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Post-issue reporting: stages and deadlines

Post-issue reporting starts once issuance closes and runs through several fixed stages, each carrying its own deadline. Missing a stage can trigger removal from the public register or an information request, not a halt to trading. This page sets out the stages, the documents each one needs, and the point after which a filing can no longer be withdrawn.

What "post-issue" reporting covers

The duty to report after issuance is not a new application. It continues the same file the issuer opened when the offering document was first prepared. Whatever body reviewed that document at the start is the body that receives the reports afterwards, and it works from the figures the issuer already committed to.

For the earlier stage of that file, see Offering document preparation step by step. Post-issue reporting picks up where that stage ends: at the moment the offer closes.

Stages, in order

Six stages run in sequence. None can be skipped, and the fourth cannot be shortened by the issuer's own timetable.

StageWhat happensHow the deadline is set
1. Closing confirmationInternal sign-off that the offer has ended, with a final count of tokens allocated.Fixed by the issuer's own offering document.
2. Notification to the authorityA short filing confirming the close and the headline figures.Deadline follows from the authority's own procedural rules.
3. Post-issuance reportA detailed report: proceeds raised, number of holders, use of funds so far.Submission window is published in the authority's guidance, not negotiated.
4. Authority reviewThe authority checks the report against the original offering document.No fixed length; the authority can pause the clock by requesting more information.
5. Periodic reportingRecurring updates for as long as the token is publicly offered or traded.Cycle is set by the authority's own supervisory calendar.
6. Point of no returnOnce a periodic report is accepted, the earlier closing report cannot be withdrawn.Correction only through a formal amendment procedure, not a resubmission.

What changes once issuance closes

Before closing, the file is still open in the sense that figures can move. Allocations can shift, and the offering document can absorb small adjustments without formal correction. After closing, that flexibility ends. Every number in the post-issuance report is treated as final, and a later change needs its own filing rather than a quiet edit.

This is also where risk shifts from the offering itself to how the issuer keeps records. An authority that finds a mismatch between the closing report and the periodic reports that follow does not usually ask why; it asks for the underlying working papers. Whether those papers exist and match is decided long before the request arrives.

What to do

  1. Have the person responsible for the issuance sign off the final allocation figures before anything else is filed.
  2. Send the closing notification within the window set by the authority's own rules, not the issuer's internal calendar.
  3. Assemble the post-issuance report from the same underlying ledger used for the offering document, not from a fresh reconciliation.
  4. Keep the working papers behind every figure in the report, separately from the report itself.
  5. Confirm receipt of the authority's acknowledgment before assuming the stage is closed.
  6. Set an internal reminder for the first periodic reporting date the moment the acknowledgment arrives.

Who decides and by when

The authority that reviewed the original offering document is the forum for every stage that follows. It sets its own submission windows and publishes them in its own guidance rather than in the issuer's timetable. It can extend the review stage by requesting further information, and that request itself resets the clock rather than adding a fixed number of days to it.

There is no separate right of first response from the authority the way there is with a private adviser. If a report is queried, the reply goes back through the same channel the original filing used, and a new submission does not open a new file.

If your situation differs

If the issuance closed on schedule and no allocation changed afterwards, the six stages run as listed and the first periodic report is the next real deadline. If a small allocation correction is needed after closing, it goes into the closing notification, not into the post-issuance report, and it must be flagged before that report is filed. If the authority raises a query during review, the periodic reporting clock does not start until the query is resolved, so treat the query as the priority over any other deadline running in parallel.

What this page does not cover

This page describes the sequence and the deadlines. It does not size the underlying risk of getting a stage wrong, and it does not check a specific counterparty, document or jurisdiction against the file. Those are separate, narrower checks with their own scope.

For the risk of appointing the wrong developer before this sequence even starts, see Counterparty report before appointing a developer.

For the risk in the wording of the report itself before it is filed, see Document report before filing with an office.

For situations where the deadline itself is unclear because local practice varies, see Jurisdiction report when a deadline depends on local practice.

Related reading

The stage before this one is covered separately, with the same level of detail on documents and decision-makers: Offering document preparation step by step is the natural companion to this page.

Verified

Checked against current administrative guidance published by the competent authorities for token issuance. Reviewed 14 February 2025. Underlying working papers referred to above are handled under our own retention practice: see Retention: the report, the extracts and our copy and for how long we keep the file after a stage closes.

FAQ

How long does post-issue reporting take in practice?
The closing notification and post-issuance report each have a fixed submission window set by the authority. Review afterwards has no fixed length, since a request for further information can pause it. Periodic reporting then runs on a recurring cycle for as long as the token remains publicly offered.

Which documents are needed to start?
The final allocation figures, the working papers behind them, and the original offering document for cross-reference. Without the working papers, the report cannot be assembled to the standard the authority expects on review.

What happens if the other side does not respond?
If the authority does not acknowledge a filing within its usual window, the stage is treated as still open. Do not assume closure and move to the next stage; confirm receipt first, since periodic reporting deadlines run from that acknowledgment, not from the date of submission.

If a filing under this sequence has already been refused and an appeal deadline is now running, the next step is time-sensitive: see When an appeal deadline follows a refusal in detail.

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