Beyond the Baseline: Five Standards We Believe a Serious Crypto Project Should Meet

In the first piece in this series, we looked at MiCA and the shape of Europe’s new crypto rules. For crypto-assets within its scope, MiCA sets a legal baseline. Meeting that baseline does not, on its own, tell you whether a project is well run. That gap is worth thinking about. A project can satisfy its legal obligations and still be opaque, fragile, or poorly governed. So the more useful question, for a holder or an observer, is not only whether a project meets the rules, but whether it holds itself to standards the rules do not require. What follows are five such standards. They are our own — the benchmarks we apply at Dohrnii — and not official MiCA requirements. We offer them as a way of thinking about the projects you come across, ours included. Where the legal baseline sits It helps to be precise about what MiCA actually obliges. Where a project makes a public offer of an “other” crypto-asset, it is generally required to prepare a crypto-asset white paper, notify it to a national regulator, and communicate about the asset in a way that is fair, clear, and not misleading. Certain limited or restricted offers can be exempt. One point deserves emphasis, because it is routinely misread: notifying a white paper is not the same as having it approved. No EU authority signs off on the project or certifies that the document is accurate. Notification does not shift responsibility for the white paper to the regulator. Compliance with MiCA is a legal baseline; it is not a quality rating. Everything below sits above that baseline. 1. Transparency that goes further than required Disclosure is the starting point. Beyond any mandated document, a serious project makes it straightforward to find out who is behind it, how the asset actually works, and where the risks lie. When basic information is hard to locate, that absence tells you something in itself. 2. Independent security audits A crypto-asset ultimately runs on code, and code can contain flaws. An independent security audit — carried out by a firm with no stake in the result — is an established way of identifying them. What matters is not only that an audit was commissioned, but that its findings are addressed and the report made available for others to read. This is a matter of practice rather than law. For the type of token offering discussed here, MiCA does not generally require an independent smart-contract security audit. 3. The capacity to adapt Rules and standards change, and a token that cannot change with them is at a disadvantage. A contract built to be upgraded — carefully, with each change subject to review — can make it easier to respond to new requirements or introduce new functionality as standards evolve. This is a design choice a project makes for itself, not an obligation MiCA imposes. In our view it is one of the more consequential ones. 4. Governance that is legible Where a contract concentrates power — the ability to upgrade it, to pause it, to restrict particular addresses — holders should be able to understand how that power is held and used. Who can act? Under what conditions? With what checks in place? Clear answers, documented in public, are the mark of a project that expects to be held to account. Ambiguity on these questions should be read as a warning rather than a detail. 5. Compliance treated as design, not decoration The projects that adjust most effectively to a regulated market are those that treat compliance as part of their infrastructure rather than as a box-ticking exercise. As standards evolve, that also means being willing to adapt legacy systems responsibly and transparently. This is less a single feature than a disposition: a readiness to document, to disclose, and to meet a standard before circumstances force the issue. Preparing early None of these standards is exotic. They represent our own benchmarks rather than a checklist imposed by MiCA. Taken together, they describe a project that treats the present moment seriously — one preparing for the direction the market is moving in, rather than waiting to be pushed. We hold this list up to ourselves as much as to anyone else. In the pieces that follow, we will keep coming back to what these standards look like in practice. — Dohrnii Labs This article is for educational and informational purposes only and is not financial, investment, or legal advice. The standards described are Dohrnii’s own views and do not represent official MiCA requirements. Regulatory frameworks evolve; always verify current requirements with official sources. Sources & further reading European Securities and Markets Authority (ESMA) — Markets in Crypto-Assets Regulation (MiCA): https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica Regulation (EU) 2023/1114 (MiCA), Title II — crypto-asset white papers for “other” crypto-assets Regulation (EU) 2023/1114 (MiCA), Article 7 — fair, clear and not misleading marketing communications

MiCA Explained: Europe’s New Rulebook for Crypto-Assets

A clear guide to the European Union’s crypto regulation and what it means for those who hold digital assets. For much of crypto’s history, a basic question went unanswered in Europe: which rules actually applied. Treatment varied from one member state to the next, supervision was uneven, and when a project failed or an exchange withdrew from the market, accountability was often unclear. That situation has now changed. The European Union has established a single legal framework for crypto-assets, and as of this year it applies in full. It is known as MiCA. For anyone who trades, holds, or issues crypto-assets, understanding what the framework does is worth the effort. What follows is a straightforward account of its main provisions. What is MiCA? MiCA is the Markets in Crypto-Assets Regulation, formally Regulation (EU) 2023/1114. It is the European Union’s first attempt to govern crypto-assets through a single set of rules rather than the divergent national regimes that preceded it. As a regulation rather than a directive, MiCA takes direct effect across all member states without requiring separate national transposition. The result is one consistent regime for issuing crypto-assets and for the firms that provide crypto-asset services throughout the EU. Its objectives are conventional for financial legislation: protecting consumers, improving transparency in a market that had little of it, supporting financial stability, and giving legitimate projects a defined legal route to operate. The three categories of crypto-assets MiCA does not treat all tokens identically. Within the scope of assets it covers, it distinguishes three principal categories. E-money tokens (EMTs) are designed to maintain a stable value by referencing a single official currency; a euro- or dollar-denominated stablecoin is the standard example. Asset-referenced tokens (ARTs) also aim for stability but reference a wider base, such as a basket of currencies, a commodity like gold, or a combination of assets. The third and broadest category, described as “other” crypto-assets, accounts for most of the market. It includes utility tokens, governance tokens, and unbacked assets such as bitcoin and ether. Two exclusions are worth noting. Non-fungible tokens, and any instrument that already qualifies as a financial instrument under existing EU markets law, fall outside MiCA and remain subject to separate rules. MiCA is already in force: the timeline The framework is not prospective; it has taken effect in stages. MiCA entered into force on 29 June 2023. The provisions governing stablecoins — the ART and EMT rules — applied first, from 30 June 2024, reflecting the view that stablecoins presented the most immediate risk to the wider financial system. The remainder of the framework applied from 30 December 2024, including the authorisation regime for crypto-asset service providers (CASPs) and the rules on public offers of “other” crypto-assets. A transitional period completed the rollout. Firms already operating lawfully under national regimes were granted time — up to eighteen months, and less in several member states — to obtain full MiCA authorisation. That period ended on 1 July 2026. Beyond that date, providing crypto-asset services to EU clients without authorisation is no longer a transitional matter but a breach of EU law. What MiCA requires from projects For issuers and offerors of crypto-assets in the EU, MiCA introduces substantive obligations. Two are particularly relevant from a holder’s perspective. The first concerns the white paper. An issuer making a public offer of an “other” crypto-asset must prepare a crypto-asset white paper and notify it to a national competent authority (NCA), the financial regulator of an EU member state. The document is not promotional material: the issuer bears legal responsibility for its content, which must set out standardised and accurate information on the asset and its risks. Certain smaller or genuinely private offers may be exempt. One distinction is frequently misunderstood: notification is not approval. No EU authority endorses the project or confirms the accuracy of the white paper, and responsibility remains with the issuer. The second concerns the public register. Under Articles 109 and 110, the European Securities and Markets Authority (ESMA) maintains a central register of notified white papers, authorised service providers, and entities identified as non-compliant, drawing on data supplied by the national regulators. Only firms authorised and listed in the register may lawfully provide crypto-asset services in the EU. Inclusion, however, should not be read as a mark of quality. It confirms that a document has been filed, not that any authority has reviewed or endorsed the underlying project. ESMA currently operates this as an interim register of downloadable files, pending full integration into its systems during 2026. A further requirement applies to service providers. Exchanges, custodians, and other CASPs must be authorised by a national regulator; once authorised, they may passport that authorisation across the EU under a single licence covering all member states. What MiCA means for you as a holder The practical effect for holders is straightforward. A question that was previously difficult to resolve now has a basis for an answer: whether a given project, and the platform used to access it, operates within the applicable rules. Part of that assessment can be carried out directly. Is the provider authorised and listed in the ESMA register? Has the project filed a white paper? Is there clarity on who is responsible for it and how the asset functions? Diligence of this kind was largely a matter of guesswork until recently. It is becoming a standard step. Projects that treat the framework as an opportunity rather than an imposition are positioning themselves for the longer term. Those that disregard it face a narrowing space in which to operate. And across the Atlantic? Europe is ahead in this respect, though not alone. In the United States, legislators have been developing a market-structure bill, the CLARITY Act. It passed the House of Representatives in July 2025 and cleared a key Senate committee in May 2026, with an updated Senate version released in July 2026. At the time of writing it has not passed the full Senate and has not become law. US regulators, meanwhile, have continued to set direction independently. The particulars and the timelines differ. The broader direction does not: the sector is moving from an unregulated environment toward a defined legal framework. Where Dohrnii stands At Dohrnii, we follow these developments closely. For a project centred on education, doing so is a matter of consistency: understanding the regulatory landscape is part of engaging with this market responsibly, and communicating that understanding to our community is part of our purpose. Regulation need not diminish what makes the technology valuable. Applied properly, it is what allows that value to reach a wider audience than an unregulated market ever could. — Dohrnii Labs This article is for educational and informational purposes only and is not financial, investment, or legal advice. Regulatory frameworks evolve; always verify current requirements with official sources. Sources & further reading ● European Securities and Markets Authority (ESMA) — Markets in Crypto-Assets Regulation (MiCA): esma.europa.eu ● Regulation (EU) 2023/1114 (MiCA), official EU legislation (EUR-Lex) ● European Banking Authority (EBA) / ESAs consumer warning and MiCA factsheet ● MiCA Article 109 — ESMA register of crypto-asset white papers

OTC Fair Buyback — Wave 1 Update Initial On-Chain Findings

Dohrnii Labs · Analysis Update Four days after launching Wave 1 of the OTC Fair Buyback Program, Dohrnii Labs completed a targeted on-chain review of wallets linked to historical OTC purchases in the USD 2–25 range. Key Finding: There is currently no verified OTC participant within the USD 2–25 range seeking to sell back at original purchase price. On-chain data indicates that most early OTC exposure has already been exited on the open market prior to the program launch. What the Data Shows Wallet-level transaction tracing reveals: Significant historical transfers from OTC wallets to DEX liquidity routes and exchange deposit addresses, including MEXC. Progressive distribution patterns consistent with market selling, not long-term holding. Current DHN balances in many original OTC wallets are materially lower than initial allocations or 0. Observed exit price ranges cluster broadly between USD 1 and USD 8 during periods of market weakness. These findings are based on verifiable blockchain transaction flows and exchange interaction patterns. The data suggests that a large portion of early OTC buyers in the USD 2–25 range already realised their positions on the open market at lower prices, rather than holding for recovery or participating in the buyback framework. Status of Wave 1 The OTC Fair Buyback — Wave 1 remains active and continues to review eligible cases individually. Further updates will be provided if participation dynamics or on-chain holding structures change materially. — Dohrnii Labs