1. OBLIGATION TO DISCLOSE SUSTAINABILITY INFORMATION UNDER MiCA

Article 66(5) of Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) requires crypto-asset service providers (CASPs) to publicly disclose information on adverse impacts on the environment and climate. That obligation also includes the requirement to describe the principal adverse effects of the consensus mechanism used on the climate and the environment.

2. WHAT IS A CONSENSUS MECHANISM?

Traditional databases are maintained and controlled by a central administrator, who is responsible for verifying transactions and recording data.

Unlike traditional databases, public blockchain databases have no central administrator, but instead rely on a decentralised network of thousands of users who jointly maintain distributed ledgers. A consensus mechanism is a standardised procedure by which network nodes reliably reach agreement on the validity of transactions and the current state of the main ledger.

3. TYPES OF CONSENSUS MECHANISMS IN BLOCKCHAIN TECHNOLOGIES

3.1 Proof of Work

Proof of Work (PoW) is a consensus mechanism that selects the proposer of the next block by requiring network nodes to solve computationally demanding mathematical problems. Miners compete with one another in solving complex cryptographic tasks. The first miner to find a solution receives, as a reward, the mined crypto-asset as well as the transaction fees paid by network users. Over time, as miners introduce more advanced machines for solving PoW tasks, the difficulty of the mathematical problems on the network also increases. At the same time, competition among miners grows, which further contributes to the scarcity of the crypto-asset.

PoW, which forms the basis of the Bitcoin blockchain, is the consensus mechanism with the highest energy consumption. The mining process consumes the largest share of energy within the Bitcoin network.

Mining operations continuously increase electricity consumption, resulting in excessive carbon dioxide (CO₂) emissions. The ecological footprint of PoW has drawn criticism from regulators, environmentalists, and investors, highlighting the need for more energy-efficient alternatives.

3.2 Proof of Stake

Proof of Stake (PoS) is a consensus mechanism that encourages validators to secure the network and verify transactions by requiring them to deposit their own crypto-assets as collateral. Validators are selected to generate new blocks on the basis of the amount of crypto-assets they hold and are willing to “stake”, rather than on the basis of computing power. If a validator correctly confirms a transaction, the block is added to the blockchain, the transaction is confirmed, and the validator is rewarded with a payment in the native crypto-asset together with the return of the collateral. If a validator does not confirm the transaction correctly and within the prescribed time, it forfeits its right to the collateral.

PoS has established itself as an environmentally acceptable alternative to PoW. According to the available data, the use of PoS consumes up to 99% less energy than PoW.

3.3 Byzantine Fault Tolerant

Byzantine Fault Tolerant (BFT) consensus mechanisms secure the network through a predetermined group of trusted validators that confirm transactions and integrate blocks into the main ledger. BFT is a property of a system that can continue to function correctly in the event of the failure of individual parts of the network or their malicious behaviour. A BFT system can tolerate a certain number of faulty nodes without compromising the integrity of the entire network. A BFT system requires at least two-thirds of the participants to act honestly. If one-third or more of the network participants act maliciously, or in the event of a failure, the protocol cannot guarantee a correct outcome.

Unlike energy-intensive consensus methods, BFT mechanisms ensure fast transaction processing while reducing energy consumption, which makes them more environmentally acceptable. The ability to reach consensus without energy-intensive mining or excessive computational prerequisites sets BFT systems apart as a promising solution for blockchain networks oriented towards ecological sustainability.

3.4 Non-Consensus Algorithm

A Directed Acyclic Graph (DAG) is based on the rule that each new transaction must independently confirm two preceding transactions. It involves no miners or validators and has no voting mechanism. Unlike traditional blockchains, which require the verification of each block in a linear sequence, a DAG allows the simultaneous confirmation of transactions, which can result in lower energy consumption and higher transaction processing speed. However, network security weakens when transaction traffic is reduced, owing to the smaller number of confirmations carried out.

4. METHODOLOGIES FOR THE MANDATORY KEY SUSTAINABILITY INDICATORS

The sustainability indicators are calculated in accordance with the methodology prescribed by Commission Delegated Regulation (EU) 2025/422 (regulatory technical standards adopted on the basis of Article 66(6) of Regulation (EU) 2023/1114) and with the methodology of the CCRI (Crypto Carbon Ratings Institute) set out in the document “Methodologies to calculate sustainability indicators for the EU Markets in Crypto-Assets (MiCA)”.

For each crypto-asset in respect of which it provides services, the Company publishes, in a prominent place on its website, at least the following mandatory sustainability indicators:

• entity data: the name of the Company (Digital Assets d.o.o.), the Legal Entity Identifier (LEI), the name of the crypto-asset and the consensus mechanism used, and the reporting period
• the annual energy consumption for the validation of transactions and the maintenance of the distributed ledger, expressed in kWh per year
• the sources and methodology of calculation.

Where the annual energy consumption of an individual crypto-asset exceeds 500,000 kWh, the Company additionally discloses the share of renewable energy, the energy intensity per transaction, scope 1 and scope 2 greenhouse gas emissions, and the greenhouse gas emissions intensity per transaction.

The disclosure is free of charge and available as a downloadable file, drafted in clear language, and is reviewed and updated as necessary.

Date of last publication: 30 July 2026.

4.1 Example disclosure of sustainability indicators for the crypto-asset Bitcoin (BTC)

Last review: 2025-06-27. The values in field S.8 and in fields S.10 to S.14 are estimates provided by CCRI for the period specified in fields S.6 and S.7 and relate to the entire Bitcoin network; for its own disclosure, the Company updates them to its own reporting period and enters its own Legal Entity Identifier (field S.2). The disclosure is informative in nature and does not constitute advice or an offer.

4.2 List of the Company's crypto-assets with their corresponding consensus mechanisms, energy consumption, and greenhouse gas emissions