Reserve evidence and attestation: documents to prepare
Reserve evidence and attestation is the stage where an issuer proves that tokens in circulation are backed by real, identifiable assets. The file needs a reserve ledger, custody confirmations, an engagement letter with an independent attestor, and a signed management representation. Once the attestor locks the reporting period, the figures cannot be quietly adjusted — only re-issued through a new attestation cycle.
What this stage covers
The stage sits between internal bookkeeping and external submission. It converts an issuer's own records into a document that a third party — the attestor — is willing to sign. The attestor does not audit the whole business. The attestor checks whether the stated reserve exists, where it is held, and whether it matches the number of tokens outstanding on a given date.
Two documents carry the weight of the whole package: the reserve ledger and the attestation report. Everything else supports one of these two.
What changes once the file is open
Before the file is opened, reserve figures are internal and can be revised freely. After the attestor accepts the engagement and sets a cut-off date, the numbers for that date are frozen. A revision after the cut-off is not a correction — it is a new engagement, with its own timeline and its own fee discussion.
This is the practical point of no return referenced in the title. Teams that treat the cut-off as a soft deadline usually lose a full cycle re-doing reconciliation that could have been finished before the freeze.
What to prepare, step by step
- Finance team assembles the reserve ledger: every asset backing the tokens, its custodian, and its value on the proposed cut-off date.
- Finance team gathers custody confirmations directly from each custodian or bank holding reserve assets, dated to the same cut-off.
- Management signs a representation letter confirming that the ledger is complete and that no undisclosed liabilities reduce the reserve.
- Legal or compliance lead selects an independent attestor and signs an engagement letter defining scope, cut-off date, and reporting format.
- Attestor tests the ledger against custody confirmations, reconciles differences, and issues the attestation report.
- Compliance lead files the attestation report as part of the wider notification package sent to the supervisor.
Documents to prepare
| Document | Purpose | Prepared by |
|---|---|---|
| Reserve ledger | Lists every asset backing outstanding tokens, with values as of the cut-off date | Issuer's finance team |
| Custody confirmations | Independent proof that named assets are held where the ledger says they are held | Custodian or bank |
| Engagement letter | Defines the scope and cut-off date of the attestation | Issuer and attestor jointly |
| Management representation letter | Confirms completeness of disclosed reserve data | Issuer's management |
| Reconciliation schedule | Shows how any gap between ledger and confirmations was resolved | Finance team, reviewed by attestor |
| Attestation report | The signed output submitted onward as part of the notification file | Attestor |
Who decides and how long it takes
No single body approves the attestation itself — it is a professional opinion, not a permit. What matters procedurally is who accepts it downstream and on what timetable.
| Decision point | Who is involved | Typical timeframe |
|---|---|---|
| Scope and cut-off date | Issuer and attestor, agreed at engagement | Set before work begins, rarely revisited |
| Acceptance of custody confirmations | Attestor | Depends on how many custodians must respond |
| Sign-off on the attestation report | Attestor, based on completed testing | Follows once all confirmations are in hand |
| Use of the report in a notification package | Supervisor receiving the wider filing | Reviewed together with the rest of the file |
Common forks
- If a custodian is slow to confirm balances, the cut-off date can still hold, but the attestor's report will note the outstanding item until it clears.
- If reserve assets sit across more than one custodian or more than one jurisdiction, expect the reconciliation schedule to take noticeably longer than the ledger itself.
- If a discrepancy appears between the ledger and a confirmation, the attestor will not sign until the issuer explains and documents the difference.
Where this page stops — and where the reports pick up
This page describes the sequence of documents and the roles behind them. It does not tell you which custodians are reliable in a given country, nor how a specific counterparty behaves once contacted for confirmation.
For the practical limits of working with a specific counterparty, see Counterparty in Estonia and its limits.
For what a given document type can and cannot establish once it reaches the wrong desk, see Document in Czechia and its limits.
For how far a jurisdiction search can be pushed before the answer stops being reliable, see Jurisdiction in Finland and its limits.
Verified
This description reflects current practice in reserve evidence and attestation files handled at this stage of token issuance. It does not name a specific statute, since procedural detail of this kind sits outside individual acts and inside supervisory expectation and market practice. Review date: current at time of publication.
For a sense of how much of our own process is tracked and published rather than left to memory, see Delivery statistics, published automatically in detail.
Related reading
Once reserve evidence and attestation is complete, the next document-heavy stage is the filing itself: see Notification to the supervisor step by step.
FAQ
How long does reserve evidence and attestation typically take?
Most files move from engagement letter to signed report within a few weeks. The variable is custody confirmations: a single custodian answers quickly, several custodians across jurisdictions rarely do.
Which documents do we need before we can start?
Start with the reserve ledger and a list of every custodian holding reserve assets. Without these two, an attestor cannot even scope the engagement letter.
What happens if a custodian does not respond?
The attestor cannot sign an unqualified report on an unconfirmed balance. The cut-off date can still be used, but the report will flag the item as outstanding until confirmation arrives, and the issuer's file stays open longer than planned.
Reserve evidence and attestation rewards preparation more than speed. A ledger built before the attestor is engaged saves more time than any amount of chasing afterwards.