Notification to the supervisor: documents to prepare
A notification to the supervisor is the filing that lets a token issuer signal, before any public offering begins, that a required document set exists and is complete. The file typically covers governance, the token description, and a summary of the intended market. How well that file is prepared decides whether the notification moves without friction or stalls on requests for clarification.
Why the notification exists
A notification gives the supervisor visibility over a new token offering before marketing starts. The supervisor does not pre-approve the token itself. It registers the filing and checks that the mandatory elements of the file are present and internally consistent.
This mechanism applies across the EU, though the authority that receives the file differs by member state. The logic stays the same everywhere: the file must exist and be complete before the clock on marketing can start.
What changes once the file is complete
Before the notification is filed, nothing about the offering is fixed in a formal sense. Drafts can change freely, and no external party is watching the timeline.
Once the file is submitted, the position shifts. The supervisor holds a record of what was filed and when. Any later change to the token description or the marketing materials typically requires a fresh submission, not a quiet edit. This is the practical point of no return: submission, not launch, is what fixes the file.
How the file is structured
Internally, a notification file is built as a set of linked components rather than a single document. One component establishes who is behind the offering and how decisions inside the issuing entity are made. A second component describes the token itself: its mechanics, its rights (if any), and how it is expected to trade. A third component covers the market-facing side — the draft marketing materials and the audience they target.
Each component is drafted separately and then checked against the other two for consistency. A mismatch between the governance component and the marketing draft is the single most common reason a file is sent back for revision.
What to prepare, step by step
- The issuer's internal team drafts the governance component first, since every other document refers back to it.
- Legal counsel reviews the token description for consistency with what the marketing team plans to say publicly.
- The compliance officer assembles the identification and contact file for the entity making the filing.
- Counsel checks the draft marketing materials against the token description for contradictions before anything is shown externally.
- The compliance officer compiles the full file into the format the supervisor accepts and logs the submission date.
- The team keeps a dated copy of everything submitted, including any cover letter, for its own records.
| Document | Purpose | Owner inside the team |
|---|---|---|
| Governance file | Shows who controls the issuing entity and how decisions are made | Legal counsel |
| Token description | Explains the mechanics and expected trading behaviour of the token | Product or technical lead |
| Marketing draft | Sets out what will be shown to the public before it is published | Marketing lead, reviewed by counsel |
| Contact and identification file | Identifies the filing entity and its point of contact for the supervisor | Compliance officer |
| Submission log | Records the date and format of what was filed, for internal reference | Compliance officer |
Who reviews the notification
The national supervisor responsible for crypto-asset markets in the issuer's home member state receives and registers the filing. Inside the supervisor, an intake team checks the file for completeness before it reaches a technical reviewer.
There is no single published maximum length for this review. Timing depends on how complete the file is on first submission and on the supervisor's own queue at the time. A file that needs correction restarts part of the clock, which is the main reason preparation matters more than speed of filing.
Common branches
If the issuer already operates an authorised entity in another EU member state, the governance file should reference that authorisation directly rather than restating it from scratch.
If the token offering relies on an outsourced custody arrangement, the file needs a separate section describing that arrangement and who is accountable for it.
If the marketing plan targets retail buyers rather than professional investors, the marketing draft typically needs additional risk language before it can be submitted.
What this page does not cover
This page covers preparation of the notification file. It does not cover what happens after the supervisor acknowledges receipt, and it does not cover the separate marketing review step, which has its own document set.
The file described here does not, by itself, establish who counts as a counterparty for related due-diligence purposes. Readers working through the counterparty side in a specific jurisdiction can see how that question is scoped in Counterparty in Latvia and its limits.
Where the notification file references a supporting document that itself needs verification, the scope of what can be checked is described separately in Document in Sweden and its limits.
Where the offering touches more than one EU jurisdiction, the boundaries of a jurisdiction check are set out in Jurisdiction in Denmark and its limits.
Related guidance
The step that follows notification, once the file has been acknowledged, is the marketing review. That process and its own document set are covered in Marketing review step by step.
For background on how this practice is scoped and where its limits sit, see About the firm and its scope in practice.
Verified
This page was last checked against current supervisory notification practice for token issuers operating within the EU. It describes procedure and sequencing only; it does not cite specific legal provisions, since the national implementing detail for each supervisor is not yet fully mapped in our records.
FAQ
How long does notification to the supervisor take in practice?
There is no fixed statutory maximum for this step. Duration depends on how complete the file is when first submitted and on the supervisor's own queue. Teams that submit a fully cross-checked file tend to move through review noticeably faster than teams that submit early drafts.
Which documents are needed to start?
At minimum, the governance file, the token description, the draft marketing materials, and the contact and identification file for the filing entity. A submission log is not mandatory but is strongly advisable for internal tracking.
What happens if the other side does not respond?
If the supervisor does not acknowledge a filing within a reasonable period, the compliance officer should contact the intake team directly and request a status update, citing the submission date from the internal log. Keeping a dated copy of the original filing makes this follow-up straightforward.