Whitepaper requirements
The whitepaper has two functions: to explain the game and the economy to players and partners, and to meet the legal requirements should there ever be a token offering to the public (no sale is planned today, nor a private round; see 14). The most complete and clear requirements today are those of MiCA (European Union, Regulation 2023/1114, applicable to tokens since 12/30/2024). Following MiCA as a standard covers much of what other jurisdictions ask for. This document does not replace the legal opinion.
Preconditions (before writing the final version)
- Incorporated company (none exists today). MiCA requires the offeror to be a legal entity, with identification (LEI), address and a management body.
- Legal opinion on the token's classification in Brazil (CVM; the Crypto-Assets Legal Framework, Law 14,478/2022, and the Central Bank regulation for service providers), in the US (SEC; Howey test) and in the EU (MiCA).
- Decide where and to whom the token will be offered (allowed and blocked countries).
- Smart contract audit by an independent firm.
- KYC and anti-money-laundering policy.
- Name of the game and of the token (pending).
Structure (follows MiCA Annex I)
| Part | Content | Source in the repository |
|---|---|---|
| Cover | Date; notice that the document has not been approved by any authority and that the offeror is solely responsible | — |
| Management statement | That the document complies with the rule and is fair, clear and not misleading | — |
| Summary | In plain language, with the mandatory warnings (not a prospectus; may lose value) | — |
| A — Offeror | Name, legal form, address, LEI, contact, managers, activity, financial situation for the last 3 years | company to be incorporated |
| D — Project | Project and token name, ticker, description, team, past and future milestones, use of funds | README, 03, 04, 06 |
| E — Offer | Only if there is an offer (no sale is planned today): quantity, price, phases, audience, right of withdrawal, custody of funds, applicable law | 14 |
| F — The token | Type, characteristics, how it works, data for classification | 14 sections 2 and 3 |
| G — Rights and obligations | What the token does and does not give (it gives no profit share or dividends), transfer, offer and burn rules, absence of deposit guarantee protection | 14 |
| H — Technology | Network, contract standard (ERC-20 and ERC-721/1155), consensus mechanism, audit result | 05, 08 |
| I — Risks | Of the offeror, the project, the token, the technology, the market, regulatory | 07 |
| Environmental impact | Annual electricity consumption of the network's consensus mechanism (mandatory; proof of stake has low consumption) | 08 |
Drafting rules (mandatory under MiCA and good practice in general)
- No statement about the token's future value.
- State clearly that the token may lose all value, may not be transferable or liquid and is not covered by a guarantee fund or investor protection scheme.
- Separate fact (what exists) from forecast (what is planned), marking each forecast as such.
- Dated document, with an index, in machine-readable format (MiCA requires iXBRL since 12/23/2025).
- Marketing materials consistent with the whitepaper and carrying the same risk warning.
Content beyond the legal minimum (what players and investors expect)
- Vision, pillars and why the game is fun without the token (
03). - World, schedules and events (
04). - Two-layer economy, gold × token, the currency of each market and the sink rule (
14). Player earnings described as a small, variable extra, with a declared withdrawal cap; no "income", "job", "APY", appreciation or deflation. - Land (
15), professions (09), PvP (13), mounts and buildings (10). - Tokenomics with distribution, schedule and circulation charts (
14+ model). - Governance: players do not vote on the treasury; the treasury belongs to the studio, with a public monthly report.
- Roadmap with exit criteria (
06). - Team, advisors and partners (to be defined).
- Access and age: wallet, token, market, NFT and voice only for verified 18+; minors play without the economy; age rating planned.
- Distribution: own launcher and Epic Games Store; Steam not planned (its policy bars blockchain and NFTs; recheck).
- Security: audit, multisig, bridge limits, KYC (one eligible account per person), anti-bot, non-custodial wallet and on/off-ramp only through a licensed partner.
- Transparency: monthly treasury report, public addresses of the contracts and wallets.
Exceptions that can exempt the whitepaper under MiCA
An offer to fewer than 150 people per EU country, or below € 1 million in 12 months, or only to qualified investors, or a token that gives access to a service that already exists and is running. That last one is relevant: selling the token only after the game is live simplifies the legal side.
Proposed order
- Public "lite" version (vision, game, economy, no token sale), for community and partners: possible already with the current documentation.
- Full whitepaper, after the company, the legal opinion, the audit and the alpha numbers.