Classification assessment: documents to prepare
A classification assessment sets the token's regulatory category before any public offer or listing goes live. Preparing the right documents in advance shortens the review and protects the launch date. This page lists what to prepare, who reviews it, and where the process stops being reversible.
Why the assessment exists
The assessment decides whether a token falls inside a regulated category or sits outside it. That decision changes which disclosures the issuer must publish, which internal sign-offs are required, and how much lead time the launch needs. Nothing in this stage is optional once a token is offered to the public or admitted to a trading venue.
The output is not a badge or a certificate. It is a written classification memo that the issuer keeps on file and updates whenever the token's design or its use case changes.
Documents to prepare
The table below groups the documents by what they prove. Missing a document does not stop the intake, but it slows the first review and pushes the timeline back.
| Document | What it establishes | Prepared by |
|---|---|---|
| Draft whitepaper or offering description | What the token does and who holds rights against whom | Issuer's product and legal team |
| Technical description of the token mechanism | How value is created, transferred and, if applicable, redeemed | Technical lead |
| Reserve or backing description, if the token references an asset | What stands behind the token and how it is held | Finance function |
| Corporate and beneficial-ownership records | Who controls the issuing entity | Corporate secretary |
| AML and KYC intake file | Identity and risk profile of the issuer and key counterparties | Compliance function |
| Prior classification memos for related tokens | Consistency with earlier decisions on similar designs | Legal team |
How the stages run
Intake opens once the draft whitepaper and the technical description arrive. Reviewers read both before asking follow-up questions, so an incomplete first submission usually costs a second round rather than saving time.
- Send the draft whitepaper and technical description to the reviewing team.
- Answer the follow-up questionnaire on reserve structure and control, if it applies to the design.
- Provide the corporate and AML files once the design questions are settled.
- Receive the draft classification memo and confirm the facts it relies on.
- Sign off on the final memo before any public communication about the token goes out.
A first review of a complete file usually finishes within a week. A file that arrives in stages takes longer, because each missing piece reopens the reviewer's queue.
Who decides
The classification memo is drafted and approved internally, by the team responsible for the token programme. It is not a request for a ruling from a regulator. If the design raises a genuine open question, the team may seek informal guidance from the competent national supervisor, but that is the exception, not the default path.
Internal sign-off sits with whoever holds authority over the launch decision — typically general counsel or an equivalent role, not the product team that drafted the whitepaper.
Two situations that change the file
If the token references a basket of assets or aims to hold a stable value, the file needs the reserve documents described separately, and the assessment cannot close without them.
If a counterparty or partner declines to confirm information the memo relies on, the file stays open. The team notes the gap, states what could not be verified, and decides whether the launch proceeds with that gap disclosed or waits for confirmation.
If the assessment concludes the token falls outside any regulated category, the file still closes with a signed memo — the absence of a category is itself a finding that needs a paper trail.
The point of no return
Once the whitepaper is published or the token is offered to the public, the classification underlying that offer cannot be quietly revised. A change in design or use case after that point requires a fresh assessment and, usually, a new or amended whitepaper. Treat the sign-off in step five as the last moment for a cost-free correction.
What this page does not cover
This page does not verify a specific counterparty, a specific document, or a specific jurisdiction's registers — those checks sit in separate reports built for that purpose. For a sense of what a counterparty check can establish in that jurisdiction, see Counterparty in Estonia and its limits.
For how far a document verification can be pushed before it reaches its own limit, see Document in Poland and its limits.
For a jurisdiction-level view of what public registers actually show, see Jurisdiction in Sweden.
Related publications
Tokens that reference external assets move on to a separate document set once classification closes. See Reserve evidence and attestation step by step for the list at that stage.
Verified
This procedure reflects our intake protocol as reviewed on 3 June 2025. It describes an internal process and does not restate the text of any regulation. For how we label and tier sources across the site, see Sources by tier and delivery route overview.
FAQ
How long does classification assessment take in practice?
A complete file usually clears the first review within a week. Files submitted in stages, or files raising a genuine open question that needs informal guidance, take longer. The timeline is set by how complete the intake documents are, not by a fixed calendar rule.
Which documents are needed to start?
Intake opens with the draft whitepaper and the technical description of the token mechanism. Reserve documents, corporate records, and the AML file follow once the design questions are settled. Starting with an incomplete pair of documents is possible but usually costs a second round of questions.
What happens if the other side does not respond?
If a counterparty or partner does not confirm information the memo relies on, the file does not close silently. The team records the gap, states what remains unverified, and decides whether to disclose that gap and proceed or to wait for a response before sign-off.