MiCA Whitepaper Inline XBRL

General information

N	Field	Content
I.00	Table of contents	I. Compliance with duties of information II. Summary Part A- Information about the issuer of the e-money token Part B - Information about the e-money token Part C - Information about the offer to the public of the e-money token or its admission to trading Part D - Information on the rights and obligations attached to e-money tokens Part E - Information on the underlying technology Part F - Information on the risks Part G – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
I.01	Date of notification	2026-01-09
I.02	Statement in accordance with Article 51(3) of Regulation (EU) 2023/1114	This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The issuer of the crypto-asset is solely responsible for the content of this crypto-asset white paper.
I.03	Compliance statement in accordance with Article 51(5) of Regulation (EU) 2023/1114	This crypto-asset white paper complies with Title IV of Regulation (EU) 2023/1114 of the European Parliament and of the Council and to the best of the knowledge of the management body, the information presented in this crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.
I.04	Warning in accordance with Article 51(4), points (a) and (b), of Regulation (EU) 2023/1114	This e-money token is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.
I.05	Warning in accordance with Article 51(6), second subparagraph of Regulation (EU) 2023/1114	Warning This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this e-money token on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and that any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.
I.06	Characteristics of the crypto-asset	Monerium is an authorised electronic money institution under Directive 2009/110/EC, supervised by the Financial Supervisory Authority of the Central Bank of Iceland. Monerium issues EMTs, including EURe, GBPe, and USDe, which are available on public blockchains, including Ethereum, Gnosis, Arbitrum, Linea, Scroll, Noble, and Polygon. Monerium EURe qualifies as e-money tokens (“EMT“) as it purports to maintain a stable value by referencing the value of one official currency, according to Art. 3(1) point (7) of MiCAR. Each e-money token is issued at par value upon receipt of funds. It is backed 1:1 by the equivalent amount denominated in the same currency, either as a deposit in segregated accounts with credit institutions or invested in qualifying high-quality liquid assets with minimal market risk, credit risk, duration risk, and concentration risk.
I.07	Right of redemption	Holders of the e-money tokens issued by Monerium have the right of redemption at any time and at par value. Redemptions are conditioned on the holder establishing a customer relationship with Monerium. Funds received in exchange for EURe are transferred via the Single Euro Payment Area (“SEPA“) payment system and denominated in euros. At request, Monerium will redeem the monetary value of the e-money at any time and at par value. Redemption may be requested in whole or in part.. Right to redeem e-money is conditional upon (i) holding the corresponding amount of e-money at your address, (ii) compliance with Monerium’s Terms of Service and internal policies, and (iii) the absence of any restriction imposed by a regulator, law enforcement authority, or a court of competent jurisdiction.
I.08	Key information about the offer and/ or admission to trading	A customer relationship must be established to be eligible to receive e-money tokens issued directly by Monerium. E-money tokens are issued at par value upon receipt of funds. Further information on establishing a customer relationship can be found in Section 2 of our Terms of Service (https://monerium.com/policies/personal-terms-of-service/). Currently, EURe is not listed on platforms operated by external crypto asset service providers. However, Monerium may seek its admission to trading on future MiCA-compliant trading platforms.

Field

Content

I.00

Table of contents

I. Compliance with duties of information
II. Summary
Part A- Information about the issuer of the e-money token
Part B - Information about the e-money token
Part C - Information about the offer to the public of the e-money token or its admission to trading
Part D - Information on the rights and obligations attached to e-money tokens
Part E - Information on the underlying technology
Part F - Information on the risks
Part G – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts

I.01

Date of notification

2026-01-09

I.02

Statement in accordance with Article 51(3) of Regulation (EU) 2023/1114

This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The issuer of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

I.03

Compliance statement in accordance with Article 51(5) of Regulation (EU) 2023/1114

This crypto-asset white paper complies with Title IV of Regulation (EU) 2023/1114 of the European Parliament and of the Council and to the best of the knowledge of the management body, the information presented in this crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

I.04

Warning in accordance with Article 51(4), points (a) and (b), of Regulation (EU) 2023/1114

This e-money token is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

I.05

Warning in accordance with Article 51(6), second subparagraph of Regulation (EU) 2023/1114

Warning

This summary should be read as an introduction to the crypto-asset white paper.

The prospective holder should base any decision to purchase this e-money token on the content of the crypto-asset white paper as a whole and not on the summary alone.

The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and that any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law.

This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.

I.06

Characteristics of the crypto-asset

Monerium is an authorised electronic money institution under Directive 2009/110/EC, supervised by the Financial Supervisory Authority of the Central Bank of Iceland. Monerium issues EMTs, including EURe, GBPe, and USDe, which are available on public blockchains, including Ethereum, Gnosis, Arbitrum, Linea, Scroll, Noble, and Polygon. Monerium EURe qualifies as e-money tokens (“EMT“) as it purports to maintain a stable value by referencing the value of one official currency, according to Art. 3(1) point (7) of MiCAR.
Each e-money token is issued at par value upon receipt of funds. It is backed 1:1 by the equivalent amount denominated in the same currency, either as a deposit in segregated accounts with credit institutions or invested in qualifying high-quality liquid assets with minimal market risk, credit risk, duration risk, and concentration risk.

I.07

Right of redemption

Holders of the e-money tokens issued by Monerium have the right of redemption at any time and at par value.
Redemptions are conditioned on the holder establishing a customer relationship with Monerium. Funds received in exchange for EURe are transferred via the Single Euro Payment Area (“SEPA“) payment system and denominated in euros. At request, Monerium will redeem the monetary value of the e-money at any time and at par value. Redemption may be requested in whole or in part.. Right to redeem e-money is conditional upon (i) holding the corresponding amount of e-money at your address, (ii) compliance with Monerium’s Terms of Service and internal policies, and (iii) the absence of any restriction imposed by a regulator, law enforcement authority, or a court of competent jurisdiction.

I.08

Key information about the offer and/ or admission to trading

A customer relationship must be established to be eligible to receive e-money tokens issued directly by Monerium. E-money tokens are issued at par value upon receipt of funds. Further information on establishing a customer relationship can be found in Section 2 of our Terms of Service (https://monerium.com/policies/personal-terms-of-service/).
Currently, EURe is not listed on platforms operated by external crypto asset service providers. However, Monerium may seek its admission to trading on future MiCA-compliant trading platforms.

Part A - Information about the issuer of the e-money token

Field

Content

A.1

Statutory name

Monerium hf

A.2

Trading name

Monerium

A.3

Legal form

Not applicable as LEI is in A.7

A.4

Registered address

Not applicable as LEI is in A.7

A.5

Head office

Not applicable as LEI is in A.7

A.6

Registration date

2012-05-10

A.7

Legal entity identifier

2549003QDNZWASSSCY31

A.8

Another identifier required pursuant to applicable law

Not applicable as LEI is in A.7

A.9

Contact telephone number

Not provided

A.10

E-mail address

hello@monerium.com

A.11

Response time (days)

005

A.12

Parent company

Not applicable as LEI is in A.7

A.13

Members of the management body

Identity	Business Address	Functions
Gísli Kristjánsson	1 Bjargargata, 102 Reykjavík, IS-1, IS	CEO
Árni Guðjónsson	1 Bjargargata, 102 Reykjavík, IS-1, IS	CRO
Hjörtur Hjartarson	1 Bjargargata, 102 Reykjavík, IS-1, IS	COO
Margus Kerma	1 Bjargargata, 102 Reykjavík, IS-1, IS	CTO

A.14

Business activity

Monerium is an Electronic Money Institution authorised and supervised by the Central Bank of Iceland, and provides e-money token services.
Monerium is also registered as a Virtual Asset Service Provider with the Central Bank of Iceland. Monerium intends to provide exchange services for EMTs and crypto assets.

A.15

Parent company business activity

This field does not apply as Monerium hf does not have a parent company.

A.16

Conflicts of interest disclosure

No potential conflicts of interest have been identified in relation to the e-money services provided by Monerium as of today.

A.17

Issuance of other crypto-assets

TRUE

A.18

Activities related to other crypto-assets

FALSE

A.19

Connection between the issuer and the entity running the DLT

TRUE

A.20

Description of the connection between the issuer and the entity running the DLT

Monerium issues e-money tokens on Ethereum, Polygon, Scroll, Noble, Arbitrum, Linea, and Gnosis Chain. The Company intends to add more blockchains and will make. appropriate amendments to this White paper in due course.
Monerium has no or limited connections with the entities, persons, or foundations associated with Ethereum, Arbitrum, Scroll, and Polygon.
Monerium has close working connections with persons associated with Gnosis, Nobel, and Linea. In some cases, Monerium has received grants related to the deployment of EMTs from the blockchain foundation in question.
Companies related to the entities running blockchains on which Monerium issues are also minority shareholders of Monerium.

A.21

Newly established

FALSE

A.22

Financial condition for the past three years

Monerium is a startup company and relies on funding. Monerium's business model is to collect interest from safeguarded funds, exchange fees, and API access fees. Monerium has relied on external funding from investors. Across the three years 2022, 2023 and 2024, Monerium transitioned from a mainly software development set-up, where e-money issuance sat in a subsidiary, to an integrated structure including e-money issuance following the merger effective 1 January 2024

Business development and performance, three-year comparison
Monerium’s activity scaled materially across the period, with e-money usage indicators strengthening year on year. EURe issuance increased from about EUR 1.0 million in 2022 to EUR 11.5 million in 2023, reaching a peak of EUR 17.0 million, and then to a peak of about EUR 25.0 million in 2024. Cumulative on-chain EURe turnover rose to EUR 620 million in 2023 and EUR 2.6 billion in 2024. Monerium experienced exceptional growth in its customer base, recording an increase of over 600% from 2022 to 2023, and a further expansion of approximately 190% in 2024, alongside a growing share of corporate clients. GBPe issuance started in 2024 and was about GBP 0.4 million by year end.

Financial performance, three-year comparison
Loss for the year was ISK 84.3 million in 2022, ISK 93.8 million in 2023, and ISK 184.0 million in 2024. The higher loss in 2024 is mainly explained by the start of amortisation of previously capitalised development costs once revenue generation began, with an amortisation expense of ISK 86.0 million in 2024, alongside higher operating costs as activities expanded. 2024 also shows operating revenue of ISK 63.7 million, mainly interest income on safeguarded funds of ISK 55.0 million plus fee income of ISK 8.7 million.

Financial position and capital resources, three-year comparison
Equity increased from ISK 651.2 million in 2022 to ISK 685.4 million in 2023 and ISK 1115.1 million in 2024. The reported equity ratio for 2024 is materially lower mainly because the balance sheet expands with safeguarded funds and matching liabilities rather than because equity fell in absolute terms. Capitalised development costs increased from ISK 415.5 million in 2022 to ISK 605.6 million in 2023 and ISK 773.6 million in 2024, reflecting continued investment in the platform.

Liquidity and cash flow narrative
Cash and cash equivalents were ISK 175.4 million at end 2022, ISK 18.7 million at end 2023, and ISK 437.7 million at end 2024. The reduction by end 2023 is consistent with the build-and-scale phase and continuing operating losses. The 2024 cash position should be interpreted alongside the safeguarding structure: safeguarded funds of e-money holders were ISK 3.872 billion and are matched by liabilities to e-money holders of the same amount. The provided annual financial statements do not include a cash flow statement, so this narrative is based on year-end cash levels and the disclosed balance sheet structure rather than a formal operating, investing and financing cash flow reconciliation.

A.23

Financial condition since registration

This field does not apply as A.21 is false.

A.24

Exemption from authorisation

FALSE

A.25

E-money token authorisation

The Financial Supervisory Authority of the Central Bank of Iceland granted Monerium authorization as an electronic money institution following the Act. No. 17/2013, which implements Directive 2009/110/EC, from June 14, 2019.

A.26

Authorisation authority

Central Bank of Iceland

A.27

Persons other than the issuer offering to the public or seeking admission to trading of the e-money token in accordance with Article 51(1), second subparagraph, of Regulation (EU) 2023/1114

This field does not apply.

A.28

Persons other than the issuer offering to the public or seeking admission to trading of the e-money token in accordance with Article 51(1), second subparagraph, of Regulation (EU) 2023/1114

This field does not apply.

A.29

Reason for offering to the public or seeking admission to trading of the e-money token by persons referred to in Article 51(1), second subparagraph, of Regulation (EU) 2023/1114

This field does not apply.

Part B - Information about the e-money token

Field

Content

B.1

Name

Not applicable as DTI was provided in B.12

B.2

Abbreviation

Not applicable as DTI was provided in B.12

B.3

Details of all natural or legal persons involved in design and development

Name of person	Type of person	Business address	Domicile
Monerium hf	Development team	1 Bjargargata, 102 Reykjavík, IS-1, IS	Iceland
Ackee Blockchain a.s.	Other person involved in implementation	Rohanske nabrezi, 717/4 186 00, CZ-10, CZ	Czechia
Halborn	Other person involved in implementation	114, NW 25th Street, Unit #143, Miami,US	United STates of America

B.4

Type of white paper

EMTW

B.5

The type of submission

NEWT

B.6

Crypto-asset characteristics

Each Monerium e-money token represents the value of one official currency. Each issued token is backed by the same fiat currency equivalent amount 1:1. The funds Monerium receives in exchange for e-money tokens are safeguarded in segregated accounts for and on behalf of the e-money token holder, separated from Monerium's own funds. Safeguarded funds are kept as deposits in segregated accounts with banks or as high-quality liquid assets (“HQLA“) denominated in the same fiat currency as the relevant e-money token under Art. 54 point (b) of MiCAR.
Monerium e-money tokens are live on Ethereum, Gnosis, Arbitrum, Scroll, Linea, and Polygon. Each token supports functions compliant with the ERC20 and ERC2612.

B.7

Website of the issuer

www.https://monerium.com/

B.8

Starting date of offer to the public or admission to trading

2026-02-09

B.9

Publication date

2026-02-09

B.10

Any other services provided by the issuer

Monerium is registered as a Virtual Asset Service Provider with the Central Bank of Iceland

B.11

Language or languages of the white paper

English

B.12

Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available

Ethereum: 81PTSP744
Polygon: JVM0S87GB
Gnosis: 3P9X6K6P2
Arbitrum One: S45L7172C
Scroll: ZHKQJ78VZ
Linea: 6KL7TK20G
Noble: 5LN265K07

B.13

Functionally fungible group digital token identifier, where available

N7B1L2FBK

B.14

Personal data flag

TRUE

B.15

LEI eligibility

TRUE

B.16

Home Member State

Iceland

B.17

Host Member States

Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Liechtenstein, Norway

Part C - Information about the offer to the public of the e-money token or its admission to trading

N	Field	Content
C.1	Public offering or trading	OTPC
C.2	Number of units	22400198
C.3	Trading platforms name	Not applicable
C.4	Trading platforms market identifier code (MIC)	Not applicable
C.5	Applicable law	Iceland
C.6	Competent court	Iceland

Field

Content

C.1

Public offering or trading

OTPC

C.2

Number of units

22400198

C.3

Trading platforms name

Not applicable

C.4

Trading platforms market identifier code (MIC)

Not applicable

C.5

Applicable law

Iceland

C.6

Competent court

Iceland

Part D - Information on the rights and obligations attached to e-money tokens

N	Field	Content
D.1	Holder’s rights and obligations	Each EURe represents a claim on the underlying funds Monerium receives in exchange for the EURe and safeguards. Holders are entitled to request redemption of their EURe at any time and at par value. To enjoy redemption rights, a holder must become a Monerium customer, conditioned upon accepting our Terms of Service and successfully completing our customer due diligence (“CDD“) process. Customers can make a redemption request by submitting a redemption order via our customer interface. Applicable information must accompany the redemption request, including the beneficiary's name and account number. The customer confirms the transaction by signing a message sent to the linked blockchain address with his/her private key. Subsequently, the same amount of EURe is burnt from the holder's address, and funds (EUR) are sent via SEPA to the identified beneficiary. As Monerium is required to comply with KYC/AML and sanction rules, in some cases, redemption requests may be halted and subjected to further checks or declined. Such cases can arise where Monerium deems that the holder has violated requirements in our Terms of Services, or suspicion of money laundering, terrorist financing, or sanction violation arises. According to Art. 50 of MiCAR Monerium is prohibited from granting holders of EURe interest or any other benefit related to the length of time a holder of an EURe holds it. Therefore, holders of EURe have no claim nor are entitled to any interests or other returns earned on the funds Monerium safeguards. In case of Monerium insolvency, EURe holders enjoy a special priority statutory claim according to the Icelandic Bankruptcy Act No. 21/1991, which states that “assets and interest in the possession of the bankruptcy estate shall be delivered to a third party if the third party proves his/her entitlement.“ Thus, the funds received in exchange for EURe shall be paid from the asset pool in priority to all other creditors. Blockchain transactions are generally irreversible. When EURe is transferred to a third-party address, which is not under the holder’s control, the holder automatically transfers and assigns the right to redeem e-money in exchange for funds to that third party. That third party's right to redeem e-money received from the holder is contingent on Monerium accepting such a person as a customer. Blockchain transactions are entered into at the holder's sole responsibility; therefore, losses due to fraudulent or accidental transactions can not be recovered. Monerium may be obligated to freeze EURe that is sent or received to/from blacklisted addresses. In such cases, a holder forfeits any rights associated with EURe, including the ability to redeem EURe.
D.2	Conditions of modifications of rights and obligations	The rights and obligations associated with EURe are governed by applicable regulations, including, but not limited to, MiCAR and our Terms of Service. Monerium reserves the right to amend our Terms of Service that are not in our customers’ favor by providing customers with at least two (2) weeks' notice. Monerium will provide such notice to customers on our websites, via email or other electronic means. Such amendments will become effective on the date specified in the notice unless the customer notifies us otherwise prior to the date specified in the notice. If a customer does not accept our revised terms, the customer has the right, at his/her sole discretion, without any liability, to terminate our Terms of Service forthwith. As stipulated in Art. 51(12) of MiCAR, a new version of this white paper shall be drawn up, notified to competent authorities, and published on the Monerium website if any significant new factor, material mistake, or material inaccuracy capable of affecting the assessment of EURe is identified.
D.3	Description of the rights of the holders	According to the Icelandic Bankruptcy Act No. 21/1991, EURe holders enjoy the highest priority claim against the bankruptcy estate in proportion to their ownership. In the event of Monerium's insolvency, or if a financial claim is made against Monerium, no creditor or claimant should be able to claim funds held in our safeguarded accounts. This is because no other person or institution may have any rights or interest over the funds held in Monerium safeguarded accounts, such as a lien.
D.4	Rights in implementation of recovery plan	In accordance with Art. 55 of MiCAR, Monerium will notify the Central Bank of Iceland of our recovery plan within six months of the date of the offer of EURe to the public. According to Art. 55 of MiCAR, which refers to Title III, Chapter 6, Monerium must draw up and maintain a recovery plan that provides measures to be taken by Monerium to restore compliance with the requirements applicable to the reserve of assets in cases where Monerium fails to comply with those requirements. In cases where events pose a significant risk of disrupting Monerium operations, the recovery plan may be implemented, which might impose certain restrictions on holders' rights, such as the following: liquidity fees on redemptions; limits on the amount of EURe that can be redeemed on any working day; suspension of redemptions. Monerium will duly inform customers of any restrictions imposed upon implementing the recovery plan.
D.5	Rights in implementation of redemption plan	Following Art. 55 of MiCAR, Monerium will notify the Central Bank of Iceland of our redemption plan within six months of the date of the EURe public offer. This operational plan is intended to support the orderly redemption of EURe and ensure the equitable treatment of all EURe holders. The Central Bank of Iceland activates the redemption plan in cases where it is deemed that Monerium is unable or likely to be unable to fulfill its obligations, including insolvency, resolution, or withdrawal of Monerium's electronic money institution authorization. The redemption plan shall demonstrate Monerium's ability to redeem all outstanding EURe issued without causing undue economic harm to its holders or to the stability of the markets of the reserve assets. Activating the redemption plan may temporarily or permanently suspend the EURe holder's right of redemption to ensure fair and equitable treatment of all holders. An information notice about activating the redemption plan and its process will be published on the Monerium website and social media channels. The redemption plan will provide further information regarding claim submission, timelines, redemption process, and claim filing criteria. Redemption requests filed under the redemption plan are contingent upon the holder's successful completion of the customer due diligence process, as further explained in the Monerium Redemption Plan.
D.6	Complaint submission contact	Monerium has established a Complaint Policy, which dictates how complaints are handled. All complaints must be objectively based and submitted in writing to complaint@monerium.com. According to Monerium, a complaint must be objectively based to be considered.
D.7	Complaints handling procedures	Monerium will ensure that complaints are handled swiftly, effectively, and fairly. Upon receiving a complaint, Monerium will acknowledge its receipt and provide information regarding the complaint handling. A response to a complaint shall be provided within four weeks. If it’s impossible to respond within that timeframe, the complainant shall be informed of the delay, its reasons, and when he/she can anticipate a response.
D.8	Dispute resolution mechanism	According to Art. 42 of Act No. 17/2013 on the issuance and handling of electronic money, customers can submit an appeal and seek a ruling with the Complaints Committee on Transactions with Financial Firms. The Complaint Committee is located at Guðrúnartún 1, 105 Reykjavik, with the email address fjarmal@nefndir.is and can be reached via the phone number +354 578-6500. Further information can be found on the Complaint Committee website nefndir.is. It shall be stressed that Committee rulings do not prevent subsequent case handling by a court of law.
D.9	Token value protection schemes	TRUE
D.10	Token value protection schemes description	No governmental or official protection or compensation scheme applies to EURe holders. EURe is fully backed 1:1 in EURO-denominated assets such as deposits or high-quality liquid assets safeguarded with regulated financial institutions on behalf of and for the benefit of EURe holders. Customer funds are segregated from Monerium's own funds
D.11	Compensation schemes	FALSE
D.12	Compensation schemes Description	No governmental or official protection or compensation scheme applies to EURe holders.
D.13	Applicable law	Iceland
D.14	Competent court	Iceland

Field

Content

D.1

Holder’s rights and obligations

Each EURe represents a claim on the underlying funds Monerium receives in exchange for the EURe and safeguards. Holders are entitled to request redemption of their EURe at any time and at par value.
To enjoy redemption rights, a holder must become a Monerium customer, conditioned upon accepting our Terms of Service and successfully completing our customer due diligence (“CDD“) process.
Customers can make a redemption request by submitting a redemption order via our customer interface. Applicable information must accompany the redemption request, including the beneficiary's name and account number. The customer confirms the transaction by signing a message sent to the linked blockchain address with his/her private key. Subsequently, the same amount of EURe is burnt from the holder's address, and funds (EUR) are sent via SEPA to the identified beneficiary. As Monerium is required to comply with KYC/AML and sanction rules, in some cases, redemption requests may be halted and subjected to further checks or declined. Such cases can arise where Monerium deems that the holder has violated requirements in our Terms of Services, or suspicion of money laundering, terrorist financing, or sanction violation arises.
According to Art. 50 of MiCAR Monerium is prohibited from granting holders of EURe interest or any other benefit related to the length of time a holder of an EURe holds it. Therefore, holders of EURe have no claim nor are entitled to any interests or other returns earned on the funds Monerium safeguards.
In case of Monerium insolvency, EURe holders enjoy a special priority statutory claim according to the Icelandic Bankruptcy Act No. 21/1991, which states that “assets and interest in the possession of the bankruptcy estate shall be delivered to a third party if the third party proves his/her entitlement.“ Thus, the funds received in exchange for EURe shall be paid from the asset pool in priority to all other creditors.
Blockchain transactions are generally irreversible. When EURe is transferred to a third-party address, which is not under the holder’s control, the holder automatically transfers and assigns the right to redeem e-money in exchange for funds to that third party. That third party's right to redeem e-money received from the holder is contingent on Monerium accepting such a person as a customer. Blockchain transactions are entered into at the holder's sole responsibility; therefore, losses due to fraudulent or accidental transactions can not be recovered.
Monerium may be obligated to freeze EURe that is sent or received to/from blacklisted addresses. In such cases, a holder forfeits any rights associated with EURe, including the ability to redeem EURe.

D.2

Conditions of modifications of rights and obligations

The rights and obligations associated with EURe are governed by applicable regulations, including, but not limited to, MiCAR and our Terms of Service.
Monerium reserves the right to amend our Terms of Service that are not in our customers’ favor by providing customers with at least two (2) weeks' notice. Monerium will provide such notice to customers on our websites, via email or other electronic means. Such amendments will become effective on the date specified in the notice unless the customer notifies us otherwise prior to the date specified in the notice. If a customer does not accept our revised terms, the customer has the right, at his/her sole discretion, without any liability, to terminate our Terms of Service forthwith.
As stipulated in Art. 51(12) of MiCAR, a new version of this white paper shall be drawn up, notified to competent authorities, and published on the Monerium website if any significant new factor, material mistake, or material inaccuracy capable of affecting the assessment of EURe is identified.

D.3

Description of the rights of the holders

According to the Icelandic Bankruptcy Act No. 21/1991, EURe holders enjoy the highest priority claim against the bankruptcy estate in proportion to their ownership. In the event of Monerium's insolvency, or if a financial claim is made against Monerium, no creditor or claimant should be able to claim funds held in our safeguarded accounts. This is because no other person or institution may have any rights or interest over the funds held in Monerium safeguarded accounts, such as a lien.

D.4

Rights in implementation of recovery plan

In accordance with Art. 55 of MiCAR, Monerium will notify the Central Bank of Iceland of our recovery plan within six months of the date of the offer of EURe to the public.
According to Art. 55 of MiCAR, which refers to Title III, Chapter 6, Monerium must draw up and maintain a recovery plan that provides measures to be taken by Monerium to restore compliance with the requirements applicable to the reserve of assets in cases where Monerium fails to comply with those requirements.
In cases where events pose a significant risk of disrupting Monerium operations, the recovery plan may be implemented, which might impose certain restrictions on holders' rights, such as the following:

liquidity fees on redemptions;
limits on the amount of EURe that can be redeemed on any working day;
suspension of redemptions.
1. Monerium will duly inform customers of any restrictions imposed upon implementing the recovery plan.

D.5

Rights in implementation of redemption plan

Following Art. 55 of MiCAR, Monerium will notify the Central Bank of Iceland of our redemption plan within six months of the date of the EURe public offer.
This operational plan is intended to support the orderly redemption of EURe and ensure the equitable treatment of all EURe holders. The Central Bank of Iceland activates the redemption plan in cases where it is deemed that Monerium is unable or likely to be unable to fulfill its obligations, including insolvency, resolution, or withdrawal of Monerium's electronic money institution authorization.
The redemption plan shall demonstrate Monerium's ability to redeem all outstanding EURe issued without causing undue economic harm to its holders or to the stability of the markets of the reserve assets.
Activating the redemption plan may temporarily or permanently suspend the EURe holder's right of redemption to ensure fair and equitable treatment of all holders.
An information notice about activating the redemption plan and its process will be published on the Monerium website and social media channels. The redemption plan will provide further information regarding claim submission, timelines, redemption process, and claim filing criteria.
Redemption requests filed under the redemption plan are contingent upon the holder's successful completion of the customer due diligence process, as further explained in the Monerium Redemption Plan.

D.6

Complaint submission contact

Monerium has established a Complaint Policy, which dictates how complaints are handled.
All complaints must be objectively based and submitted in writing to complaint@monerium.com. According to Monerium, a complaint must be objectively based to be considered.

D.7

Complaints handling procedures

Monerium will ensure that complaints are handled swiftly, effectively, and fairly. Upon receiving a complaint, Monerium will acknowledge its receipt and provide information regarding the complaint handling. A response to a complaint shall be provided within four weeks. If it’s impossible to respond within that timeframe, the complainant shall be informed of the delay, its reasons, and when he/she can anticipate a response.

D.8

Dispute resolution mechanism

According to Art. 42 of Act No. 17/2013 on the issuance and handling of electronic money, customers can submit an appeal and seek a ruling with the Complaints Committee on Transactions with Financial Firms.
The Complaint Committee is located at Guðrúnartún 1, 105 Reykjavik, with the email address fjarmal@nefndir.is and can be reached via the phone number +354 578-6500. Further information can be found on the Complaint Committee website nefndir.is.
It shall be stressed that Committee rulings do not prevent subsequent case handling by a court of law.

D.9

Token value protection schemes

TRUE

D.10

Token value protection schemes description

No governmental or official protection or compensation scheme applies to EURe holders. EURe is fully backed 1:1 in EURO-denominated assets such as deposits or high-quality liquid assets safeguarded with regulated financial institutions on behalf of and for the benefit of EURe holders. Customer funds are segregated from Monerium's own funds

D.11

Compensation schemes

FALSE

D.12

Compensation schemes Description

No governmental or official protection or compensation scheme applies to EURe holders.

D.13

Applicable law

Iceland

D.14

Competent court

Iceland

Part E - Information on the underlying technology

N	Field	Content
E.1	Distributed ledger technology	Not applicable as DTI was provided in B.12.
E.2	Protocols and technical standards	EURe is an e-money token deployed on multiple blockchain networks, including Ethereum, Arbitrum, Gnosis, Polygon (PoS), Linea, and Noble (Cosmos). Each deployment operates within the technical framework and consensus model of its respective base layer, inheriting that network’s approach to consensus, data availability, and transaction finality. EURe is implemented using the native token and smart-contract standards of the blockchains on which it is deployed. On Ethereum, Arbitrum, Gnosis, Polygon and Linea, EURe is deployed as an ERC-20-compatible contract compiled for the EVM. Token balances, allowances and transfer events are stored in the contract’s on-chain state and are updated deterministically as part of EVM transaction execution. On Noble, which is built on the Cosmos SDK, EURe is issued through native modules rather than an EVM contract; issuance and redemption logic is handled by the x/florin module and balances are recorded in the Cosmos x/bank subsystem. On EVM-based networks, the EURe contracts follow the ERC-20 fungible token standard and adopt additional issuer-specific controls. The v2 contracts integrate ERC-2612 “permit” functionality, allowing off-chain signatures to authorise approvals and enabling gasless approval flows in compatible applications. The contract design also incorporates blacklist features implemented via dedicated components in the Monerium smart-contracts codebase.Token upgrades are implemented using an upgradeable proxy pattern: version 1 (V1) token addresses remain stable while delegating state management to version 2 (V2) contracts behind the scenes, so on-chain balances remain associated with a fixed address even when the underlying implementation is updated. The execution environment for EURe on Ethereum, Arbitrum, Gnosis, Polygon and Linea is an EVM-compatible virtual machine. Contracts are written in high-level languages and compiled to EVM bytecode, which is executed deterministically on all participating nodes. Transactions and blocks in the execution layer are serialised using Recursive Length Prefix (RLP) encoding, and smart-contract calls follow the Ethereum Application Binary Interface (ABI) specification. Transaction authentication relies on secp256k1-based ECDSA signatures, and addresses are represented as 20-byte values commonly displayed using EIP-55 checksum casing. Keccak-256 hashing is used to derive transaction identifiers, compute storage keys and produce internal state commitments. Client access on EVM-based networks uses Ethereum-standard JSON-RPC 2.0 interfaces exposed over HTTP(s) or WebSocket by execution clients and infrastructure providers. These interfaces allow applications and wallets to query EURe balances, inspect transfer logs at specific block heights and submit signed transactions for inclusion in the network without running a validator or full node. On Ethereum, Gnosis and Polygon, these JSON-RPC endpoints sit on top of standard Ethereum-style node stacks. On Arbitrum and Linea, JSON-RPC compatibility is maintained at the API level, but node roles differ: both networks introduce a rollup-specific sequencer component that orders transactions and batches them for settlement on Ethereum, and Linea additionally operates a prover pipeline that generates zkSNARK proofs for batched state transitions. Arbitrum exposes both general-purpose public RPC endpoints and sequencer-focused endpoints intended primarily for transaction submission. The sequencer endpoints are restricted to a narrow set of methods (for example, eth_sendRawTransaction and related calls) and are optimised for forwarding transactions into the sequencer’s ordering pipeline, whereas standard RPC URLs provide a broader read/write interface for querying chain data. This separation allows infrastructure providers to scale transaction ingress independently from state-query traffic while preserving Ethereum-style JSON-RPC semantics for most application integrations. On Noble, EURe leverages the Cosmos SDK’s native module architecture. Noble is an application-specific chain focused on asset issuance; modules such as x/florin enable native issuance of EURe, and x/bank maintains an account-based ledger of balances. Transactions are ordered and finalised via the CometBFT consensus engine, and clients interact with the chain using Cosmos RPC, gRPC and REST endpoints rather than Ethereum JSON-RPC. Token balances, transfers and module events related to EURe can be queried through these APIs or via block explorers that index Noble’s on-chain data. Across all supported blockchains networks, the EURe implementation follows consistent design principles: an account-based ledger model, deterministic on-chain execution and reliance on widely adopted, open standards for transaction encoding, cryptography and client interfaces.
E.3	Technology used	The EURe system combines on-chain token logic with an off-chain, regulated e-money platform and developer-facing services. On EVM-compatible networks, EURe is implemented via Monerium’s open-source smart-contract system, while the Noble integration is implemented as the x/florin Cosmos SDK module maintained in Noble’s ecosystem repositories. Off-chain, Monerium operates an electronic-money institution platform that manages customer onboarding, wallet linking, IBAN allocation, and SEPA bank transfer flows associated with issuance and redemption. The off-chain platform reconciles fiat movements and coordinates corresponding on-chain actions. Monerium’s technical documentation describes EURe as being minted when a payment is received and burned when tokens are used to send euros via SEPA transfer, linking regulated e-money operations to on-chain balances on supported networks. Developers integrate primarily through Monerium’s REST APIs and published SDKs, which support distinct sandbox and production environments and provide mechanisms to monitor issuance/redemption workflows (e.g., via order/event subscriptions). Cross-network movement of EURe is exposed as a Monerium-operated service: users initiate the transfer in Monerium’s interface, sign the request, and Monerium coordinates the required steps across the relevant networks as part of the overall issuance/redemption and bookkeeping process. Operationally, EURe’s on-chain supply, transfers, and contract/module events remain publicly verifiable on each supported network via standard explorers and node interfaces. This enables independent verification of on-chain activity even if Monerium’s web services are unavailable, while the off-chain platform operates under the controls and requirements applicable to a licensed electronic money institution.
E.4	Purchaser’s technical requirements	A purchaser of EURe from Monerium must become a customer by submitting the required documentation in the customer due diligence process. A purchaser must bring his/her blockchain wallet address and link it to the Monerium interface. The purchaser will then be asked to sign a message with his/her private key to verify that he/she owns and controls the blockchain address in question. Once the customer's due diligence has been completed, a purchaser will receive an IBAN (International Bank Account Number) associated with the purchaser's blockchain address. To receive EURe, the customer must receive a euro payment via SEPA to the IBAN Monerium provided to the purchaser. Once Monerium has received the order via SEPA, the equivalent amount of euros will be minted as EURe tokens to the purchaser's blockchain wallet address. Therefore, to execute an EURe blockchain transaction, purchasers must have the technical capabilities to operate their own blockchain wallets and hold the relevant native crypto-asset to pay blockchain transaction fees. As EURe is issued on public blockchain networks, access to EURe can be achieved through various decentralized finance applications (“DeFi“). Purchasers should be aware that a direct customer relationship is required to redeem EURe directly through Monerium. EURe acquired via DeFi may become subject to further scrutiny and, in some cases, denial of service where we suspect fraudulent activity.
E.5	Consensus mechanism	EURe does not have its own consensus mechanism. As an e-money token issued on third-party networks, EURe leverages, and inherits the transaction ordering, data-availability and finality properties of each underlying blockchain on which it is supported. The security and liveness of EURe transfers therefore depend on the consensus design and operational integrity of those base layers. On Ethereum, transaction ordering and finality are provided by Ethereum’s Proof-of-Stake consensus mechanism. Validators participate as block proposers and attesters, following Ethereum’s fork-choice rules and finality gadget to agree on the canonical chain and provide economic finality for blocks containing EURe transactions. On Gnosis Chain, EURe relies on Gnosis’ Proof-of-Stake consensus. Gnosis transitioned to this model through “The Merge” on Gnosis, adopting a separation between an execution layer and a PoS consensus layer. Validators in this model are responsible for proposing and validating blocks, and for finalising the chain that records EURe transfers. On Polygon PoS, EURe is recorded on a Proof-of-Stake network operated by a validator set that handles block production, validation and chain security. Polygon’s PoS architecture defines validator roles and the settlement design that together determine the ordering and confirmation of EURe transactions on this network. On Arbitrum, EURe operates on an optimistic rollup built on top of Ethereum. Arbitrum uses a sequencer-based ordering layer to provide fast inclusion of transactions: the sequencer orders and batches user transactions, including those involving EURe. Ultimate settlement and finality are anchored to Ethereum Layer 1, with withdrawals and finality dependent on the rollup’s dispute and challenge process on Ethereum. On Linea, EURe is supported on a zero-knowledge rollup that also relies on Ethereum for final settlement. Linea orders transactions via a sequencer and achieves economic finality through validity proofs that are verified on Ethereum. Blocks are treated as final once their associated proofs have been accepted on Layer 1, with Linea’s architecture also documenting internal coordination and attestation components that support this flow. On Noble, EURe relies on Noble’s use of CometBFT for consensus and its Proof-of-Authority model. Noble operates with a permissioned validator set, as described in Noble’s PoA documentation. These validators run CometBFT consensus to order transactions, commit blocks and provide finality for EURe state transitions on Noble. Across all these environments, EURe does not modify or extend the base-layer consensus rules. Instead, it is a token whose correctness and finality are determined by the consensus mechanisms of Ethereum, Gnosis Chain, Polygon PoS, Arbitrum, Linea and Noble respectively.
E.6	Incentive Mechanisms and Applicable Fees	EURe itself does not introduce any protocol-level incentive mechanisms at the token layer. There are no mining or staking rewards specific to EURe: holding or transferring EURe does not, in itself, generate consensus rewards. Instead, EURe inherits the incentive structures and transaction-fee models of the underlying networks, and any issuance, redemption or cross-chain movements are performed through Monerium’s regulated e-money workflows and service interfaces, which are subject to Monerium’s published commercial terms and fee schedule. On Ethereum, validators are incentivised through staking rewards and fee revenue derived from transactions included in their blocks. User transactions, including those involving EURe, pay gas fees. Under Ethereum’s EIP-1559 mechanism, these fees consist of a base fee that is burned and an optional priority fee (tip) that is paid to the block proposer or validator for transaction inclusion. On Gnosis Chain, users pay transaction fees in the chain’s gas token. Gnosis has adopted an EIP-1559-style mechanism in which a BASEFEE component of the transaction fee is burned, while a PRIORITYFEE component acts as a tip to validators, incentivising them to include transactions such as EURe transfers in their blocks. On Polygon PoS, validators are economically incentivised through the network’s Proof-of-Stake validator economics, including staking and associated rewards as defined in the Polygon PoS design. Users pay transaction fees in Polygon PoS’s native gas token. Polygon supports type-2 / EIP-1559-style transactions, and its documentation describes the fee mechanics that govern how base fees and tips are handled within the network. On Arbitrum, users pay a single transaction fee that reflects both the cost of L2 execution and the cost of posting the necessary calldata and data to Ethereum Layer 1. The sequencer plays a central role in transaction ordering and fee collection for inclusion in the rollup’s L2 chain, while the underlying economic model accounts for the costs of securing data and settlement on Ethereum. On Linea, fees are designed to cover both the cost of L2 execution and the cost of publishing data to Ethereum. Linea uses an EIP-1559-style fee model with a base fee and a priority fee, and its documentation describes in more detail the behaviour of these parameters, including the treatment of the base-fee floor under varying network conditions. On Noble, which operates under a PoA model, economic security is linked to fees captured in USDC. The globalfee module defines the transaction-fee parameters and the set of accepted fee tokens and amounts at the chain level. EURe transactions on Noble are therefore subject to Noble’s fee configuration, including the requirement to pay transaction fees in accepted fee tokens as specified by the globalfee module. From the perspective of an EURe holder, the primary direct costs of using EURe are the transaction fees imposed by the underlying network, payable in the relevant gas or fee token and any fees set out in Monerium’s own pricing for issuance, redemption and cross-chain services.
E.7	Use of distributed ledger technology	FALSE
E.8	DLT functionality description	This field does not apply as E.7 is false
E.9	Audit	TRUE
E.10	Audit outcome	All audits documented below: Ackee Blockchain’s Monerium smart contracts 22 Aug 2023 Object: Monerium protocol smart contracts. Results: 18 findings in total (5 Medium, 1 Low, 12 Informational/Warning). The result shows some issues as partially fixed and others as acknowledged. No Critical or High severity issues were identified. Actions: All Medium issues were addressed and the owner multisignature threshold was strengthened from 2of6 to 3of6. Additionally, the M5 fix was reverted and formally acknowledged due to migration complexity. Ackee Blockchain’s additional review Feb – Mar 2024 Object: ERC2612 permit handling and signature validation logic. Results: 8 findings in total, all Informational or Warning; no Medium or High severity issues. Actions: 5 issues fixed and 3 acknowledged. Most items related to event emission, returnvalue checking, and minor code cleanup. Ackee Blockchain’s Monerium V2 smart contracts 13 Jun 2024 Object: EURe smartcontrac. Results: 11 findings (2 High, 1 Medium, 1 Low, 7 Warning/Info). The most serious issue (H1 “Bypass validator rules”) was fully fixed. The results show H1 Fixed, H2 (Token frontend can impersonate anyone) Fixed Partially, and W3 (Validator can cause DoS) Acknowledged; no unresolved critical issues remain. Actions: The main vulnerabilities were mitigated, with DoS logic addressed via L1 remediation. Halborn’s EURe Monerium; Noble’s florin module Audit Aug – Sep 2024 Object: Audit of the Noble florin module. Results:3 findings (1 Medium, 1 Low, 1 Informational; none Critical or High). The Medium issue (MsgRecover not registered in codec) was Solved; the Low issue (Signature reuse in burn and recover) was Risk Accepted; and the Informational issue (Blacklistadmin enforcement) was Acknowledged. Actions: codec registration and verification logic were corrected and reviewed.

Part F - Information on the risks

N	Field	Content
F.1	Issuer-related risks	Monerium, as the issuer of EURe, is exposed to several risks that can affect its stability, usage, and reliability. Identified risks include, but are not limited to, insolvency risk, regulatory risk, operational risk, third-party risk, compliance risk, technological risks, market risks, and environmental, social, and governance (“ESG“) risks. Insolvency risks: The risk of Monerium going bankrupt can severely impact the price stability of EURe and holders' capability to redeem EURe at par value. Insolvency risk can also impact Monerium's ability to perform redemptions upon request. Regulatory risks: Monerium services are conditional on complying with regulatory requirements, including maintaining a license or other governmental authorizations in the jurisdictions in which Monerium operates. Circumstances may change when more stringent requirements are imposed on companies such as Monerium. Such constraints may limit our ability to provide our services as is. Monerium may also lose its license or be subject to further restrictions when Monerium fails to meet regulatory requirements. In any such circumstances, Monerium's ability to provide EURe holders with the same level of services may be limited. Operational risks: Operational risk can stem from the inadequate implementation, execution, or overall functioning of our internal systems, processes, or procedures. Failure to manage operational risks can lead to service delays or more severe deficiencies that can materially affect EURe issuance and redemption processes. Third-party risks: Monerium relies on multiple third parties to provide the services. A third party's failure in service delivery may lead to unexpected outcomes, such as delays in performing issuing and redemption functions. Compliance risks: Failure to comply with all applicable legal requirements governing Monerium operations can lead to legal penalties and reputational loss. Customers may temporarily or permanently lose access to issuing and redemption functions in cases where suspicion of money laundering, terrorist financing, sanction evasion, or other illegitimate activities arises. Market risks: Funds that Monerium safeguards on behalf of EURe holders can decrease in value and/or become illiquid due to market forces. In such scenarios, Monerium may not execute redemption requests within the expected execution times as stated in Monerium's Terms of Service. Environmental, Social, and Governance risks: With an increased focus on ESG factors, businesses' potential negative impact on the environment and societies must be assessed and controlled. ESG risks may prevent Monerium from issuing EURe on certain blockchain networks that utilize the Proof of Work consensus mechanism due to the alleged excessive energy consumption.
F.2	Token-related risks	Technical risks: Due to the technical nature of blockchain networks, EURe is subject to various technical risks, including third-party platforms, transaction irreversibility, and private key management. Materialized technical risks can lead to the irreversible loss of EURe. See more on technical risks and how they are managed in Section F.3 Technology-Related Risks Price stability risks: As EURe may be acquired on secondary markets, its market value might not be stable compared to EUR. Safeguarding risks: Mismanagement of the funds Monerium receives in exchange for EURe or the insolvency of our banking partners can lead to circumstances where the safeguarded assets decrease in value, subsequently becoming lower than the outstanding issued EURe. This risk could affect Monerium's ability to redeem EURe at par and promptly. Liquidity risks: Market conditions may be such that the financial instruments Monerium invests in the safeguarded assets can become illiquid, thus deterring Monerium's ability to perform redemption upon request. This risk can materialize during market stress, bank insolvencies, or Monerium financial difficulties. Market risks: Changes in the interest rate environment can affect the value of the financial instruments Monerium invests in the safeguarded assets. Under such circumstances, Monerium may be unable to redeem EURe at par value. Fraud risks: Risk of EURe holder loss resulting from fraud, scam, or other malicious actions. Fraud can include phishing attacks, identity theft, and general scams. Taxation risks: Due to the novelty of blockchain technology, EURe's tax treatment may differ between jurisdictions. Holders should also note that because MiCA defines EURe, it may qualify as a crypto-asset and electronic money. Thus, the tax treatment of EURe may vary among EEA member states. EURe holders are solely responsible for reporting and paying all, if any, taxes associated with their EURe usage. Regulatory risks: Changes in legislation or enforcement actions carried out against Monerium can affect the legality and price stability of EURe.
F.3	Technology-related risks	As Monerium utilizes open, permissionless blockchain networks, EURe holders can be exposed to unique technological risks. Blockchain risks: Blockchain networks can become subject to technical vulnerabilities, including attacks that can lead to network disruption, such as transaction downtime, which would prevent EURe holders from executing transactions during such disruptions. Other risks derived from the use of blockchain technology are identified below: Smart contract risks: Smart contracts deployed by Monerium that govern the mint, burn, and transaction functions of EURe can be exposed to technical vulnerabilities that hackers can exploit, leading to losses for EURe holders. Transaction risks: Blockchain transactions are generally irreversible. Therefore, losses due to fraudulent or accidental transactions may not be recoverable. Private key management risks: Holders control their EURe holdings with private keys. Mismanagement of private keys can thus lead to irrecoverable EURe loss. Interoperability risks: The opensource nature of blockchain networks allows for the ability to easily communicate, exchange data, and build on features and use cases created by others. This is generally referred to as interoperability. Consequently, EURe holders can use EURe within other blockchain products such as wallets, DeFi protocols, or decentralized applications (Dapps). Using thirdparty applications exposes EURe holders to technical risks associated with such products. Due to the permissionless nature of blockchain networks, Monerium cannot dictate who builds on top of EURe or allows EURe to be used within its products. Infrastructure risks: Monerium relies on thirdparty service providers who provide infrastructure services such as access and connection to blockchain networks. Failure in the services provided can lead to delays in EURe operations and the execution of blockchain transactions. Blockchain operational risks: Blockchain networks rely on consensus mechanisms to execute transactions. These mechanisms depend on the active participation of miners or validators. Plunges in validators' activity or failures can compromise the capabilities of the network of processing and validating transactions. Forking risks: Due to the technical nature of blockchains, a scenario may occur where the chain splits into two competing paths, i.e., a fork. Thus, a duplicate version of the chain is created that diverges from that point in time. In such cases, EURe holders may hold EURe tokens on both chains, but holders should note that Monerium EURe liabilities won't double. Forks may result in downtime, where EURe holder capabilities of performing EURe functions can be limited. Unidentified risks: Due to blockchain technology's novelty and immaturity, some risks can be unknown and untested. Thus, other risks not identified above may emerge and affect EURe holders' ability to perform certain functions. Technological risks: Monerium's IT infrastructure is subject to vulnerabilities and cyber threats. Failure or a security breach to Monerium's IT infrastructure can lead to potential financial losses, personal data leaks or breaches, operational disruptions, and damage to Monerium's reputation.
F.4	Mitigation measures	Issuer-related risks Insolvency risks: Monerium has appointed auditors who audit our financial statements for semiannual reporting to our supervisory authority as required of authorized Electronic Money Institutions. Reconciliations are performed daily where the matching of orders placed, funds received, and outstanding EURe is conducted. Our Reconciliation Policy outlines measures where the amount of these three subjects doesn’t match. Regulatory risks: Monerium's Risk Policy states that the company will obey the spirit and the letter of the laws and regulations that apply to the Company. Audits are carried out annually to ensure Monerium regulatory compliance. Operational risks: Internal audits are performed annually to maintain sound operational standards. Thirdparty risks: Monerium has established an outsourcing framework based on EBA guidelines to ensure that third parties carrying out functions on behalf of Monerium are fit for purpose. Compliance risks: Monerium has established a robust compliance program with external and internal requirements audited annually. Token-related risks Price stability risks: Monerium enables direct customer relationships with EURe holders, allowing them to redeem EURe at par. Safeguarding risks: Monerium has established a Reconciliation Policy that demands the conduction of reconciliation between the total value of issued EURe, orders, and safeguarded funds to be carried out at least daily. Monerium strives to establish safeguarding relationships with multiple trusted financial institutions. Liquidity risks: Monerium has established an Investment Policy to define investment policies and procedures for safeguarding customer funds. The policy establishes investment guidelines and limits towards credit, market, currency, liquidity, and operational risks. Market risks: Monerium has established an Investment Policy to define investment policies and procedures for safeguarding customer funds. The policy establishes investment guidelines and limits regarding credit, market, currency, liquidity, and operational risks. Fraud risks: In certain circumstances, Monerium can assist customers in recovering EURe associated with their address in cases where access to private keys has been lost. Taxation risks: Monerium supports its customers by offering account statements, which can help with tax filings. Regulatory risks: Monerium's risk policy states that the company will obey the spirit and the letter of the laws and regulations that apply to it. Audits are carried out annually to ensure Monerium regulatory compliance. Technology-related risks Smart contract risks: Monerium ensures that smart contracts are developed in accordance with industry standards to ensure the safe and secure development of our product. Thus, Monerium ensures that relations are established with industryleading security audit firms such as Ackee and Halborn. Transaction risks: Functions are introduced to our smart contract framework, preventing holders from sending EURe to known black holes. Private key management risks: An asset recovery process is available for customers who have linked a compromised address to Monerium services. Interoperability risks: Monerium strives to maintain a close and honest relationship with our community and users. When Monerium becomes aware of frauds or exploits that utilize EURe, holders will be notified via our communication channels. Blockchain operational risks: Conducting deployment analysis of the blockchain networks Monerium intends to support to ensure the chain has a healthy incentive mechanism and validator community. Monerium has identified measures to prevent irrecoverable loss for EURe holders when a supported blockchain becomes inactive or unavailable. Forking risks: Monerium reserves the right to determine which chain it will rely on going forward. Further disclaimers are provided for in our terms of service. Unidentified risks: Monerium has established robust and repetitive risk management practices.

Field

Content

F.1

Issuer-related risks

Monerium, as the issuer of EURe, is exposed to several risks that can affect its stability, usage, and reliability. Identified risks include, but are not limited to, insolvency risk, regulatory risk, operational risk, third-party risk, compliance risk, technological risks, market risks, and environmental, social, and governance (“ESG“) risks.

Insolvency risks: The risk of Monerium going bankrupt can severely impact the price stability of EURe and holders' capability to redeem EURe at par value. Insolvency risk can also impact Monerium's ability to perform redemptions upon request.

Regulatory risks: Monerium services are conditional on complying with regulatory requirements, including maintaining a license or other governmental authorizations in the jurisdictions in which Monerium operates. Circumstances may change when more stringent requirements are imposed on companies such as Monerium. Such constraints may limit our ability to provide our services as is. Monerium may also lose its license or be subject to further restrictions when Monerium fails to meet regulatory requirements. In any such circumstances, Monerium's ability to provide EURe holders with the same level of services may be limited.

Operational risks: Operational risk can stem from the inadequate implementation, execution, or overall functioning of our internal systems, processes, or procedures. Failure to manage operational risks can lead to service delays or more severe deficiencies that can materially affect EURe issuance and redemption processes.

Third-party risks: Monerium relies on multiple third parties to provide the services. A third party's failure in service delivery may lead to unexpected outcomes, such as delays in performing issuing and redemption functions.

Compliance risks: Failure to comply with all applicable legal requirements governing Monerium operations can lead to legal penalties and reputational loss. Customers may temporarily or permanently lose access to issuing and redemption functions in cases where suspicion of money laundering, terrorist financing, sanction evasion, or other illegitimate activities arises.

Market risks: Funds that Monerium safeguards on behalf of EURe holders can decrease in value and/or become illiquid due to market forces. In such scenarios, Monerium may not execute redemption requests within the expected execution times as stated in Monerium's Terms of Service.

Environmental, Social, and Governance risks: With an increased focus on ESG factors, businesses' potential negative impact on the environment and societies must be assessed and controlled. ESG risks may prevent Monerium from issuing EURe on certain blockchain networks that utilize the Proof of Work consensus mechanism due to the alleged excessive energy consumption.

F.2

Token-related risks

Technical risks: Due to the technical nature of blockchain networks, EURe is subject to various technical risks, including third-party platforms, transaction irreversibility, and private key management. Materialized technical risks can lead to the irreversible loss of EURe. See more on technical risks and how they are managed in Section F.3 Technology-Related Risks

Price stability risks: As EURe may be acquired on secondary markets, its market value might not be stable compared to EUR.

Safeguarding risks: Mismanagement of the funds Monerium receives in exchange for EURe or the insolvency of our banking partners can lead to circumstances where the safeguarded assets decrease in value, subsequently becoming lower than the outstanding issued EURe. This risk could affect Monerium's ability to redeem EURe at par and promptly.

Liquidity risks: Market conditions may be such that the financial instruments Monerium invests in the safeguarded assets can become illiquid, thus deterring Monerium's ability to perform redemption upon request. This risk can materialize during market stress, bank insolvencies, or Monerium financial difficulties.

Market risks: Changes in the interest rate environment can affect the value of the financial instruments Monerium invests in the safeguarded assets. Under such circumstances, Monerium may be unable to redeem EURe at par value.

Fraud risks: Risk of EURe holder loss resulting from fraud, scam, or other malicious actions. Fraud can include phishing attacks, identity theft, and general scams.

Taxation risks: Due to the novelty of blockchain technology, EURe's tax treatment may differ between jurisdictions. Holders should also note that because MiCA defines EURe, it may qualify as a crypto-asset and electronic money. Thus, the tax treatment of EURe may vary among EEA member states. EURe holders are solely responsible for reporting and paying all, if any, taxes associated with their EURe usage.

Regulatory risks: Changes in legislation or enforcement actions carried out against Monerium can affect the legality and price stability of EURe.

F.3

Technology-related risks

As Monerium utilizes open, permissionless blockchain networks, EURe holders can be exposed to unique technological risks.

Blockchain risks: Blockchain networks can become subject to technical vulnerabilities, including attacks that can lead to network disruption, such as transaction downtime, which would prevent EURe holders from executing transactions during such disruptions. Other risks derived from the use of blockchain technology are identified below:

Smart contract risks: Smart contracts deployed by Monerium that govern the mint, burn, and transaction functions of EURe can be exposed to technical vulnerabilities that hackers can exploit, leading to losses for EURe holders.
Transaction risks: Blockchain transactions are generally irreversible. Therefore, losses due to fraudulent or accidental transactions may not be recoverable.
Private key management risks: Holders control their EURe holdings with private keys. Mismanagement of private keys can thus lead to irrecoverable EURe loss.
Interoperability risks: The opensource nature of blockchain networks allows for the ability to easily communicate, exchange data, and build on features and use cases created by others. This is generally referred to as interoperability. Consequently, EURe holders can use EURe within other blockchain products such as wallets, DeFi protocols, or decentralized applications (Dapps). Using thirdparty applications exposes EURe holders to technical risks associated with such products. Due to the permissionless nature of blockchain networks, Monerium cannot dictate who builds on top of EURe or allows EURe to be used within its products.
Infrastructure risks: Monerium relies on thirdparty service providers who provide infrastructure services such as access and connection to blockchain networks. Failure in the services provided can lead to delays in EURe operations and the execution of blockchain transactions.
Blockchain operational risks: Blockchain networks rely on consensus mechanisms to execute transactions. These mechanisms depend on the active participation of miners or validators. Plunges in validators' activity or failures can compromise the capabilities of the network of processing and validating transactions.
Forking risks: Due to the technical nature of blockchains, a scenario may occur where the chain splits into two competing paths, i.e., a fork. Thus, a duplicate version of the chain is created that diverges from that point in time. In such cases, EURe holders may hold EURe tokens on both chains, but holders should note that Monerium EURe liabilities won't double. Forks may result in downtime, where EURe holder capabilities of performing EURe functions can be limited.
Unidentified risks: Due to blockchain technology's novelty and immaturity, some risks can be unknown and untested. Thus, other risks not identified above may emerge and affect EURe holders' ability to perform certain functions.
1. Technological risks: Monerium's IT infrastructure is subject to vulnerabilities and cyber threats. Failure or a security breach to Monerium's IT infrastructure can lead to potential financial losses, personal data leaks or breaches, operational disruptions, and damage to Monerium's reputation.

F.4

Mitigation measures

Issuer-related risks

Insolvency risks: Monerium has appointed auditors who audit our financial statements for semiannual reporting to our supervisory authority as required of authorized Electronic Money Institutions. Reconciliations are performed daily where the matching of orders placed, funds received, and outstanding EURe is conducted. Our Reconciliation Policy outlines measures where the amount of these three subjects doesn’t match.
Regulatory risks: Monerium's Risk Policy states that the company will obey the spirit and the letter of the laws and regulations that apply to the Company. Audits are carried out annually to ensure Monerium regulatory compliance.
Operational risks: Internal audits are performed annually to maintain sound operational standards.
Thirdparty risks: Monerium has established an outsourcing framework based on EBA guidelines to ensure that third parties carrying out functions on behalf of Monerium are fit for purpose.
Compliance risks: Monerium has established a robust compliance program with external and internal requirements audited annually.
1. Token-related risks
Price stability risks: Monerium enables direct customer relationships with EURe holders, allowing them to redeem EURe at par.
Safeguarding risks: Monerium has established a Reconciliation Policy that demands the conduction of reconciliation between the total value of issued EURe, orders, and safeguarded funds to be carried out at least daily. Monerium strives to establish safeguarding relationships with multiple trusted financial institutions.
Liquidity risks: Monerium has established an Investment Policy to define investment policies and procedures for safeguarding customer funds. The policy establishes investment guidelines and limits towards credit, market, currency, liquidity, and operational risks.
Market risks: Monerium has established an Investment Policy to define investment policies and procedures for safeguarding customer funds. The policy establishes investment guidelines and limits regarding credit, market, currency, liquidity, and operational risks.
Fraud risks: In certain circumstances, Monerium can assist customers in recovering EURe associated with their address in cases where access to private keys has been lost.
Taxation risks: Monerium supports its customers by offering account statements, which can help with tax filings.
Regulatory risks: Monerium's risk policy states that the company will obey the spirit and the letter of the laws and regulations that apply to it. Audits are carried out annually to ensure Monerium regulatory compliance.
1. Technology-related risks
Smart contract risks: Monerium ensures that smart contracts are developed in accordance with industry standards to ensure the safe and secure development of our product. Thus, Monerium ensures that relations are established with industryleading security audit firms such as Ackee and Halborn.
Transaction risks: Functions are introduced to our smart contract framework, preventing holders from sending EURe to known black holes.
Private key management risks: An asset recovery process is available for customers who have linked a compromised address to Monerium services.
Interoperability risks: Monerium strives to maintain a close and honest relationship with our community and users. When Monerium becomes aware of frauds or exploits that utilize EURe, holders will be notified via our communication channels.
Blockchain operational risks: Conducting deployment analysis of the blockchain networks Monerium intends to support to ensure the chain has a healthy incentive mechanism and validator community. Monerium has identified measures to prevent irrecoverable loss for EURe holders when a supported blockchain becomes inactive or unavailable.
Forking risks: Monerium reserves the right to determine which chain it will rely on going forward. Further disclaimers are provided for in our terms of service.
Unidentified risks: Monerium has established robust and repetitive risk management practices.

Part G - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts

Field

Content

Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism

General information about adverse impacts

S.1

Name

Monerium hf.

S.2

Relevant legal entity identifier

2549003QDNZWASSSCY31

S.3

Name of the crypto-asset

EURe

S.4

Consensus mechanism

EURe does not have its own consensus mechanism. As an e-money token issued on third-party networks, EURe leverages, and inherits the transaction ordering, data-availability and finality properties of each underlying blockchain on which it is supported. The security and liveness of EURe transfers therefore depend on the consensus design and operational integrity of those base layers.
On Ethereum, transaction ordering and finality are provided by Ethereum’s Proof-of-Stake consensus mechanism. Validators participate as block proposers and attesters, following Ethereum’s fork-choice rules and finality gadget to agree on the canonical chain and provide economic finality for blocks containing EURe transactions.
On Gnosis Chain, EURe relies on Gnosis’ Proof-of-Stake consensus. Gnosis transitioned to this model through “The Merge” on Gnosis, adopting a separation between an execution layer and a PoS consensus layer. Validators in this model are responsible for proposing and validating blocks, and for finalising the chain that records EURe transfers.
On Polygon PoS, EURe is recorded on a Proof-of-Stake network operated by a validator set that handles block production, validation and chain security. Polygon’s PoS architecture defines validator roles and the settlement design that together determine the ordering and confirmation of EURe transactions on this network.
On Arbitrum, EURe operates on an optimistic rollup built on top of Ethereum. Arbitrum uses a sequencer-based ordering layer to provide fast inclusion of transactions: the sequencer orders and batches user transactions, including those involving EURe. Ultimate settlement and finality are anchored to Ethereum Layer 1, with withdrawals and finality dependent on the rollup’s dispute and challenge process on Ethereum.
On Linea, EURe is supported on a zero-knowledge rollup that also relies on Ethereum for final settlement. Linea orders transactions via a sequencer and achieves economic finality through validity proofs that are verified on Ethereum. Blocks are treated as final once their associated proofs have been accepted on Layer 1, with Linea’s architecture also documenting internal coordination and attestation components that support this flow.
On Noble, EURe relies on Noble’s use of CometBFT for consensus and its Proof-of-Authority model. Noble operates with a permissioned validator set, as described in Noble’s PoA documentation. These validators run CometBFT consensus to order transactions, commit blocks and provide finality for EURe state transitions on Noble.
Across all these environments, EURe does not modify or extend the base-layer consensus rules. Instead, it is a token whose correctness and finality are determined by the consensus mechanisms of Ethereum, Gnosis Chain, Polygon PoS, Arbitrum, Linea and Noble respectively.

S.5

Incentive Mechanisms and Applicable Fees

See E.6

S.6

Beginning of the period to which the disclosed information relates

2025-01-15

S.7

End of the period to which the disclosed information relates

2025-12-16

Mandatory key indicator

S.8

Energy consumption

235.15755

Sources and methodologies

S.9

Energy consumption sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at : www.micacryptoalliance.com/methodology

Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of the consensus mechanism

Supplementary key indicators

S.10

Renewable energy consumption

0.3525053275

S.11

Energy intensity

0.00077

S.12

Scope 1 DLT GHG emissions – Controlled

0.00000

S.13

Scope 2 DLT GHG emissions – Purchased

0.07513

S.14

GHG intensity

0.00024

Sources and methodologies

S.15

Key energy sources and methodologies

S.16

Key GHG sources and methodologies

Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism

Optional indicators

S.17

Energy mix

Energy source	Percentage {DECIMAL-11/10}
Bioenergy	2.9652498894%
Coal	17.8001666181%
Flared Methane	0.0000000000%
Gas	30.4894480311%
Hydro	9.4943286996%
Nuclear	14.4818746028%
Other Fossil	1.9779779966%
Other Renewables	0.4303517578%
Solar	6.8062342075%
Vented Methane	0.0000000000%
Wind	15.5543681972%

S.18

Energy use reduction

N/A

S.19

Carbon intensity

0.31949

S.20

Scope 3 DLT GHG emissions – Value chain

N/A

S.21

GHG emissions reduction targets or commitments

N/A

S.22

Generation of waste electrical and electronic equipment (WEEE)

0.00033

S.23

Non-recycled WEEE ratio

0.6107881838

S.24

Generation of hazardous waste

0.0000001664

S.25

Generation of waste (all types)

0.00033

S.26

Non-recycled waste ratio (all types)

0.6107881838

S.27

Waste intensity (all types)

0.00109

S.28

Waste reduction targets or commitments (all types)

FALSE

S.29

Impact of the use of equipment on natural resources

5.68599

S.30

Natural resources use reduction targets or commitments

FALSE

S.31

Water use

1.00358

S.32

Non recycled water ratio

0.7291635578

Sources and and methodologies

S.33

Other energy sources and methodologies

S.34

Other GHG sources and methodologies

S.35

Waste sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).Estimates on individual node weight, hazardous components and deprecation rate are used.
Full methodology available at: www.micacryptoalliance.com/methodologies

S.36

Natural resources sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5). Usage of natural resources is approximated through land use metrics. Land use, water use and water recycling are calculated based on energy mix-specific estimates of purchased electricity land intensity, purchased electricity water intensity, and water recycling rates. Full methodology available at: www.micacryptoalliance.com/methodologies

Disclaimer: This document is made available by the MiCA Crypto Alliance Limited ("MiCA Crypto Alliance"), trading as “The MiCA Crypto Alliance”. MiCA Crypto Alliance does not provide any warranty of any kind, express or implied, including but not limited to warranties of accuracy, fitness for a particular purpose, compliance with any laws and/or non-infringement. MiCA Crypto Alliance also assumes no responsibility for any errors, defects, or omissions in the document. To the maximum extent permitted by applicable laws, MiCA Crypto Alliance will not be liable for any direct, indirect, incidental, special, consequential, or exemplary damages, including but not limited to, damages for loss of profits, goodwill, data, or other intangible losses arising out of or relating to any use and/or reliance on the information in this document, however arising, including negligence.

General information	Page 3
Part A - Information about the issuer of the e-money token	Page 4
Part B - Information about the e-money token	Page 5
Part C - Information about the offer to the public of the e-money token or its admission to trading	Page 6
Part D - Information on the rights and obligations attached to e-money tokens	Page 7
Part E - Information on the underlying technology	Page 8
Part F - Information on the risks	Page 9
Part G - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts	Page 10

Index

General information

Part A - Information about the issuer of the e-money token

Part B - Information about the e-money token

Part C - Information about the offer to the public of the e-money token or its admission to trading

Part D - Information on the rights and obligations attached to e-money tokens

Part E - Information on the underlying technology

Part F - Information on the risks

Part G - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts