MODIFIED CRYPTO-ASSET WHITE PAPER (ARTICLE 12)
This is a modified crypto-asset white paper notified under Article 12
of Regulation (EU) 2023/1114. It modifies the crypto-asset white paper for the $IOI token
notified to the Central Bank of Ireland on 7 April 2026 (DTI MWMGJ5CHL, functionally fungible
group DTI KS4PZL3ZV). It is not a new notification.
The modifications concern the classification of the offer, the token
allocation and vesting disclosure at field E.18 and the figures dependent on it, the utility
functions of the token, the offer and token generation event dates, the refund period, the
roadmap, the host Member States, and the conflict of interest disclosure. A field by field
statement of the modifications, and the reasons for them, accompanies this white paper in the
summary of changes submitted to the Central Bank of Ireland.
Summary
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 crypto-asset 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 any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to Union or 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.
[08] Characteristics of the Crypto-Asset
The $IOI token is a BEP-20 utility token deployed on BNB Smart Chain with a fixed total supply of 1,000,000,000 tokens. It grants holders access to the IOTrader protocol's core services: leveraged prediction markets, perpetual futures trading, staking for fee-sharing, trading fee discounts, custom market creation with a share of that market's transaction fees, and future DAO governance. The token does not confer equity, debt, or profit-sharing rights. Holders are responsible for self-custody of their tokens and compliance with applicable laws.
[09] Utility Token Goods/Services
The $IOI utility token provides access to the following services on the IOTrader protocol: (1) Leveraged prediction markets on crypto and commodity prices, (2) Perpetual futures trading with up to 20x leverage, (3) Staking to earn protocol fee revenue, (4) Permissionless custom market creation, with the creator receiving a share of that market's transaction fees, (5) Trading fee discounts based on staking tiers. The protocol is accessible at app.iotrader.io. There are no restrictions on transferability beyond standard BEP-20 transfer requirements (BNB gas fees).
[10] Key Information about the Offer
The $IOI token is being offered to the public and admitted to trading. Total supply: 1,000,000,000 tokens. Issue price: USD 0.080. No subscription fees. Targeted holders: all types of investors (retail and professional). The token sale comprises four rounds: Seed (USD 0.010, 3.000%), Private (USD 0.050, 5.000%), KOL (USD 0.040, 1.000%), and Public (USD 0.080, 1.625%). The remaining 89.375% of supply is allocated to Team, Ecosystem Alpha, CEX Allocation, ECO and Marketing, Airdrop, Reserve, Foundation and Liquidity, as set out in full in field E.18. Early purchasers received discounts of 37.5% to 87.5% relative to the public offer price, subject to vesting schedules of up to 22 months including 12-month cliffs on the Seed and Private allocations. No crypto-asset service provider is in charge of the placing and the offer is settled on-chain. Trading platforms: Kraken (CEX) and PancakeSwap (DEX).
Part D — Information about the Crypto-Asset Project
[D.2]
IOTrader Token ($IOI)
[D.4]
IOTrader is an advanced, non-custodial, composable decentralised finance (DeFi) protocol deployed on the BNB Smart Chain. The protocol introduces a new class of trading primitive known as Leveraged Prediction Markets, combining perpetual futures trading (up to 20x leverage), on-chain price predictions powered by Chainlink and Pyth oracles, and permissionless custom prediction markets into a single unified interface. The $IOI token is the native utility token of the IOTrader ecosystem, granting holders access to protocol services, staking rewards funded from protocol transaction fees, tiered fee discounts, custom market creation with a share of that market's fees, and future governance rights.
[D.5]
Ali Emmali | Director and Founder | IO TRADE LAB LIMITED | Flat A-B, 162-164 High Street North, London, E6 2JA, UK; Blockchain Tools Tech | Security Auditor | Independent third-party smart contract auditing firm; Chainlink Labs | Oracle Provider | Decentralised oracle network for price feeds; Pyth Network | Oracle Provider | High-frequency oracle network for price feeds.
[D.7]
The $IOI utility token provides digital access to the following goods and services on the IOTrader protocol: (1) Protocol Access — native token for interacting with predictions, perpetual futures, and custom markets; (2) Staking — users stake $IOI to earn a proportional share of protocol-generated fees from trading, settlement, and liquidations; (3) Custom Market Creation — creators post $IOI as collateral to create a prediction market and receive a share of the transaction fees generated by that market; (4) Trading Fee Discounts — tiered fee discounts for holders above the minimum staking threshold; (5) Governance (future) — DAO voting on protocol parameters, fee structures, and development priorities, targeted for Q4 2026.
[D.8]
Phase 1 — Foundation (completed): company incorporation on 7 May 2025, smart contract architecture, initial funding. Phase 2 — Testnet and security audit (completed): testnet deployment, security audit by Blockchain Tools Tech, and UI/UX development; audit findings were addressed prior to mainnet deployment. Phase 3 — Mainnet deployment (completed): the IOTrader protocol was deployed on BNB Smart Chain and has been live and generating transaction fee revenue since mid 2025. Phase 4 — Token generation event preparation (completed): exchange listing negotiations, community building, and notification of this modified white paper to the Central Bank of Ireland. Phase 5 — Token generation event and listing (Q3 2026, scheduled for 28 August 2026): $IOI token generation event, listing on Kraken, and deployment of protocol-owned liquidity on PancakeSwap, as recorded at fields E.28 and F.9. Phase 6 — Expansion (Q4 2026 to Q2 2027): DAO governance implementation in Q4 2026, cross-chain deployment, institutional partnerships, and advanced market types.
[D.9]
Approximately USD 3,200,000 has been raised to date through the token sale rounds. Allocation: 35% Product and Protocol Development (smart contract engineering, oracle integration, front-end development, security audits); 35% Liquidity and Market-Making (CEX and DEX liquidity provisioning, market-making partnerships); 30% Operations, Legal, and Compliance (team salaries, legal advisory, regulatory compliance, marketing and community growth).
[D.10]
Funds collected from token sales are allocated to: smart contract development and ongoing security audits, oracle integration and infrastructure costs, initial liquidity provisioning on Kraken (CEX) and PancakeSwap (DEX), exchange listing fees, legal and regulatory compliance costs including MiCA white paper preparation, marketing, community building, and partnership development, operational costs including team compensation and administrative expenses.
Part E — Information about the Offer to the Public or Admission to Trading
[E.2]
The offeror is conducting an offer to the public of the Public Round allocation of $IOI and is separately seeking admission to trading of the $IOI token on licensed crypto-asset service providers, in order to provide global liquidity, establish a transparent market price, and enable holders to exercise the utility functions of the token within the IOTrader protocol ecosystem.
[E.3]
USD 1,300,000, being the Public Round allocation of 16,250,000 IOI at USD 0.080 per token.
[E.4]
No minimum subscription goal applies. The offer is not conditional on a minimum subscription being reached.
[E.5]
USD 1,300,000, equal to the full Public Round allocation of 16,250,000 IOI at USD 0.080 per token.
[E.7]
Not applicable (E.6 is false).
[E.11]
The issue price of USD 0.080 per $IOI token was determined by the offeror based on the valuation implied by the seed and private rounds, protocol revenue generated to date, comparable decentralised finance protocol valuations, and the total fixed supply of 1,000,000,000 tokens, implying a fully diluted valuation of USD 80,000,000. After the token generation event, the price will be determined by market supply and demand on the trading platforms.
[E.14]
No restrictions on the type of holders. All investors (retail and professional) may hold $IOI tokens, subject to standard KYC/AML requirements of the listing exchange (Kraken) and applicable laws in the holder's jurisdiction. The token may not be offered or sold in jurisdictions where such offer or sale would be prohibited.
[E.15]
No minimum subscription goal applies to this offer, so no reimbursement arises on that basis. Purchasers participating in the offer to the public will be able to be reimbursed if they exercise the right of withdrawal provided for in Article 13 of Regulation (EU) 2023/1114 of the European Parliament and of the Council, or if the offer is cancelled.
[E.16]
Refunds, where applicable, will be processed in the crypto-asset used for the original purchase (BNB or USDC) and sent to the originating wallet address.
[E.17]
Refunds will be completed within 14 days from the date the refund obligation arises.
[E.18]
The total supply of 1,000,000,000 IOI is allocated in full as follows. Seed Round: 3.000% of total supply (30,000,000 tokens), price USD 0.010, 0% released at TGE, 12-month cliff followed by 6 months linear vesting. Private Round: 5.000% (50,000,000 tokens), price USD 0.050, 0% at TGE, 12-month cliff followed by 10 months linear vesting. KOL Round: 1.000% (10,000,000 tokens), price USD 0.040, 12% at TGE, 2-month cliff followed by 8 months linear vesting. Public Round: 1.625% (16,250,000 tokens), price USD 0.080, 20% at TGE, 2-month cliff followed by 6 months linear vesting. Team: 8.000% (80,000,000 tokens), 0% at TGE, 12-month cliff followed by 24 months linear vesting. Ecosystem Alpha: 4.000% (40,000,000 tokens), 0% at TGE, 4-month cliff followed by 18 months linear vesting. CEX Allocation: 5.000% (50,000,000 tokens), 50% at TGE, 1-month cliff followed by 12 months linear vesting. ECO and Marketing: 24.000% (240,000,000 tokens), 0% at TGE, 16 months linear vesting. Airdrop: 3.000% (30,000,000 tokens), 0% at TGE, 3-month cliff followed by 12 months linear vesting. Reserve: 18.375% (183,750,000 tokens), 0% at TGE, 48 months linear vesting. Foundation: 20.000% (200,000,000 tokens), 0% at TGE, 12-month cliff followed by 36 months linear vesting. Liquidity: 7.000% (70,000,000 tokens), 100% deployed at TGE. Total: 100.000% (1,000,000,000 tokens). At the token generation event 99,450,000 tokens are released from their vesting contracts. Of those, 8,450,000 tokens (0.845% of total supply) enter circulation and constitute the market-facing float, comprising the KOL round unlock of 1,200,000, the Public Round unlock of 3,250,000 and 4,000,000 of deployed liquidity. The remaining 91,000,000 tokens are released from vesting but do not enter circulation at the token generation event: 25,000,000 are held in exchange custody under market maker agreements to support listing and market-making, and 66,000,000 are bonded as protocol-owned liquidity in decentralised exchange pools and are not available for sale. There is no separate staking-reward pool and no liquidity-provision-reward pool within the allocation. Staking rewards are paid from protocol transaction fees generated by trading activity and are not drawn from any token allocation. Rewards to creators of custom prediction markets are likewise a share of the transaction fees generated by the market concerned. The Liquidity allocation of 70,000,000 tokens is protocol-owned liquidity deployed by the offeror into decentralised exchange pools, including PancakeSwap, and is not distributed to holders as an incentive. No token emissions accrue to liquidity providers.
[E.19]
Seed round purchasers received an 87.5% discount relative to the public offer price (USD 0.010 vs USD 0.080). Private round purchasers received a 37.5% discount (USD 0.050 vs USD 0.080). KOL round purchasers received a 50% discount (USD 0.040 vs USD 0.080). The discounted prices reflect the higher risk assumed by early-stage purchasers, who committed capital at earlier stages of the project's development and before any trading market for the token existed. Early purchasers are subject to vesting schedules of up to 22 months, including 12-month cliffs on the Seed and Private allocations, which restrict their ability to sell tokens immediately and support orderly price formation.
[E.21]
Not applicable (E.20 is false; the offer is not time-limited).
[E.22]
Not applicable (E.20 is false).
[E.23]
Funds received during the offer are safeguarded in multi-signature wallets requiring multiple authorised signatories for any transaction. Smart contract escrow mechanisms ensure that token allocations are locked according to the published vesting schedules and cannot be released prematurely.
[E.24]
BNB and USDC, both on BNB Smart Chain. The offer is settled on-chain and no fiat currency is accepted.
[E.25]
Reimbursement will be made in the same crypto-asset used for the original purchase and will be sent to the originating wallet address.
[E.26]
Purchasers who acquire $IOI tokens through an offer to the public have the right to withdraw their agreement to purchase within 14 calendar days, without incurring any fees and without giving reasons, in accordance with Article 13 of Regulation (EU) 2023/1114. The right of withdrawal may be exercised by sending a written notice to contact@iotrader.io within the 14-day period.
[E.27]
Purchased $IOI tokens are transferred on-chain as BEP-20 tokens on the BNB Smart Chain to the purchaser's designated wallet address. Tokens subject to vesting are held in a vesting smart contract and released automatically according to the published schedule.
[E.29]
Purchasers must have a BNB Smart Chain compatible wallet (e.g., MetaMask, Trust Wallet, or any EVM-compatible wallet) and a small amount of BNB to cover network gas fees (approximately USD 0.03 per transaction).
[E.30]
Not applicable. No crypto-asset service provider is placing the crypto-assets on behalf of the offeror. The offer is conducted directly by the offeror and settled on-chain.
[E.31]
Not applicable. No crypto-asset service provider is placing the crypto-assets.
[E.33]
Kraken; PancakeSwap (decentralised exchange on BNB Smart Chain)
[E.34]
Not applicable (crypto-asset trading platforms do not have MIC codes under ISO 10383).
[E.35]
Kraken: https://www.kraken.com — Accessible globally via web browser and mobile application. PancakeSwap: https://pancakeswap.finance — Accessible via any Web3-enabled browser with a BSC-compatible wallet.
[E.36]
Kraken: standard trading fees per Kraken's published fee schedule (maker/taker fees ranging from 0.00% to 0.26% depending on 30-day trading volume). PancakeSwap: 0.25% swap fee per transaction. BNB Smart Chain: network gas fees of approximately USD 0.03 per transaction.
[E.37]
Legal and regulatory advisory: approximately USD 50,000. Smart contract security audit (Blockchain Tools Tech): approximately USD 30,000. Marketing and community building: approximately USD 200,000. Total estimated offer expenses, excluding exchange listing fees: approximately USD 280,000. Exchange listing fees are confidential and subject to commercial agreement with the trading platform, and are not included in the total stated above.
[E.38]
The sole director of IO TRADE LAB LIMITED is responsible for all decisions relating to the token issuance, protocol development, and fund allocation. This concentration of decision-making authority constitutes a potential conflict of interest. To mitigate this, protocol governance will transition to a decentralised autonomous organisation (DAO) model, at which point token holders will have voting rights over protocol parameters. The sole director does not hold any $IOI in a personal capacity. Tokens earmarked for ecosystem growth, partnerships, and community incentives are held at project level within the Ecosystem Alpha allocation (4.000% of total supply, 40,000,000 tokens) and the ECO and Marketing allocation (24.000% of total supply, 240,000,000 tokens), as set out at field E.18. Tokens not in circulation are held by the issuer and by the protocol foundation and are subject to the vesting schedules set out at field E.18. No other material conflicts of interest have been identified.
[E.39]
Laws of England and Wales
[E.40]
Courts of England and Wales
Part F — Information about the Crypto-Assets
[F.1]
BEP-20 utility token on BNB Smart Chain (BSC). The $IOI token is classified as a crypto-asset other than an asset-referenced token or e-money token, and specifically as a utility token within the meaning of Article 3(1), point (9), of Regulation (EU) 2023/1114.
[F.2]
The $IOI token serves five core utility functions within the IOTrader protocol: (1) Protocol Access, (2) Staking for fee-sharing, (3) Custom Market Creation collateral, with the creator receiving a share of the fees generated by that market, (4) Trading Fee Discounts, and (5) Governance voting rights (future, Q4 2026).
[F.3]
Core utility functions (protocol access, staking, fee discounts, custom market creation) are implemented in the IOTrader protocol, which has been live on BNB Smart Chain mainnet since mid 2025. Those functions become exercisable by holders of $IOI from the token generation event on 28 August 2026, being the date recorded at fields E.28 and F.9. DAO governance functionality is planned for Q4 2026.
[F.6]
BEP-20 standard token on BNB Smart Chain. Fixed total supply of 1,000,000,000 tokens. 18 decimal places. Non-mintable (no new tokens can be created after deployment). Non-rebasing. Smart contract deployed on BNB Smart Chain with verified source code.
[F.8]
https://iotrader.io
[F.11]
The issuer provides decentralised finance trading services through the IOTrader protocol, including leveraged prediction markets, perpetual futures trading, and permissionless custom prediction markets. These services are not separately regulated under Regulation (EU) 2023/1114 as they are provided through a non-custodial smart contract protocol.
[F.19]
Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden
Part G — Information on the Rights and Obligations Attached to the Crypto-Assets
[G.1]
Rights: Holders of $IOI tokens have the right to: (a) access and use all features of the IOTrader protocol; (b) stake tokens to receive a proportional share of protocol transaction fees distributed by smart contract; (c) receive tiered trading fee discounts based on staking amount; (d) create custom prediction markets using tokens as collateral, the creator of a market receiving a share of the fees generated by that market for as long as it operates; (e) participate in DAO governance votes on protocol parameters (future). Obligations: Holders are responsible for: (a) safeguarding their own private keys and wallet access; (b) compliance with all applicable laws and regulations in their jurisdiction; (c) payment of gas fees for on-chain transactions; (d) conducting their own due diligence before trading or staking. For the avoidance of doubt, the $IOI token does not confer any equity, debt, dividend, profit-sharing or ownership rights in IO TRADE LAB LIMITED. Holders have no claim on the revenues, profits or assets of the issuer, and the issuer is under no obligation to make any payment to holders. Staking rewards are not a distribution of issuer profits. They are an allocation of transaction fees generated by the protocol, executed autonomously by smart contract in consideration for the holder locking tokens and thereby supporting protocol function, and they are contingent on protocol usage rather than on the financial performance of the issuer. Where there is no protocol activity, no reward accrues.
[G.2]
To exercise their rights, holders must connect a BNB Smart Chain compatible wallet (e.g., MetaMask, Trust Wallet) to the IOTrader protocol interface at app.iotrader.io. Staking is performed via the protocol's staking smart contract. Trading and prediction market participation are conducted through the protocol's trading interface. All interactions require BNB for gas fees.
[G.3]
Protocol parameters (fee rates, staking thresholds, fee distribution parameters) may be modified through DAO governance votes once governance functionality is implemented (target Q4 2026). Prior to DAO implementation, the management body of IO TRADE LAB LIMITED may modify protocol parameters with a minimum of 30 days' advance notice published on the protocol website and communicated via official channels. Token holder rights as described in this white paper may only be modified with reasonable notice and in good faith.
[G.4]
The Public Round allocation of 16,250,000 tokens is offered to the public at USD 0.080 in connection with this white paper. Beyond that allocation, no further public offers of $IOI tokens are planned. The total supply is fixed at 1,000,000,000 tokens and the smart contract is non-mintable, meaning no additional tokens can ever be created.
[G.7]
The $IOI utility token gives access to the following goods and services: leveraged prediction markets on crypto and commodity prices; perpetual futures trading with up to 20x leverage using Chainlink and Pyth oracle price feeds; permissionless custom prediction market creation; staking rewards from protocol fee revenue; and tiered trading fee discounts. The protocol is accessible at app.iotrader.io.
[G.8]
The $IOI token is not redeemable against the issuer for fiat currency or other crypto-assets. The token grants access to protocol services as described in this white paper. The value of the token is derived from its utility within the IOTrader ecosystem and market supply and demand. Holders may sell their tokens on supported trading platforms (Kraken, PancakeSwap) at the prevailing market price.
[G.10]
After listing, $IOI tokens can be purchased and sold on: Kraken (centralised exchange) at https://www.kraken.com; PancakeSwap (decentralised exchange) at https://pancakeswap.finance. Tokens can also be transferred peer-to-peer on the BNB Smart Chain at any time without restriction.
[G.11]
$IOI is a standard BEP-20 token. Once released, tokens can be freely transferred between any BNB Smart Chain wallet addresses, the only requirement being BNB for gas fees. No transfer restriction is embedded in the token contract itself. Tokens that have not yet been released are held in vesting smart contracts and cannot be transferred until their scheduled release dates. The allocations subject to vesting are set out in full at field E.18 and comprise the Seed, Private, KOL and Public Rounds, and the Team, Ecosystem Alpha, CEX, ECO and Marketing, Airdrop, Reserve, Foundation and Liquidity allocations. Purchasers in the Public Round should note that 20% of their allocation is released at the token generation event and the balance is subject to a 2-month cliff followed by 6 months linear vesting.
[G.13]
Not applicable (G.12 is false; the $IOI token has a fixed supply of 1,000,000,000 with no mint or burn mechanisms).
[G.15]
Not applicable (G.14 is false; there is no value protection scheme for the $IOI token).
[G.17]
Not applicable (G.16 is false; there is no compensation scheme for $IOI token holders).
[G.18]
Laws of England and Wales
[G.19]
Courts of England and Wales