Offering document preparation: what the decision maker looks at
The decision maker checks three things: whether the offering document describes the token as it actually works, whether every material claim carries supporting evidence, and whether the risk section covers redemption, custody and transfer restrictions in full. A document that fails any one of these checks returns to drafting before it reaches sign-off.
What this review actually tests
The offering document reaches this stage only after classification closes. Classification tells you what kind of token you have. This review tells you whether the document tells the truth about it. The check is not about style or polish.
It is about consistency between the mechanics you describe, the rights you promise and the risks you disclose. A drafting team writes the first version from the technical specification and the commercial terms. The decision maker reads it against both, line by line, looking for gaps rather than errors of grammar.
What changes once the review starts
The consequence of a failed review is time, not liability. Each return cycle adds a full drafting round. A file with three open comments after the first pass typically loses a working week before the next review slot opens.
The second consequence is sequencing. Token issuance work moves in one direction: once the offering document is approved, marketing and distribution start using it as the reference text. Reopening it after that point means reworking everything built on top of it, not just the document itself.
What to do
| Step | Who does it | What is checked |
|---|---|---|
| Compile the working draft | Drafting team | Match between the draft and the technical specification |
| Attach supporting evidence | Legal counsel | Each claim backed by a document, not by memory |
| Run the internal consistency pass | Compliance officer | Same facts stated the same way throughout the file |
| Send the file for decision-maker review | Compliance officer | Complete file submitted, not a partial draft |
| Close every open comment | Drafting team | Comments resolved, not merely acknowledged |
| Confirm sign-off | Decision maker | Final version locked before distribution starts |
If part of the drafting work sits with an external partner, check how that engagement is structured before the file reaches review — see Subprocessors, including local delivery partners overview.
Who decides
The decision maker is whoever holds sign-off authority inside your organisation for this file. In most structures that is a senior compliance officer or a designated board member. They decide alone or in a short review committee, and the review itself usually takes between two and five working days once the file is complete.
A file that arrives incomplete is not queued for later attention. It is returned immediately, and the clock on the review period only starts once every required piece is in place.
Two or three scenarios
If you are issuing a single token type in one jurisdiction, the review usually runs once and closes within a week of the file becoming complete.
If you are issuing several token types under one programme, each type is reviewed separately. The risks differ even when the wording across documents looks similar.
If a service provider drafted parts of the document, the decision maker checks that provider's output with the same rigour applied to an in-house draft. No section is waived because of who wrote it.
What this page does not cover
This page describes the internal review step at the drafting stage. It does not price the counterparty risk you take on once you extend credit against this token; that question sits in a separate file, Counterparty report before extending credit.
It also does not measure how much weight this document carries once a dispute starts. That question is answered in Document report before relying on it in a dispute.
And it does not cover what changes when the underlying register sits in a jurisdiction you do not know well. That gap is closed separately in Jurisdiction report when a register is unfamiliar.
Related reading
The stage that precedes this one is covered on its own page: Classification assessment step by step. Read it first if classification has not closed yet.
Verified
Verified: 14 February 2025. This page describes internal procedural practice for offering document review at the drafting stage. No statutory citation applies to this description, and none is claimed here; the steps, roles and timing reflect how the review is run in practice, not a rule found in any single act.
FAQ
How long does offering document preparation take in practice?
A straightforward file closes within one to two review cycles, roughly one to three weeks from first draft to sign-off. A file that comes back with open comments after the first pass adds a full cycle for each round of correction.
Which documents are needed to start?
You need the technical specification of the token, the commercial terms of the offering, and the evidence file supporting each claim you intend to make. Without these three, the drafting team cannot produce a version the decision maker will accept for review.
What happens if the other side does not respond?
If a counterparty or partner needed for supporting evidence does not respond within the agreed window, the file stays open rather than moving forward on an assumption. The review does not proceed on an unconfirmed claim, and the missing piece is recorded in writing against the sign-off record.