSE
6
Statement in accordancewith Article 6(5), points (e)and (f) of Regulation (EU)2023/1114
The crypto-asset referred to in this white paper is notcovered by the investor compensation schemes underDirective 97/9/EC of the European Parliament and of theCouncil or the deposit guarantee schemes under Directive2014/49/EU of the European Parliament and of the Council.
7
Warning in accordancewith Article 6(7), secondsubparagraph ofRegulation (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 whitepaper 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.
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 whitepaper 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.
8
Characteristics of the crypto-asset
DRONE (the 'Token') will be launched on Base Layer 2 ('Base')to serve as the native token of LayerDrone Protocol (the'Protocol'), a geospatial drone data capture and distribution protocol built on Base. The Token will serve as the primary medium of exchange within the Protocol's decentralised network of drone operators and data buyers.
The Token will be used to compensate drone pilots when they complete verified data capture missions by submitting verified aerial imagery. Data buyers will use the Token to buy imagery from the Protocol or through Value-AddedProviders ('VAPs'). Additionally, drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol.
Token holders may potentially participate in the Protocol's governance. According to the Protocol's documentation, Token holders could be able to influence the Protocol's trajectory through governance participation, but how the governance will work in practice is yet to be defined.
Any modifications to the Token's characteristics, rights, or obligations will be implemented through protocol updates managed by LayerDrone Foundation (the 'Foundation'). Changes to the protocol and Token mechanics will be communicated through the Protocol's official channels and documentation.
The Token will be used to compensate drone pilots when they complete verified data capture missions by submitting verified aerial imagery. Data buyers will use the Token to buy imagery from the Protocol or through Value-AddedProviders ('VAPs'). Additionally, drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol.
Token holders may potentially participate in the Protocol's governance. According to the Protocol's documentation, Token holders could be able to influence the Protocol's trajectory through governance participation, but how the governance will work in practice is yet to be defined.
Any modifications to the Token's characteristics, rights, or obligations will be implemented through protocol updates managed by LayerDrone Foundation (the 'Foundation'). Changes to the protocol and Token mechanics will be communicated through the Protocol's official channels and documentation.
9
N/A
10
Key information about the offer to the public or admission to trading
The issuer seeks admission of the Token to trading in order to enable more individuals to obtain and use the Token so that they can contribute and participate in the Protocol, thereby creating a mutually beneficial system where every participant is fairly compensated for their efforts. Additionally, by seeking admission to trading, they aim to increase the liquidity of the Token, facilitating equity and its exchangeability. The trading platforms for which admission to trading is being sought have been delineated in part E.33 of this whitepaper.
Part A - Information about the offeror or the person seeking admission to trading
A.1
Name
LayerDrone Inc.
A.2
Legal form
Company limited by shares
A.3
Registered address
CO Services (BVI) Ltd. of Rodus Building, P.O. Box 3093, Road Town, Tortola, VG1110, British Virgin Islands.
A.4
Head office
N/A
A.5
Registration Date
2025-05-23
A.6
Legal entity identifier
N/A
A.7
Another identifier required pursuant to applicable national law
2177449
A.8
Contact telephone number
+1 345 9360807
A.9
E-mail address
sarah@marfire.com
A.10
Response Time (Days)
5
A.11
Parent Company
LayerDrone Foundation
A.12
Members of the Management body
The management body responsible for the person seeking admission to trading of the Token is the Layerdrone Foundation. The Foundation is directed solely by Ms. Sarah Wheeler, who has therefore been identified as the control person, situated at the following address: Elgin Court, Elgin Avenue, George Town, Grand Cayman, KY1-1106, Cayman Islands.
A.13
Business Activity
The person seeking admission to trading is also the issuer of the Token i.e. primarily responsible for the issuance of the DRONE token.
A.14
Parent Company Business Activity
The LayerDrone Foundation is responsible for overseeing the operations of the LayerDrone protocol.
A.15
Newly Established
TRUE
A.16
Financial condition for the past three years
N/A
A.17
Financial condition since registration
Since its establishment in 2025, LayerDrone Inc. has maintained a stable financial position supported by structured inter company funding arrangements. The Company serves as the designated token issuance entity within the LayerDrone group structure.
Funding for LayerDrone Inc. is provided by the LayerDrone Foundation, which in turn is financed through a promissory note issued by Spexi Geospatial Labs. Spexi Geospational Labs has successfully raised approximately USD 20.7 million to date, providing a robust capital base to support the development and launch of the LayerDrone Protocol.
Prior to the token generation event, operational and development expenditures are funded through this promissory note arrangement. The project's monthly operating expenses remain modest, currently averaging between USD 20,000 - 30,000 per month, ensuring a controlled burn rate relative to available resources.
Following the TGE, the LayerDrone Foundation will continue to fund LayerDrone Inc. through over-the-counter (OTC) token sales and its allocation of 4.5% of the total Drone token supply, reserved specifically to support ongoing operational activities, ecosystem development, and the expansion of the Protocol.
The overall structure, comprising a Cayman Islands foundation with a BVI subsidiary, has been established to facilitate transparent funding flows and efficient resource allocation. This setup ensures that LayerDrone Inc. maintains adequate financial resources to meet its obligations and sustain its activities in connection with the token issuance and related ecosystem development.
Funding for LayerDrone Inc. is provided by the LayerDrone Foundation, which in turn is financed through a promissory note issued by Spexi Geospatial Labs. Spexi Geospational Labs has successfully raised approximately USD 20.7 million to date, providing a robust capital base to support the development and launch of the LayerDrone Protocol.
Prior to the token generation event, operational and development expenditures are funded through this promissory note arrangement. The project's monthly operating expenses remain modest, currently averaging between USD 20,000 - 30,000 per month, ensuring a controlled burn rate relative to available resources.
Following the TGE, the LayerDrone Foundation will continue to fund LayerDrone Inc. through over-the-counter (OTC) token sales and its allocation of 4.5% of the total Drone token supply, reserved specifically to support ongoing operational activities, ecosystem development, and the expansion of the Protocol.
The overall structure, comprising a Cayman Islands foundation with a BVI subsidiary, has been established to facilitate transparent funding flows and efficient resource allocation. This setup ensures that LayerDrone Inc. maintains adequate financial resources to meet its obligations and sustain its activities in connection with the token issuance and related ecosystem development.
Part B - Information about the issuer, if different from the offeror or person seeking admission to trading
B.1
Issuer different from offeror or person seeking admission to trading
FALSE
B.2
Name
N/A
B.3
Legal form
N/A
B.4
Registered address
N/A
B.5
Head office
N/A
B.6
Registration Date
N/A
B.7
Legal entity identifier
N/A
B.8
Another identifier required pursuant to applicable national law
N/A
B.9
Parent Company
N/A
B.10
Members of the Management body
N/A
B.11
Business Activity
N/A
B.12
Parent Company Business Activity
N/A
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
C.1
Name
N/A
C.2
Legal form
N/A
C.3
Registered address
N/A
C.4
Head office
N/A
C.5
Registration Date
N/A
C.6
Legal entity identifier of the operator of the trading platform
N/A
C.7
Another identifier required pursuant to applicable national law
N/A
C.8
Parent Company
N/A
C.9
Reason for Crypto-AssetWhite Paper Preparation
N/A
C.10
Members of theManagement body
N/A
C.11
Operator Business Activity
N/A
C.12
Parent Company BusinessActivity
N/A
C.13
Other persons drawing upthe crypto- asset whitepaper according to Article6(1), second subparagraph,of Regulation (EU)2023/1114
N/A
C.14
Reason for drawing thewhite paper by personsreferred to in Article 6(1),second subparagraph, ofRegulation (EU) 2023/1114
N/A
Part D - Information about the crypto-asset project
D.1
Crypto-asset project name
LayerDrone Protocol
D.2
Crypto-assets name
DRONE Token
D.3
Abbreviation
DRONE
D.4
Crypto-asset projectdescription
The Protocol is a geospatial drone data capture and distribution protocol built on Base. It standardises and monetises aerial imagery collection by incentivising a decentralised network of drone operators to capture high- resolution data on standardised geographic zones. The Protocol team has developed a system to coordinate data collection missions, verification of the captured imagery, and distribution to data buyers. By relying on a blockchain-based verification system, the Protocol offers data authenticity and immutable proof of capture. This combination provides data integrity for buyers while creating a reward system for drone pilots. The Protocol follows a structured mission system based on 'spexigons', which are 25-acre hexagon-shaped pieces of land that represent standard image capture zones. The Protocol has two types of missions: supply-led missions that approximate target spexigons, and demand-led missions where humans are willing to pay for standardised aerial imagery. The Token serves as the Protocol's native token. Pilots who complete data capture missions and provide verified imagery received in exchange a non-fungible token ('NFT') as a submission and validity proof and are compensated with the Token. Data buyers use the Token to buy imagery directly from the Protocol. In exchange, they receive an NFT that represents the right to access and commercialise the imagery. Additionally, data can be bought through Value- Added Providers (VAPs') who acquire the data from the Protocol using the Token, to then resell it. The Token is also used to reward pilots who complete specific flights requested by the Protocol. Lastly, the Protocol is split into sub-protocols that handle mission creation, data verification, and storage. The sub- protocols will initially be handled by the Foundation, and then by technical committees coordinated by the Protocol governance.
D.5
Details of all natural orlegal persons involved inthe implementation of thecrypto-asset project
Details relating to key advisors, development team, crypto-assets service providers and other persons involved in the implementation of the Project include:
● Coinbase Custody (QC) is situated at the following business address: Coinbase, Inc. 248 3rd St, #434
Oakland, CA 94607
● Autonomous projects (service provider) is situated at the following business address: Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands
● Carey Olsen (offshore legal) is situated at the
following business address: Pavilion East, Cricket Square, Grand Cayman, KY1-1001, Cayman Islands
● Fenwick (onshore legal) is situated at the following business address: 801 California Street
Mountain View, CA 94041
● Spexi Geospatial (labs co) is situated at the following business address: 087 Headquarters Road Courtenay BC V9J 1M1, CANADA
D.6
Utility Token Classification
False
D.7
Key Features ofGoods/Services for UtilityToken Projects
N/A
D.8
Plans for the token
The Token will be launched through a Token Generation Event ('TGE') planned to be announced towards the end of 2025. The Protocol is organised under a set of sub-protocols that handle mission creation, data verification, and storage. Currently, the Foundation is in charge of defining sub- protocol parameters. However, the Foundation's plan is to decentralise the management of these sub-protocols to technical committees that will be coordinated by the Protocol governance.
In this context, the Token's use cases will be introduced following the TGE. Token holders may gain governance participation rights, allowing them to influence the Protocol's future and to coordinate the technical committees in charge of each sub-protocol. Moreover, the Token will be used to reward drone pilots that successfully complete missions within the Protocol. Drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol. The Token will also serve as the Protocol's medium, allowing users to buy data from the Protocol. Lastly, VAPs, such as Spexi, will be able to use the Token to buy imagery from the Protocol and resell it.
The Protocol's roadmap comprises the launch of an API and developer tools, establishing partnerships with VAPs beyond Spexi, and implementing bounty systems for community- requested imagery. Additionally, the Foundation aims to expand network coverage to new countries, add 50 new municipalities, and capture over 3 million acres of imagery in 2025.
In this context, the Token's use cases will be introduced following the TGE. Token holders may gain governance participation rights, allowing them to influence the Protocol's future and to coordinate the technical committees in charge of each sub-protocol. Moreover, the Token will be used to reward drone pilots that successfully complete missions within the Protocol. Drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol. The Token will also serve as the Protocol's medium, allowing users to buy data from the Protocol. Lastly, VAPs, such as Spexi, will be able to use the Token to buy imagery from the Protocol and resell it.
The Protocol's roadmap comprises the launch of an API and developer tools, establishing partnerships with VAPs beyond Spexi, and implementing bounty systems for community- requested imagery. Additionally, the Foundation aims to expand network coverage to new countries, add 50 new municipalities, and capture over 3 million acres of imagery in 2025.
D.9
Reason for drawing thewhite paper by personsreferred to in Article 6(1),second subparagraph, ofRegulation (EU) 2023/1114
This allocation will be subject to a 1-year lockup
followed by a 3-year linear vesting.
● Foundation Operations: 2.0% - 20,000,000 Tokens, reserved for the Foundation operations and development of the Protocol. This allocation will be completely released at TGE.
● Market Makers: 1.5% - 15,000,000 Tokens, allocated to market makers. This allocation will be completely released at TGE.
● Treasury Service Providers: 1.5% - 15,000,000 Tokens, allocated to treasury service providers. This allocation will be subject to a 1-year lockup followed by a 3-year linear vesting schedule.
● Airdrop: 1.0% - 10,000,000 Tokens, distributed through an airdrop campaign and completely released at TGE.
● Foundation Service Providers: 1.0% - 10,000,000 Tokens, allocated to foundation service providers, subject to a 2-year linear unlock schedule.
D.10
Planned Use of CollectedFunds or Crypto-Assets
N/A
Part E - Information about the offer to the public of crypto-assets or their admission to trading
E.1
Public Offering orAdmission to trading
ATTR
E.2
Reasons for Public Offer orAdmission to trading
The issuer seeks admission of the Token to trading in orderto enable more individuals to obtain and use the Token sothat they can contribute and participate in the Protocol,thereby creating a mutually beneficial system where everyparticipant is fairly compensated for their efforts.Additionally, by seeking admission to trading, they aim toincrease the liquidity of the Token, facilitating equity and itsexchangeability.
E.3
Fundraising Target
N/A
E.4
Minimum SubscriptionGoals
N/A
E.5
Maximum SubscriptionGoal
N/A
E.6
OversubscriptionAcceptance
FALSE
E.7
OversubscriptionAllocation
N/A
E.8
Issue Price
N/A
E.9
Official currency or any other crypto- assets determining the issue price
N/A
E.10
Subscription fee
N/A
E.11
Offer Price Determination Method
N/A
E.12
Total Number ofOffered/Traded Crypto-Assets
1,000,000,000
E.13
Targeted Holders
ALL
E.14
Holder restrictions
While the rewards of the Token are geofenced to the region where the missions are held, the actual purchase of the Token from EU-regulated trading platform will be available to all users of such trading platform.
Most trading and exchange services offered by trading platforms are open to retail holders, and may be subject to the compliance requirements of the respective trading platform. The trading platform may impose restrictions on holders of Tokens on their respective trading platform, in accordance with applicable laws and internal policies.
Most trading and exchange services offered by trading platforms are open to retail holders, and may be subject to the compliance requirements of the respective trading platform. The trading platform may impose restrictions on holders of Tokens on their respective trading platform, in accordance with applicable laws and internal policies.
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
FALSE
E.21
Subscription period beginning
N/A
E.22
Subscription period end
N/A
E.23
Safe guarding Arrangements for Offered Funds/Crypto-Assets
N/A
E.24
Payment Methods for Crypto-Asset Purchase
N/A
E.25
Value Transfer Methods for Reimbursement
N/A
E.26
Right of Withdrawal
N/A
E.27
Transfer of Purchased
Crypto-Assets
Crypto-Assets
N/A
E.28
Transfer Time Schedule
N/A
E.29
Purchaser's Technical
Requirements
Requirements
Technical requirements will be specified by the trading platform and may include the following:
1. A compatible digital wallet or account on supported exchanges;
2. Internet access;
3. A device (computer or mobile) to manage a digital wallet/private key and/or account on an exchange to carry out transactions
1. A compatible digital wallet or account on supported exchanges;
2. Internet access;
3. A device (computer or mobile) to manage a digital wallet/private key and/or account on an exchange to carry out transactions
E.30
Crypto-asset service
provider (CASP) name
provider (CASP) name
N/A
E.31
CASP identifier
N/A
E.32
Placement form
NATV
E.33
Trading Platforms name
The trading platforms for which admission to trading of the Token is being sought include but are not limited to the following: OK, Kraken, Crypto.com, Gemini, Coinbase, ByBit, Bitvavo and Binance. The issuer reserves the right to expand such listings as additional MiCA-compliant trading platforms become available over time.
E.34
Trading Platforms Market
Identifier Code (MIC)
Identifier Code (MIC)
N/A
E.35
Trading Platforms Access
The trading platforms are accessible via their respective websites. Naturally, investors would need to complete standard registration procedures and are recommended to secure their accounts via adequate security measures such as two-factor authentication to prevent unauthorised access.
E.36
Involved costs
The use of services offered by trading platforms may involve costs, including transaction fees, withdrawal fees, and other charges. These costs are determined and set by the respective trading platforms, varying between one and the other, which is why investors are encouraged to carefully review the fee schedule of their chosen trading platform prior to trading.
Moreover, these costs are not controlled, influenced, or governed by the person seeking admission to trading. Consequently, any changes to fee structures or the introduction of new costs are solely at the discretion of these platforms.
Moreover, these costs are not controlled, influenced, or governed by the person seeking admission to trading. Consequently, any changes to fee structures or the introduction of new costs are solely at the discretion of these platforms.
E.37
Offer Expenses
N/A
E.38
Conflicts of Interest
N/A
E.39
Applicable law
British Virgin Islands Law
E.40
Competent court
Courts of the British Virgin Islands
Part F - Information about the crypto-assets
F.1
Crypto-Asset Type
The Token is classified as a "crypto-asset other than asset-referenced token or e-money token" under Title II of theMarkets in Crypto-Assets Regulation (EU) 2023/1114.
F.2
Crypto-Asset Functionality
According to article 3(1)(5) of MiCA, a crypto-asset is a digital representation of a value or of a right that is able to be transferred and stored electronically using distributed ledger technology or similar technology. As reminded by the European Banking Authority ('EBA'), the term 'right' should be interpreted broadly in accordance with recital (2) of MiCA.
The Token qualifies as a crypto-asset within the meaning of MiCA, as it a digital representation of the right to access the Ecosystem and participate in the Ecosystem's governance. The Token can be transferred and stored using the distributed ledger technology ('DLT')
The Token facilitates Token holders' interaction with the Network by displaying the following functionalities:
Use cases following the TGE:
• Payment: Drone pilots who complete data capture missions and provide verified imagery will be compensated with the Token. Data buyers and VAPs will use the Token to buy imagery from the Protocol. The Token will be used to reward pilots who complete flight missions requested by the Protocol.
• Deposits - Special Access: Drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol.
Potential use cases:
• Governance: Token holders may be able to participate in the Protocol governance, influencing the Protocol's future.
The Token qualifies as a crypto-asset within the meaning of MiCA, as it a digital representation of the right to access the Ecosystem and participate in the Ecosystem's governance. The Token can be transferred and stored using the distributed ledger technology ('DLT')
The Token facilitates Token holders' interaction with the Network by displaying the following functionalities:
Use cases following the TGE:
• Payment: Drone pilots who complete data capture missions and provide verified imagery will be compensated with the Token. Data buyers and VAPs will use the Token to buy imagery from the Protocol. The Token will be used to reward pilots who complete flight missions requested by the Protocol.
• Deposits - Special Access: Drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol.
Potential use cases:
• Governance: Token holders may be able to participate in the Protocol governance, influencing the Protocol's future.
F.3
Planned Application of Functionalities
The first two functionalities mentioned on F.2, Payment and Deposits - Special Access, will be available after the Token's Page 17 of 33 TGE. Meanwhile, the Governance functionality is yet to be confirmed by the Foundation.
A description of the characteristics of the crypto-asset, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article
F.4
Type of white paper
OTHR
F.5
The type of submission
Courts of the British Virgin Islands
F.6
Crypto-Asset Characteristics
The Token will be launched on Base to serve as the native token of Protocol, a geospatial drone data capture and distribution protocol built on Base. The Token will serve as the primary medium of exchange within the Protocol's decentralised network of drone operators and data buyers.
The Token will be used to compensate drone pilots when they complete verified data capture missions by submitting verified aerial imagery. Data buyers will use the Token to buy imagery from the Protocol or through VAPs. Additionally, drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol.
Token holders may potentially participate in the Protocol's governance. According to the Protocol's documentation, Token holders could be able to influence the Protocol's trajectory through governance participation, but how the governance will work in practice is yet to be defined.
Any modifications to the Token's characteristics, rights, or obligations will be implemented through protocol updates managed by Foundation. Changes to the protocol and Token mechanics will be communicated through the Protocol's official channels and documentation.
The Token will be used to compensate drone pilots when they complete verified data capture missions by submitting verified aerial imagery. Data buyers will use the Token to buy imagery from the Protocol or through VAPs. Additionally, drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol.
Token holders may potentially participate in the Protocol's governance. According to the Protocol's documentation, Token holders could be able to influence the Protocol's trajectory through governance participation, but how the governance will work in practice is yet to be defined.
Any modifications to the Token's characteristics, rights, or obligations will be implemented through protocol updates managed by Foundation. Changes to the protocol and Token mechanics will be communicated through the Protocol's official channels and documentation.
F.7
Commercial name or trading name
DRONE
F.8
Website of the issuer
https://www.layerdrone.org/
F.9
Starting date of offer to the public or admission to trading
2025-11-17
F.10
Publication date
2025-11-16
F.11
Any other services provided by the issuer
N/A
F.12
Language or languages of the white paper
English
F.13
N/A
Courts of the British Virgin Islands
F.14
Functionally Fungible Group Digital Token Identifier, where available
N/A
F.15
Voluntary data flag
FALSE
F.16
Personal data flag
TRUE
F.17
LEI eligibility
TRUEF.18
Home Member State
Malta
F.19
Host Member States
The admission to trading of the Token is passported in the following countries:
• Austria
• Belgium
• Belgaria
• Croatia
• Cyprus
• Czech
• Germany
• Denmark
• Estonia
• Spain
• Finland
• France
• Greece
• Hungary
• Iceland
• Ireland
• Italy
• Latvia
• Liechtenstein
• Lithuania
• Luxembourg
• Netherlands
• Norway
• Poland
• Portugal
• Romania
• Slovakia
• Austria
• Belgium
• Belgaria
• Croatia
• Cyprus
• Czech
• Germany
• Denmark
• Estonia
• Spain
• Finland
• France
• Greece
• Hungary
• Iceland
• Ireland
• Italy
• Latvia
• Liechtenstein
• Lithuania
• Luxembourg
• Netherlands
• Norway
• Poland
• Portugal
• Romania
• Slovakia
Part G - Information on the rights and obligations attached to the crypto-assets
G.1
Purchaser Rights and Obligations
Following the TGE, the Token will provide the following rights:
• Payment: Drone pilots who complete data capture missions and provide verified imagery will be compensated with the Token. Data buyers and VAPs will use the Token to buy imagery from the Protocol. The Token will be used to reward pilots who complete flight missions requested by the Protocol.
• Deposits - Special Access: Drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol.
If the Foundation proceeds, the Token could provide the following additional right:
• Governance: Token holders may be able to participate in the Protocol governance, influencing the Protocol's future.
• Payment: Drone pilots who complete data capture missions and provide verified imagery will be compensated with the Token. Data buyers and VAPs will use the Token to buy imagery from the Protocol. The Token will be used to reward pilots who complete flight missions requested by the Protocol.
• Deposits - Special Access: Drone pilots will be able to deposit the Token to reserve future flights or gain access to missions requested by the Protocol.
If the Foundation proceeds, the Token could provide the following additional right:
• Governance: Token holders may be able to participate in the Protocol governance, influencing the Protocol's future.
G.2
Exercise of Rights and obligations
Following the TGE, to exercise the rights mentioned in G.1, Token holders must:
• Payment: To be compensated with the Token, drone pilots will have to complete data capture missions and provide verified imagery. To exercise their right to buy data from the Protocol, data buyers and VAPs will have to use the Token to buy imagery from the Protocol. To be rewarded with the Token, pilots will need to complete specific flight requests requested by the Protocol.
• Deposits - Special Access: To be able to reserve future flights or gain access to missions requested by the Protocol, drone pilots will have to deposit the Token.
Due to the lack of confirmation, currently, there is no information on how the governance rights will be executed within the Protocol.
• Payment: To be compensated with the Token, drone pilots will have to complete data capture missions and provide verified imagery. To exercise their right to buy data from the Protocol, data buyers and VAPs will have to use the Token to buy imagery from the Protocol. To be rewarded with the Token, pilots will need to complete specific flight requests requested by the Protocol.
• Deposits - Special Access: To be able to reserve future flights or gain access to missions requested by the Protocol, drone pilots will have to deposit the Token.
Due to the lack of confirmation, currently, there is no information on how the governance rights will be executed within the Protocol.
G.3
Conditions for modifications of rights and obligations
Any modifications to the Token's characteristics, rights, or obligations are to be decided and implemented by the Foundation. Modifications to the protocol and Token mechanics are to be communicated through the Platform's official channels and documentation.
G.4
Future Public Offers
FALSE
G.5
Issuer Retained Crypto- Assets
520,000,000
G.6
Utility Token Classification
FALSE
G.7
Key Features of Goods/Services of Utility Tokens
N/A
G.8
Utility Tokens Redemption
N/A
G.9
Non-Trading request
TRUE
G.10
Crypto-Assets purchase or sale modalities
N/A
G.11
Crypto-Assets Transfer Restrictions
The trading platforms may impose restrictions on holders of Tokens on their respective trading platform, in accordance with applicable laws and internal policies. Token holders who acquire the Token through 'private sales' are subject to restrictions as per the terms of sale.
G.12
Supply Adjustment Protocols
FALSE
G.13
Supply Adjustment Mechanisms
N/A
G.14
Token Value Protection Schemes
FALSE
G.15
Token Value Protection Schemes Description
N/A
G.16
Compensation Schemes
FALSE
G.17
Compensation Schemes Description
N/A
G.18
Home Applicable law State
British Virgin Islands Law
G.19
Competent court
Courts of the British Virgin Islands
Part H - Information on the underlying technology
H.1
Distributed ledger technology
The Token was initially launched on the Base under the ERC- 20 standard to guarantee industry-standard compatibility.
H.2
Protocols and technical standards
The Token was initially launched on Base under the ERC-20 standard to guarantee industry-standard compatibility.
H.3
Technology Used
As an ERC-20 token, the Token will be deployed as a smart contract on the Ethereum blockchain. Users can manage the Token through their own non-custodial wallet software provided by third parties or by directly interacting with the token's smart contract through a third-party API.
H.4
Consensus Mechanism
Base is a Layer-2 (L2) solution on Ethereum that was introduced by Coinbase and developed using Optimism's OP Stack. L2 transactions do not have their own consensus mechanism and are only validated by the execution clients. The so-called sequencer regularly bundles stacks of L2 transactions and publishes them on the L1 network, i.e. Ethereum. Ethereum's consensus mechanism (Proof-of- stake) thus indirectly secures all L2 transactions as soon as they are written to L1.
H.5
Incentive Mechanisms and Applicable Fees
Base is a Layer-2 (L2) solution on Ethereum that uses optimistic rollups provided by the OP Stack on which it was developed. Transaction on base are bundled by a, so called, sequencer and the result is regularly submitted as an Layer- 1 (L1) transactions. This way many L2 transactions get combined into a single L1 transaction. This lowers the average transaction cost per transaction, because many L2 transactions together fund the transaction cost for the single L1 transaction. This creates incentives to use base rather than the L1, i.e. Ethereum, itself. To get crypto-assets in and out of base, a special smart contract on Ethereum is used. Since there is no consensus mechanism on L2 an additional mechanism ensures that only existing funds can be withdrawn from L2. When a user wants to withdraw funds, that user needs to submit a withdrawal request on L1. If this request remains unchallenged for a period of time the funds can be withdrawn. During this time period any other user can submit a fault proof, which will start a dispute resolution process. This process is designed with economic incentives for correct behaviour.
H.6
Use of Distributed Ledger Technology
FALSE
H.7
DLT Functionality Description
N/A
H.8
Audit
TRUE
H.9
Audit outcome
All areas of risk were assessed at either low (majority) or moderate (minority). 8 risk vectors were audited.
Severity of Vulnerability: 7 Low, 1 Moderate Probability of exploitation: 4 Moderate, 4 low Overall Risk to Spexi: 8 Low
Low Risk: Vulnerabilities are not exploitable but would reduce an organisation's attack surface. Remediation within 4-6 months is recommended. Moderate Risk: Vulnerabilities exist but are not exploitable or require l extras s steps such as social engineering. Remediation within 1-3 months is highly recommended.
Severity of Vulnerability: 7 Low, 1 Moderate Probability of exploitation: 4 Moderate, 4 low Overall Risk to Spexi: 8 Low
Low Risk: Vulnerabilities are not exploitable but would reduce an organisation's attack surface. Remediation within 4-6 months is recommended. Moderate Risk: Vulnerabilities exist but are not exploitable or require l extras s steps such as social engineering. Remediation within 1-3 months is highly recommended.
Part I - Information on risks
I.1
Offer-Related Risks
A non-exhaustive list of risks associated with admitting a crypto-asset for trading include:
Exchange Selection and Counterparty Risk: The admission to trading on a crypto-asset exchange exposes token holders to risks associated with the specific exchange's operational practices, financial stability, and security measures. Exchanges vary significantly in their regulatory compliance, custody arrangements and track record. If a token is listed on exchanges with inadequate security, poor governance, or weak financial controls, holders face increased risks of losing their assets due to exchange insolvency, mismanagement, or fraud. Token holders who maintain their assets on exchanges rather than in self-custody wallets are particularly exposed to these counterparty risks, as they rely entirely on the exchange's ability and willingness to honor withdrawal requests and protect deposited assets.
Market Manipulation and Trading Irregularities: Crypto-asset exchanges, particularly those with lower trading volumes or less stringent oversight, may be susceptible to market manipulation activities including wash trading, spoofing, pump-and-dump schemes, and coordinated trading by groups of actors. Such manipulative practices can create artificial price movements that do not reflect genuine supply and demand, potentially misleading investors about a token's true market value and liquidity. Token holders may suffer losses if they make trading decisions based on manipulated price signals, or if they are unable to execute trades at expected prices due to artificial order book conditions.
Delisting and Trading Suspension Risk: Exchanges retain the discretion to suspend trading or delist crypto-assets based on their own policies, regulatory requirements, compliance concerns, or commercial decisions. A token may be delisted due to insufficient trading volume, regulatory developments, concerns about the project's legitimacy, technical issues, or changes in the exchange's listing criteria. Delisting or trading suspension can severely impact a token's liquidity and market value, as holders may find themselves with limited or no venues to trade their assets. In cases where a token is delisted from major exchanges, remaining liquidity may concentrate on smaller, less reputable platforms with higher risks, or liquidity may effectively disappear entirely. Exchanges typically provide limited notice before delisting, giving holders little time to react.
Cross-Exchange Price Fragmentation and Arbitrage Inefficiencies: When a crypto-asset trades on multiple exchanges simultaneously, prices may diverge significantly across venues due to differences in liquidity, trading volumes, geographical user bases, or temporary technical issues. This price fragmentation can make it difficult for holders to determine a fair market price and may result in disadvantageous trading outcomes depending on which exchange they use. While arbitrage activity typically works to align prices across exchanges, inefficiencies in deposit and withdrawal processes, varying transaction fees, network congestion, or restrictions on inter-exchange transfers can delay or prevent effective arbitrage. Holders may find themselves unable to take advantage of better prices on other exchanges due to these friction costs and operational barriers.
Withdrawal Restrictions and Liquidity Constraints: Exchanges may impose restrictions on withdrawals through daily limits, minimum holding periods, enhanced verification requirements, or temporary suspensions during periods of high volatility or technical issues. Such restrictions can prevent token holders from accessing their assets when they need or wish to, particularly during market stress when many holders may simultaneously attempt to withdraw. Additionally, exchanges may require completion of extensive know-your-customer (KYC) procedures before permitting withdrawals, and holders who cannot or do not complete these procedures may find their assets effectively locked on the platform.
Exchange Selection and Counterparty Risk: The admission to trading on a crypto-asset exchange exposes token holders to risks associated with the specific exchange's operational practices, financial stability, and security measures. Exchanges vary significantly in their regulatory compliance, custody arrangements and track record. If a token is listed on exchanges with inadequate security, poor governance, or weak financial controls, holders face increased risks of losing their assets due to exchange insolvency, mismanagement, or fraud. Token holders who maintain their assets on exchanges rather than in self-custody wallets are particularly exposed to these counterparty risks, as they rely entirely on the exchange's ability and willingness to honor withdrawal requests and protect deposited assets.
Market Manipulation and Trading Irregularities: Crypto-asset exchanges, particularly those with lower trading volumes or less stringent oversight, may be susceptible to market manipulation activities including wash trading, spoofing, pump-and-dump schemes, and coordinated trading by groups of actors. Such manipulative practices can create artificial price movements that do not reflect genuine supply and demand, potentially misleading investors about a token's true market value and liquidity. Token holders may suffer losses if they make trading decisions based on manipulated price signals, or if they are unable to execute trades at expected prices due to artificial order book conditions.
Delisting and Trading Suspension Risk: Exchanges retain the discretion to suspend trading or delist crypto-assets based on their own policies, regulatory requirements, compliance concerns, or commercial decisions. A token may be delisted due to insufficient trading volume, regulatory developments, concerns about the project's legitimacy, technical issues, or changes in the exchange's listing criteria. Delisting or trading suspension can severely impact a token's liquidity and market value, as holders may find themselves with limited or no venues to trade their assets. In cases where a token is delisted from major exchanges, remaining liquidity may concentrate on smaller, less reputable platforms with higher risks, or liquidity may effectively disappear entirely. Exchanges typically provide limited notice before delisting, giving holders little time to react.
Cross-Exchange Price Fragmentation and Arbitrage Inefficiencies: When a crypto-asset trades on multiple exchanges simultaneously, prices may diverge significantly across venues due to differences in liquidity, trading volumes, geographical user bases, or temporary technical issues. This price fragmentation can make it difficult for holders to determine a fair market price and may result in disadvantageous trading outcomes depending on which exchange they use. While arbitrage activity typically works to align prices across exchanges, inefficiencies in deposit and withdrawal processes, varying transaction fees, network congestion, or restrictions on inter-exchange transfers can delay or prevent effective arbitrage. Holders may find themselves unable to take advantage of better prices on other exchanges due to these friction costs and operational barriers.
Withdrawal Restrictions and Liquidity Constraints: Exchanges may impose restrictions on withdrawals through daily limits, minimum holding periods, enhanced verification requirements, or temporary suspensions during periods of high volatility or technical issues. Such restrictions can prevent token holders from accessing their assets when they need or wish to, particularly during market stress when many holders may simultaneously attempt to withdraw. Additionally, exchanges may require completion of extensive know-your-customer (KYC) procedures before permitting withdrawals, and holders who cannot or do not complete these procedures may find their assets effectively locked on the platform.
I.2
Issuer-Related Risks
N/A - the Issuer is the same as the Person Seeking the Admission of the Token to Trading.
I.3
Crypto-Assets-related Risks
A non-exhaustive list of the risks relating to crypto-assets include:
Market Volatility Risk: Crypto-assets, including the Token, are subject to extreme price volatility that can result in significant and rapid changes in value. Unlike traditional financial instruments, crypto-asset markets operate continuously without circuit breakers or trading halts, meaning prices can fluctuate dramatically within short timeframes due to market sentiment, speculation, regulatory news, macroeconomic factors, or large trading volumes. Resultantly, holders of the Token may experience substantial losses in the Token's market value, and there is no guarantee that the Token will maintain any particular value or that holders will be able to sell their tokens at a price equal to or greater than their acquisition cost.
Liquidity Risk: There is no guarantee that an active, liquid secondary market for the Token will develop or be maintained. Even if trading venues list the token, liquidity may be limited, sporadic, or concentrated on specific platforms. Low liquidity can result in wide bid-ask spreads, making it difficult for holders to buy or sell tokens at desired prices without significantly impacting the market price. In extreme cases, holders may find themselves unable to exit their positions entirely, particularly during periods of market stress or if trading venues suspend or delist the token.
Regulatory and Legal Uncertainty: The regulatory landscape for crypto-assets is evolving rapidly and varies significantly across jurisdictions. While MiCA provides a regulatory framework within the European Union, other jurisdictions may impose different, conflicting, or more restrictive requirements. Changes in applicable laws and regulations could adversely affect the Token's utility, transferability, or value.
Loss of Private Keys and Irreversibility of Transactions: Crypto-assets are sometimes held in digital wallets controlled by cryptographic private keys. If a holder loses access to their private keys through theft, loss, or technical failure, they will permanently lose access to their Tokens with no possibility of recovery, as there is no central authority capable of restoring access or reversing transactions. Similarly, blockchain transactions are generally irreversible, meaning that tokens sent to an incorrect address or as a result of fraud or error cannot be recovered. Holders bear sole responsibility for implementing appropriate security measures to safeguard their private keys and wallet credentials, and failure to do so may result in total and permanent loss of their crypto-assets.
Cyber Security and Hacking Risk: Crypto-asset infrastructure, including exchanges, wallets, smart contracts, and blockchain networks, are targets for cyber-attacks, hacking attempts, and other malicious activities. Additionally, holders who use third-party wallets, exchanges, or custody services face risks associated with the security practices of those providers. Historical incidents in the crypto-asset industry have resulted in significant losses for token holders, and there is no guarantee that similar incidents will not occur in the future, potentially affecting token holders.
Market Volatility Risk: Crypto-assets, including the Token, are subject to extreme price volatility that can result in significant and rapid changes in value. Unlike traditional financial instruments, crypto-asset markets operate continuously without circuit breakers or trading halts, meaning prices can fluctuate dramatically within short timeframes due to market sentiment, speculation, regulatory news, macroeconomic factors, or large trading volumes. Resultantly, holders of the Token may experience substantial losses in the Token's market value, and there is no guarantee that the Token will maintain any particular value or that holders will be able to sell their tokens at a price equal to or greater than their acquisition cost.
Liquidity Risk: There is no guarantee that an active, liquid secondary market for the Token will develop or be maintained. Even if trading venues list the token, liquidity may be limited, sporadic, or concentrated on specific platforms. Low liquidity can result in wide bid-ask spreads, making it difficult for holders to buy or sell tokens at desired prices without significantly impacting the market price. In extreme cases, holders may find themselves unable to exit their positions entirely, particularly during periods of market stress or if trading venues suspend or delist the token.
Regulatory and Legal Uncertainty: The regulatory landscape for crypto-assets is evolving rapidly and varies significantly across jurisdictions. While MiCA provides a regulatory framework within the European Union, other jurisdictions may impose different, conflicting, or more restrictive requirements. Changes in applicable laws and regulations could adversely affect the Token's utility, transferability, or value.
Loss of Private Keys and Irreversibility of Transactions: Crypto-assets are sometimes held in digital wallets controlled by cryptographic private keys. If a holder loses access to their private keys through theft, loss, or technical failure, they will permanently lose access to their Tokens with no possibility of recovery, as there is no central authority capable of restoring access or reversing transactions. Similarly, blockchain transactions are generally irreversible, meaning that tokens sent to an incorrect address or as a result of fraud or error cannot be recovered. Holders bear sole responsibility for implementing appropriate security measures to safeguard their private keys and wallet credentials, and failure to do so may result in total and permanent loss of their crypto-assets.
Cyber Security and Hacking Risk: Crypto-asset infrastructure, including exchanges, wallets, smart contracts, and blockchain networks, are targets for cyber-attacks, hacking attempts, and other malicious activities. Additionally, holders who use third-party wallets, exchanges, or custody services face risks associated with the security practices of those providers. Historical incidents in the crypto-asset industry have resulted in significant losses for token holders, and there is no guarantee that similar incidents will not occur in the future, potentially affecting token holders.
I.4
Project Implementation- Related Risks
A non-exhaustive list of the risks associated with the Project's implementation include:
Centralisation and Foundation Control: The LayerDrone Foundation initially retains around half of the total token supply and controls critical aspects of the Protocol's governance, including sub-protocol parameters for mission creation, data verification, and storage processes. This significant concentration of control and token holdings creates risks that the Foundation may act in ways that are not aligned with the interests of other token holders or the broader community. Decisions regarding token distribution, mission reward structures, or protocol parameters could disproportionately benefit the Foundation or certain participants at the expense of others. That being said, the intention is that to transition governance to technical committees in due course.
Adoption and Network Effects Risk: The success of the LayerDrone Protocol depends critically on achieving sufficient adoption among drone pilots, data buyers, and Value-Added Providers to create a functional, liquid marketplace for geospatial imagery. If the Protocol fails to attract an adequate number of drone operators willing to capture and submit imagery, or if data buyers do not perceive sufficient value in the Protocol's offerings compared to alternative data sources, the network may fail to achieve the critical mass necessary for sustainability. Low adoption would result in limited mission availability, reduced
token utility, minimal transaction volume, and potentially render the Token valueless.
Mission Economics and Reward Sustainability: The Protocol's economic model relies on balancing token rewards for drone pilots with revenue from data buyers and the strategic allocation of the Foundation's token holdings. If the token rewards offered for completing missions are insufficient to cover pilots' operational costs, pilot participation may decline, reducing data capture and network utility. Conversely, if rewards are too generous relative to revenue generation, the Protocol may deplete its token reserves unsustainably, leading to inflation, token value decline, and eventual economic collapse.
Data Quality and Verification System Risk: The Protocol's value proposition depends on providing high-quality, verified, authentic geospatial imagery to data buyers. While the Protocol implements a proof-of-capture verification system that records metadata (timestamp, GPS location, file size) on-chain, this system may have limitations or vulnerabilities that could compromise data quality or authenticity. If the verification system proves inadequate or if data quality issues emerge systematically, buyer confidence in the Protocol would erode, reducing demand for imagery, depressing token value, and potentially causing network failure.
Technology Integration and Operational Complexity: The successful operation of the LayerDrone Protocol requires seamless integration of multiple complex technological components, including blockchain infrastructure (Base Layer 2), smart contracts, drone capture applications, data verification systems, storage solutions, NFT minting processes, and interfaces for pilots and data buyers. Failures, bugs, or incompatibilities in any of these components could disrupt Protocol operations, prevent mission completion, block reward distribution, or render captured data inaccessible. The Protocol's reliance on third-party infrastructure providers also creates dependencies that are outside the Protocol's direct control.
Governance Transition and Decision-Making Risk: While the plan is for governance to eventually transition from the Foundation to technical committees coordinated by token- holder governance, the specifics of this transition remain undefined and unconfirmed. Additionally, if token holders lack the technical expertise necessary to make informed decisions about complex sub-protocol parameters, governance outcomes may be suboptimal. Until governance mechanisms are fully specified and implemented, token holders face uncertainty about their ability to influence the Protocol's direction and protect their interests.
Centralisation and Foundation Control: The LayerDrone Foundation initially retains around half of the total token supply and controls critical aspects of the Protocol's governance, including sub-protocol parameters for mission creation, data verification, and storage processes. This significant concentration of control and token holdings creates risks that the Foundation may act in ways that are not aligned with the interests of other token holders or the broader community. Decisions regarding token distribution, mission reward structures, or protocol parameters could disproportionately benefit the Foundation or certain participants at the expense of others. That being said, the intention is that to transition governance to technical committees in due course.
Adoption and Network Effects Risk: The success of the LayerDrone Protocol depends critically on achieving sufficient adoption among drone pilots, data buyers, and Value-Added Providers to create a functional, liquid marketplace for geospatial imagery. If the Protocol fails to attract an adequate number of drone operators willing to capture and submit imagery, or if data buyers do not perceive sufficient value in the Protocol's offerings compared to alternative data sources, the network may fail to achieve the critical mass necessary for sustainability. Low adoption would result in limited mission availability, reduced
token utility, minimal transaction volume, and potentially render the Token valueless.
Mission Economics and Reward Sustainability: The Protocol's economic model relies on balancing token rewards for drone pilots with revenue from data buyers and the strategic allocation of the Foundation's token holdings. If the token rewards offered for completing missions are insufficient to cover pilots' operational costs, pilot participation may decline, reducing data capture and network utility. Conversely, if rewards are too generous relative to revenue generation, the Protocol may deplete its token reserves unsustainably, leading to inflation, token value decline, and eventual economic collapse.
Data Quality and Verification System Risk: The Protocol's value proposition depends on providing high-quality, verified, authentic geospatial imagery to data buyers. While the Protocol implements a proof-of-capture verification system that records metadata (timestamp, GPS location, file size) on-chain, this system may have limitations or vulnerabilities that could compromise data quality or authenticity. If the verification system proves inadequate or if data quality issues emerge systematically, buyer confidence in the Protocol would erode, reducing demand for imagery, depressing token value, and potentially causing network failure.
Technology Integration and Operational Complexity: The successful operation of the LayerDrone Protocol requires seamless integration of multiple complex technological components, including blockchain infrastructure (Base Layer 2), smart contracts, drone capture applications, data verification systems, storage solutions, NFT minting processes, and interfaces for pilots and data buyers. Failures, bugs, or incompatibilities in any of these components could disrupt Protocol operations, prevent mission completion, block reward distribution, or render captured data inaccessible. The Protocol's reliance on third-party infrastructure providers also creates dependencies that are outside the Protocol's direct control.
Governance Transition and Decision-Making Risk: While the plan is for governance to eventually transition from the Foundation to technical committees coordinated by token- holder governance, the specifics of this transition remain undefined and unconfirmed. Additionally, if token holders lack the technical expertise necessary to make informed decisions about complex sub-protocol parameters, governance outcomes may be suboptimal. Until governance mechanisms are fully specified and implemented, token holders face uncertainty about their ability to influence the Protocol's direction and protect their interests.
I.5
Technology-Related Risks
A non-exhaustive list of the risks associated with the technology used include:
Smart Contract Vulnerabilities and Exploits: The LayerDrone Protocol relies on smart contracts deployed on the Base Layer 2 blockchain to manage critical functions including mission creation, proof-of-capture verification, token rewards distribution, NFT minting, and potentially governance mechanisms. Smart contracts are immutable once deployed and may contain coding errors, logic flaws, or security vulnerabilities that could be exploited by malicious actors. Such vulnerabilities could enable unauthorised token minting, theft of tokens, manipulation of mission parameters, bypassing of verification systems, or other unintended behaviours that compromise the Protocol's integrity and cause financial losses to participants. While smart contracts can be audited before deployment, audits do not guarantee the absence of vulnerabilities, and even audited contracts have been successfully exploited.
Base Layer 2 Dependencies and Risks: The Token and LayerDrone Protocol are built on Base, a Layer 2 scaling solution for Ethereum. This creates dependencies on Base's ongoing operation, security, and performance. Layer 2 solutions introduce additional technical complexity compared to Layer 1 blockchains, including bridge mechanisms between layers, sequencer operations, and data availability guarantees. If Base experiences technical failures, security breaches, consensus issues, prolonged downtime, or network congestion, the LayerDrone Protocol's operations could be disrupted or suspended. Additionally, Base itself depends on Ethereum's Layer 1 for security guarantees, creating further dependency risks.
Blockchain Network Congestion and Transaction Costs: During periods of high network activity on Base, transaction costs (gas fees) can increase and transaction confirmation times may be delayed. Network congestion could also delay time-sensitive operations, degrading the Protocol's user experience and utility. While Layer 2 solutions like Base are designed to reduce transaction costs compared to Ethereum mainnet, they are not immune to congestion.
Token Standard and Interoperability Limitations: The Token is implemented as an ERC-20 token on Base, which means it inherits both the capabilities and limitations of this token standard. While ERC-20 provides broad compatibility with wallets and exchanges, it may not support certain advanced functionalities that could be beneficial for the Protocol's use cases going forward.
Data Storage and Availability Risks: While the Protocol stores proof-of-capture metadata on-chain, the actual drone imagery files are necessarily stored off-chain due to their size. If the off-chain storage systems experience failures, data corruption, provider insolvency, or loss of data, the nagery associated with minted NFTS could become permanently inaccessible despite the on-chain proof-of- apture existing. This would render the NFTs valueless and damage buyer confidence in the Protocol.
Smart Contract Vulnerabilities and Exploits: The LayerDrone Protocol relies on smart contracts deployed on the Base Layer 2 blockchain to manage critical functions including mission creation, proof-of-capture verification, token rewards distribution, NFT minting, and potentially governance mechanisms. Smart contracts are immutable once deployed and may contain coding errors, logic flaws, or security vulnerabilities that could be exploited by malicious actors. Such vulnerabilities could enable unauthorised token minting, theft of tokens, manipulation of mission parameters, bypassing of verification systems, or other unintended behaviours that compromise the Protocol's integrity and cause financial losses to participants. While smart contracts can be audited before deployment, audits do not guarantee the absence of vulnerabilities, and even audited contracts have been successfully exploited.
Base Layer 2 Dependencies and Risks: The Token and LayerDrone Protocol are built on Base, a Layer 2 scaling solution for Ethereum. This creates dependencies on Base's ongoing operation, security, and performance. Layer 2 solutions introduce additional technical complexity compared to Layer 1 blockchains, including bridge mechanisms between layers, sequencer operations, and data availability guarantees. If Base experiences technical failures, security breaches, consensus issues, prolonged downtime, or network congestion, the LayerDrone Protocol's operations could be disrupted or suspended. Additionally, Base itself depends on Ethereum's Layer 1 for security guarantees, creating further dependency risks.
Blockchain Network Congestion and Transaction Costs: During periods of high network activity on Base, transaction costs (gas fees) can increase and transaction confirmation times may be delayed. Network congestion could also delay time-sensitive operations, degrading the Protocol's user experience and utility. While Layer 2 solutions like Base are designed to reduce transaction costs compared to Ethereum mainnet, they are not immune to congestion.
Token Standard and Interoperability Limitations: The Token is implemented as an ERC-20 token on Base, which means it inherits both the capabilities and limitations of this token standard. While ERC-20 provides broad compatibility with wallets and exchanges, it may not support certain advanced functionalities that could be beneficial for the Protocol's use cases going forward.
Data Storage and Availability Risks: While the Protocol stores proof-of-capture metadata on-chain, the actual drone imagery files are necessarily stored off-chain due to their size. If the off-chain storage systems experience failures, data corruption, provider insolvency, or loss of data, the nagery associated with minted NFTS could become permanently inaccessible despite the on-chain proof-of- apture existing. This would render the NFTs valueless and damage buyer confidence in the Protocol.
I.6
Mitigation measures
The technology-related risks are, in part, mitigated given that an external security audit has been conducted, which identified eight risk vectors, all assessed as low or moderate in severity, with no high-risk vulnerabilities detected.
Additionally, a data verification system designed to guarantee that all captured imagery is authentic, traceable, and timestamped has been implemented. When a pilot submits data (images), an on-chain receipt records the metadata directly from the drone, including a timestamp of capture, GPS location, and file size taken directly from the capture app that was directing the drone. This metadata is used to verify the actual image files submitted to ensure pilots are not uploading invalid imagery. This system provides some mitigation against data authenticity and quality risks by creating an immutable, blockchain-based verification trail.
Following this, once a mission is successfully completed and the imagery is verified and approved, a non-fungible token is minted as proof. This serves as an immutable record of submission, verification, and approval, providing transparency and traceability, effectively creating an auditable trail of verified captures on the blockchain.
Additionally, a data verification system designed to guarantee that all captured imagery is authentic, traceable, and timestamped has been implemented. When a pilot submits data (images), an on-chain receipt records the metadata directly from the drone, including a timestamp of capture, GPS location, and file size taken directly from the capture app that was directing the drone. This metadata is used to verify the actual image files submitted to ensure pilots are not uploading invalid imagery. This system provides some mitigation against data authenticity and quality risks by creating an immutable, blockchain-based verification trail.
Following this, once a mission is successfully completed and the imagery is verified and approved, a non-fungible token is minted as proof. This serves as an immutable record of submission, verification, and approval, providing transparency and traceability, effectively creating an auditable trail of verified captures on the blockchain.
Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
J.1
Adverse impacts on climate and other environment- related adverse impacts
Base operates as a Layer-2 (L2) on Ethereum, developed with Optimism's OP Stack. It does not have its own consensus mechanism; instead, transactions are sequenced and bundled before being secured on Ethereum's proof-of-stake consensus. Incentives are driven by fee aggregation, reducing per-transaction costs and energy use. Estimated annual energy consumption is 1.43303 kWh, with 32.23% from renewable sources. Scope 1 emissions are 0.00000 tCO2e, Scope 2 emissions 0.00047 tCO2e, and overall GHG intensity per transaction is negligible. Calculations are based on a conservative bottom-up methodology using node-level assumptions, geo-location data, and benchmark datasets from Ember (2025) and the Energy Institute (2024).
Mandatory information on principal adverse impacts on climate and other environment-related adverse impacts of the consensus mechanism
S.1
Name
LayerDrone Inc.
S.2
Relevant legal entity identifier
2177449
S.3
Name of the crypto-asset
DRONE Token
S.4
Consensus Mechanism
Base is a Layer-2 (L2) solution on Ethereum that was introduced by Coinbase and developed using Optimism's OP Stack. L2 transactions do not have their own consensus mechanism and are only validated by the execution clients. The so-called sequencer regularly bundles stacks of L2 transactions and publishes them on the L1 network, i.e. Ethereum. Ethereum's consensus mechanism (Proof-of- stake) thus indirectly secures all L2 transactions as soon as they are written to L1.
S.5
Incentive Mechanisms and Applicable Fees
Base is a Layer-2 (L2) solution on Ethereum that uses optimistic rollups provided by the OP Stack on which it was developed. Transaction on base are bundled by a, so called, sequencer and the result is regularly submitted as an Layer- 1 (L1) transactions. This way many L2 transactions get combined into a single L1 transaction. This lowers the average transaction cost per transaction, because many L2 transactions together fund the transaction cost for the single L1 transaction. This creates incentives to use base rather than the L1, i.e. Ethereum, itself. To get crypto-assets in and out of base, a special smart contract on Ethereum is used. Since there is no consensus mechanism on L2 an additional mechanism ensures that only existing funds can be withdrawn from L2. When a user wants to withdraw funds, that user needs to submit a withdrawal request on L1. If this request remains unchallenged for a period of time the funds can be withdrawn. During this time period any other user can submit a fault proof, which will start a dispute resolution process. This process is designed with economic incentives for correct behaviour.
S.6
Beginning of the period to which the disclosed information relates
2025-09-25
S.7
End of the period to which the disclosed information relates
2026-09-25
Mandatory key indicator on energy consumption
S.8
Energy consumption
1.43303 kWh/a
Sources and methodologies
S.9
Energy consumption sources and methodologies
Since the crypto-asset is not yet been fully implemented at the time of writing the white paper, conservative estimates regarding the expected activity have been made.
For the calculation of energy consumption, the so-called 'bottom-up' approach is being used. The nodes are considered to be the central factor for the energy consumption of the network. The main determinants for estimating the hardware used within the network are the requirements for operating the client software. To determine the energy consumption of a token, the energy consumption of the networks Base is calculated first. For the energy consumption of the token, a fraction of the energy consumption of the network is attributed to the token, which is determined based on the activity of the crypto-asset within the network.
The information regarding the hardware used and the number of participants in the network is based on assumptions that are verified with best effort using empirical data. In general, participants are assumed to be largely economically rational. As a precautionary principle, we make assumptions on the conservative side when in doubt, i.e. making higher estimates for the adverse impacts.
For the calculation of energy consumption, the so-called 'bottom-up' approach is being used. The nodes are considered to be the central factor for the energy consumption of the network. The main determinants for estimating the hardware used within the network are the requirements for operating the client software. To determine the energy consumption of a token, the energy consumption of the networks Base is calculated first. For the energy consumption of the token, a fraction of the energy consumption of the network is attributed to the token, which is determined based on the activity of the crypto-asset within the network.
The information regarding the hardware used and the number of participants in the network is based on assumptions that are verified with best effort using empirical data. In general, participants are assumed to be largely economically rational. As a precautionary principle, we make assumptions on the conservative side when in doubt, i.e. making higher estimates for the adverse impacts.
Supplementary information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism
S.10
Renewable energy consumption
32.2255486008 %
S.11
Energy intensity
0.00000 kWh
S.12
Scope 1 DLT GHG emissions - Controlled
0.00000 tCO2e/a
S.13
Scope 2 DLT GHG emissions - Purchased
0.00047 tCO2e/a
S.14
GHG intensity
0.00000 kgCO2e
Sources and methodologies
S.15
Key energy sources and methodologies
To determine the proportion of renewable energy usage, the locations of the nodes are to be determined using public information sites, open-source crawlers and crawlers developed in-house. If no information is available on the geographic distribution of the nodes, reference networks are used which are comparable in terms of their incentivization structure and consensus mechanism. This geo-information is merged with public information from Our World in Data, see citation. The intensity is calculated as the marginal energy cost wrt. one more transaction. Ember (2025); Energy Institute - Statistical Review of World Energy (2024) - with major processing by Our World in Data. "Share of electricity generated by renewables - Ember and Energy Institute" [dataset]. Ember, "Yearly Electricity Data Europe"; Ember, "Yearly Electricity Data"; Energy Institute, "Statistical Review of World Energy" [original data]. Retrieved from https://ourworldindata.org/grapher/share-electricity- renewables.
S.16
Key GHG sources and methodologies
To determine the GHG Emissions, the locations of the nodes are to be determined using public information sites, open- source crawlers and crawlers developed in-house. If no information is available on the geographic distribution of the nodes, reference networks are used which are comparable in terms of their incentivization structure and consensus mechanism. This geo-information is merged with public information from Our World in Data, see citation. The intensity is calculated as the marginal emission wrt. one more transaction. Ember (2025); Energy Institute - Statistical Review of World Energy (2024) - with major processing by Our World in Data. "Carbon intensity of electricity generation - Ember and Energy Institute" [dataset]. Ember, "Yearly Electricity Data Europe"; Ember, "Yearly Electricity Data"; Energy Institute, "Statistical Review of World Energy" [original data]. Retrieved from https://ourworldindata.org/grapher/carbon-intensity- electricity Licenced under CC BY 4.0.