SBT Token
White Paper
§ 02 – Article 6(3) NoticeThis white paper has not been approved by any competent authority in any EU Member State. Sbarter Ltd. is solely responsible for its content.
§ 03 – Compliance StatementThis white paper complies with Title II of Regulation (EU) 2023/1114. To the best of the knowledge of the management body, the information presented is fair, clear and not misleading.
§ 04 / 05 – Risk & Utility NoticesSBT may lose its value in part or in full, may not always be transferable and may not be liquid. SBT may not be exchangeable against the promised goods or services in case of project failure.
§ 06 – Investor ProtectionSBT is not covered by investor compensation schemes (Dir. 97/9/EC) or deposit guarantee schemes (Dir. 2014/49/EU).
Summary
Key characteristics of SBT and the Sbarter protocol — to be read as introduction to the full white paper only.
The SBT token is a fungible utility crypto-asset issued by Association Sbarter and deployed on Solana, a public Proof-of-Stake blockchain. SBT constitutes a crypto-asset under Article 3(1)(5) of MiCA and is classified as an “other crypto-asset” under Title II of that Regulation.
SBT does not qualify as: an electronic money token (EMT) · an asset-referenced token (ART) · a financial instrument under MiFID II · a deposit, structured product, securitisation instrument, or collective investment scheme · a payment instrument under PSD2.
SBT functions exclusively as the operational utility token of the Sbarter protocol — a blockchain-based coordination and automated settlement infrastructure enabling eligible users to create and participate in peer-to-peer, performance-based digital challenges within integrated third-party video games.
SBT provides access exclusively to the technical functionalities of the Sbarter protocol. The services accessible through possession and use of SBT are limited to the following functional categories:
Users holding SBT may create or join skill-based challenges through the protocol interface. When creating a challenge, a user defines predetermined parameters. Participation requires that the defined SBT amount be programmatically locked within a smart contract for the duration of the challenge.
Access is conditional upon: successful KYC verification where required · jurisdictional eligibility · technical compatibility with supported video games · compliance with protocol rules. Holding SBT does not guarantee the availability of any specific game, opponent, or contest format.
Upon confirmation of participation, the relevant quantity of SBT is locked in a smart contract autonomously managed for the duration of the challenge. Following match completion, the VGP transmits authenticated outcome data strictly as a technical oracle. The VGP does not: hold user tokens · influence settlement logic · participate economically in the challenge · modify smart contract rules.
Upon receipt of validated outcome data, the smart contract executes predetermined redistribution logic automatically. The protocol does not determine game outcomes — outcomes are determined solely by player performance within the video game environment.
SBT may be used to pay protocol-level service fees, including fees associated with verification infrastructure, data processing, network maintenance, and smart contract execution. The required quantity depends on user-defined parameters and the applicable protocol fee structure at time of use.
Subject to eligibility criteria defined in the statutes of Association Sbarter, holders meeting membership and compliance requirements may participate in governance. Governance participation is not automatic upon possession of SBT, is subject to verification and statutory requirements, does not confer ownership rights, and does not grant entitlement to revenues or assets.
SBT does not provide entitlement to a fixed quantity of services. The extent of access depends on: the number of SBT held · the entry amounts defined by users · protocol rules and fee parameters · technical availability of integrated games · regulatory restrictions in specific jurisdictions. There is no guaranteed minimum level of access or service continuity.
SBT is technically transferable on the Solana blockchain without protocol-level restrictions, subject to vesting or smart-contract constraints where applicable. Transfers occur peer-to-peer through standard blockchain transactions. Access to certain protocol functionalities may be subject to eligibility verification, including KYC/AML checks or jurisdictional restrictions at the application layer. Transfers executed on-chain are irreversible once confirmed. SBT does not grant any right to redemption or conversion into fiat currency by the issuer.
At TGE, SBT will be made available on Raydium (Solana DEX / AMM). No formal CEX listing agreement has been executed as of this white paper. Future admission to centralised exchanges — Gate.io, OKX, and Crypto.com are under consideration — is subject to independent platform approval, due diligence, and regulatory requirements.
Certain allocation categories are subject to structured vesting arrangements and lock-up periods including initial cliff periods, progressive linear monthly release schedules, extended release timelines for reserve allocations, and conditional release structures where applicable.
At TGE, only a limited portion of the total supply will be in circulation. Circulating supply will increase progressively over time in accordance with vesting schedules.
Part A – Offeror
Information about Sbarter Ltd., the person seeking admission to trading under MiCA Article 5.
Sbarter Ltd. is a company incorporated under the laws of Malta. It is the publisher of this white paper and the person seeking admission to trading under MiCA. Activities include: development and maintenance of the protocol’s application-layer infrastructure · smart contract deployment and technical management · integration of VGPs as technical data providers (oracles) transmitting authenticated match results · implementation of compliance mechanisms · management of protocol-level service fee structures · coordination of token distribution and market access arrangements.
Association Sbarter is a blockchain-focused organisation whose principal activity is the development and promotion of a blockchain-based ecosystem for the video game industry, providing infrastructure and tools to support its members. Its principal market is the global video gaming and digital entertainment sector.
Sbarter Ltd. was incorporated in Malta on 15 December 2025 and, as of the date of this white paper, has not yet commenced commercial operations. No revenues have been generated and no audited financial statements have been prepared.
Sbarter Ltd. has been engaged primarily in organisational and preparatory activities, including corporate structuring, technical development planning, and preparations for the operational rollout of the Sbarter protocol. The initial financial inflows supporting development originated from the private placement of SBT tokens conducted by Association Sbarter. Association Sbarter has confirmed its intention to make funds available to Sbarter Ltd. as necessary to support protocol development and deployment.
Part B – Issuer
Information about Association Sbarter, the issuer of SBT — a separate and distinct entity from the offeror Sbarter Ltd.
Association Sbarter is a non-profit association incorporated under Article 60 et seq. of the Swiss Civil Code, with registered office in Switzerland. It acts as the issuer of SBT and is the legal owner of the intellectual property relating to the Sbarter protocol, including protocol architecture specifications, branding, and related technical documentation.
Issuance of SBT · Stewardship and protection of protocol-related intellectual property · Definition of governance principles in accordance with its statutes · Oversight of long-term ecosystem objectives and sustainability.
Part D – The Sbarter Project
Information about the crypto-asset project, its description, roadmap, and resource allocation.
The Sbarter project introduces a technical infrastructure protocol designed exclusively for performance-based digital challenges between users. The system operates on a player-versus-player basis, where outcomes are determined solely by measurable performance of participants within the underlying video game environment.
The protocol does not introduce elements of randomness, probabilistic mechanics, or outcome determination independent of player skill. It functions as an automated infrastructure layer that formalises and settles predefined challenge conditions between users.
The SBT token is the native utility token of the Sbarter protocol. Core features accessible through SBT include:
Users may create or accept structured digital challenges by defining predetermined parameters within the protocol interface. These parameters may include the selected video game, format (e.g. one-on-one or tournament structure), participation conditions, and entry amount denominated in SBT. The protocol formalises these parameters through smart contract encoding, ensuring that the defined rules are fixed prior to challenge commencement.
Participation in a challenge requires the predefined quantity of SBT to be programmatically locked within a smart contract. The smart contract autonomously manages token custody during the lifecycle of the challenge and enforces the encoded redistribution rules. The locking and redistribution mechanisms operate deterministically and are executed without discretionary human intervention.
Following completion of the relevant game session, authenticated match outcome data is transmitted to the protocol by the relevant VGP. The VGP acts solely as a technical data provider (oracle) and supplies verified performance results derived from its own game servers. The oracle mechanism does not alter challenge parameters or influence settlement logic; it provides the data input required for automated execution.
Upon validation of outcome data, the smart contract executes the predefined redistribution logic and transfers the locked SBT in accordance with the encoded challenge rules. Redistribution occurs on-chain and is immutably recorded on the blockchain.
SBT may also be used to access protocol-level infrastructure functions, including interaction with the challenge management framework and associated verification processes. The availability and scope of these services depend on technical integration status, user eligibility requirements, and applicable regulatory conditions. The SBT token does not grant access to financial products, investment services, or house-operated gaming services.
The protocol’s development roadmap focuses on continuous enhancement of functionality, fairness mechanisms, and system resilience. Progressive integration of additional competitive structures includes: multi-round tournament models · bracket-based elimination structures · league-based competition systems · time-based competitive events · hybrid competition formats. The technical framework is modular, allowing new tournament models to be embedded without altering the deterministic settlement core.
Planned ranking and integrity developments include: multi-dimensional ranking methodologies · integrity-weighted scoring systems · performance consistency modelling · anti-collusion detection parameters · reputation-based integrity scoring. In future development phases, AI-assisted analytical tools may be implemented to analyse behavioural anomalies, detect suspicious patterns of gameplay, and strengthen fraud prevention mechanisms.
The growth strategy is centred on progressive integration of Video Game Providers seeking to offer a structured, compliant competitive environment with transparent automated settlement mechanisms and an alternative monetisation model integrated at the protocol level. Adoption efforts focus on onboarding VGPs that align with regulatory standards and technical integration requirements.
The protocol is designed to operate across multiple jurisdictions, subject to legal and regulatory compatibility. Expansion follows a phased approach beginning in jurisdictions assessed as compatible, with ongoing legal assessment prior to entering new markets and implementation of jurisdiction-specific access controls where required. Expansion decisions will prioritise regulatory compliance, operational feasibility, and ecosystem stability.
Roadmap includes: initial availability on Raydium (DEX) at TGE · pursuit of admission to trading on one or more centralised exchanges · progressive enhancement of market accessibility subject to regulatory and exchange approval processes.
At present, governance control of Association Sbarter is exercised by its founders. The strategic plan contemplates a progressive transition toward broader governance participation by integrated VGPs and other eligible ecosystem contributors, subject to ecosystem maturity, operational readiness, and regulatory compatibility. This transition is intended to align protocol governance with industry stakeholders and encourage broad adoption by granting governance participation to operational contributors.
Since its establishment on 27 March 2024, Association Sbarter has raised financial resources primarily through private placement of SBT tokens. Following the TGE, the Association may continue the private placement of a portion of tokens allocated to investors.
| Resource Area | Description |
|---|---|
| Protocol Development | Technical architecture, smart contract framework, backend infrastructure, integration mechanisms, application interfaces and technological components for protocol operation |
| Legal, Regulatory & Compliance | Regulatory assessments across relevant jurisdictions, legal structuring, preparation of technical and regulatory documentation, independent security audits, legal reviews |
| Ecosystem Development & Market Adoption | Partnerships with video game providers, community development, initiatives to support progressive adoption of the Sbarter protocol |
Resource allocation decisions may evolve over time depending on the development stage of the protocol and the needs of the ecosystem.
Proceeds of the private placement are received and managed exclusively by Association Sbarter as the legal entity responsible for SBT issuance. No proceeds are raised by Sbarter Ltd. through publication of this white paper, which is issued exclusively in connection with admission to trading under Article 5 of MiCA.
| Use of Funds | Description |
|---|---|
| Protocol Development & Technical Advancement | Smart contract architecture, tournament formats, leaderboard systems, integrity scoring, AI-supported analytics, security audits, infrastructure resilience |
| Ecosystem Adoption & Integration | VGP integration frameworks, oracle interface development, scalability, UI improvements, community and ecosystem growth |
| Regulatory & Compliance Framework | Ongoing legal assessments, jurisdictional expansion analysis, compliance mechanisms, governance framework implementation |
| Operational & Administrative Support | Technical personnel, infrastructure, cloud services, administrative expenses, corporate governance |
| Market Accessibility Measures | Initial liquidity arrangements at TGE, DEX pool provisioning, preparatory work for potential CEX listings |
Part E – Offer & Admission to Trading
Complete information about the admission of SBT to trading, allocation structure, payment methods, token transfer mechanics, and market access.
This white paper is published by Sbarter Ltd. exclusively in connection with the intended admission of SBT to trading pursuant to Article 5 of Regulation (EU) 2023/1114. No offer to the public of SBT within the meaning of MiCA is being made by means of this white paper.
Any distributions of SBT completed prior to the publication of this white paper were carried out separately through private placement arrangements conducted by Association Sbarter and are described in this white paper solely for transparency purposes.
The purpose of this white paper is to provide the disclosures required for the intended admission of SBT to trading on eligible third-party trading venues, subject in each case to separate due diligence, technical integration, listing approval, and applicable legal and regulatory requirements.
SBT does not qualify as an asset-referenced token, an e-money token, or a financial instrument. It is classified as an “other crypto-asset” under Title II of Regulation (EU) 2023/1114.
For transparency purposes only: the nominal private placement reference price used by Association Sbarter in earlier private placement arrangements was EUR 0.01 per SBT token before the application of any bonus allocations and subject to the vesting and lock-up arrangements described in this white paper. Following admission to trading, the market price of SBT, if any, will be determined solely by supply and demand on secondary markets.
No restriction is imposed on the category of persons who may hold SBT on secondary markets following admission to trading. SBT may be freely transferred on the Solana blockchain subject to applicable law, the vesting restrictions encoded in the Solana vesting program, and any applicable compliance requirements.
With respect to the private placement of SBT tokens conducted by Association Sbarter prior to the publication of this white paper, participation was subject to applicable KYC and AML compliance requirements under the Swiss Anti-Money Laundering Act (AMLA) and Association Sbarter’s applicable compliance framework.
Neither Sbarter Ltd. nor Association Sbarter exercises ongoing monitoring or control over secondary market transfers of SBT following admission to trading. Holders are responsible for ensuring compliance with applicable laws in their respective jurisdictions, including any restrictions on the holding or trading of crypto-assets.
No offer to the public of SBT within the meaning of Article 3(1)(12) of MiCA is being made by means of this white paper. This white paper is published exclusively in connection with admission to trading under Article 5 of MiCA. Accordingly, no reimbursement right under Article 13(4) of MiCA arises in connection with the publication of this white paper.
SBT does not confer any right to redemption, repayment, or reimbursement against Sbarter Ltd., Association Sbarter, or any affiliated entity arising from the holding or transfer of SBT tokens.
Not applicable. No offer to the public of SBT within the meaning of Article 3(1)(12) of MiCA is being made by means of this white paper. This white paper is published exclusively in connection with admission to trading under Article 5 of MiCA.
The distribution of SBT tokens has been conducted exclusively through private placement arrangements by Association Sbarter prior to the publication of this white paper, in accordance with applicable exemptions under Article 4(2) of Regulation (EU) 2023/1114.
Prior to publication of this white paper, Association Sbarter conducted private placement allocations of SBT to selected strategic counterparties. These allocations were carried out independently and do not constitute a public offer under MiCA. The incentive structure was implemented through a bonus token mechanism rather than a reduction of the nominal subscription price, ensuring consistency of the reference price across allocation phases.
12-month cliff · 24-month linear vesting
6-month cliff · 18-month linear vesting
12-month cliff · 24-month linear vesting
12-month cliff · 24-month linear vesting
The progressive reduction of bonus allocations from the pre-seed phase to later institutional allocations reflects the decreasing level of project risk as development progressed and the ecosystem matured. The existence of early purchase incentives does not constitute a guarantee of financial return or capital appreciation.
The following information relates to the payment methods accepted by Association Sbarter in connection with the private placement of SBT tokens conducted prior to the publication of this white paper.
Payments for SBT tokens under the private placement were accepted by Association Sbarter in EUR via bank transfer from verified subscriber accounts, subject to applicable KYC and AML compliance procedures under the Swiss Anti-Money Laundering Act (AMLA) and Association Sbarter’s applicable compliance framework.
In limited cases, Association Sbarter accepted payment in crypto-assets, subject to the same KYC and AML requirements. Any crypto-asset consideration was converted to a fiat-equivalent value for the purpose of determining the applicable token allocation.
Purchases of SBT on secondary markets, including on Raydium and any future centralised exchanges on which SBT is admitted to trading, are subject to the payment mechanisms, terms and conditions, and compliance requirements of the relevant trading platform. Neither Sbarter Ltd. nor Association Sbarter is responsible for the payment processes of independent trading platforms.
Not applicable. No offer to the public of SBT within the meaning of Article 3(1)(12) of MiCA is being made by means of this white paper. This white paper is published exclusively in connection with admission to trading under Article 5 of MiCA. Accordingly, no statutory right of withdrawal under Article 13(4) of MiCA arises.
At the TGE, the SBT token will be created on the Solana blockchain through execution of a dedicated Solana program.
Token transfers to pre-sale participants will be executed upon satisfaction of applicable KYC requirements. Following Association Sbarter’s affiliation with PolyReg, each pre-sale participant will be required to complete a fresh KYC procedure. Tokens will be transferred to the participant’s designated Solana wallet address promptly upon successful completion of the KYC procedure and validation of the wallet address provided.
At the Token Generation Event: the total token supply will be minted in accordance with the predefined maximum supply cap · the mint authority will be revoked following issuance · no further tokens may be created after revocation. Revocation of the mint authority ensures that the total supply of SBT cannot be increased beyond the fixed maximum cap defined in this white paper.
Following minting, allocated tokens subject to vesting conditions will not be immediately transferred to recipients. Tokens subject to cliff and vesting schedules will be transferred to accounts controlled exclusively by a dedicated Solana vesting program. The vesting program holds the tokens in a program-controlled account; neither Association Sbarter nor Sbarter Ltd. can unilaterally access or transfer tokens held within the vesting program.
No tokens are released during the cliff period. After expiry of the cliff period, tokens are released progressively according to a linear schedule through automatic execution of the Solana program logic. Upon each vesting event, the corresponding amount of SBT is transferred to the wallet address designated by the relevant purchaser, or to the designated Association wallet where applicable. The vesting logic is encoded in the smart contract and operates deterministically.
All token transfers occur on-chain and are recorded immutably on the Solana blockchain. Once transferred to a recipient’s wallet, SBT is fully controlled by the holder, subject to any remaining vesting conditions embedded in the program logic.
Pre-sale participants who received SBT token allocations through the private placement conducted by Association Sbarter are required to maintain a non-custodial Solana-compatible wallet that supports SPL tokens in order to receive their token allocation. Participants are solely responsible for the security of their wallet, including the safekeeping of private keys and seed phrases.
Neither Sbarter Ltd. nor Association Sbarter provides custody services or has the ability to recover lost or stolen private keys or access credentials. Pre-sale participants must ensure their wallet address is correctly registered with Association Sbarter prior to the token transfer date. Neither entity accepts liability for tokens transferred to an incorrectly provided wallet address. During the applicable vesting period, participants must maintain access to their designated wallet in order to receive vested token releases. Network transaction fees (gas fees) on the Solana blockchain are the responsibility of the participant.
Persons acquiring SBT on secondary markets must comply with the technical requirements and terms and conditions of the relevant trading platform. For self-custody of SBT acquired on secondary markets, a non-custodial Solana-compatible SPL token wallet is required. Neither Sbarter Ltd. nor Association Sbarter provides technical support to secondary market purchasers.
Sbarter Ltd. also intends to seek admission to one or more centralised platforms. Platforms currently under consideration or intended to be approached, including but not limited to: Gate.io, OKX, and Crypto.com. No formal listing agreement has been executed as at the date of this white paper. Admission to centralised platforms is subject to independent third-party approval, due diligence, technical integration requirements, and applicable regulatory considerations.
Any admission to trading on an EU/EEA authorised platform will be announced through the official communication channels of Sbarter Ltd. and Association Sbarter. Neither entity operates any trading venue and does not provide exchange, brokerage, or multilateral trading facilities.
Access to and trading of SBT tokens may be subject to the fee structure and pricing policies of the respective trading platforms. Purchasers are responsible for reviewing and complying with the applicable fees, commissions, or transaction costs set by each platform.
| Conflict | Description |
|---|---|
| Issuer–Offeror Relationship | Association Sbarter controls Sbarter Ltd. Decisions on token issuance and exchange admission may involve overlapping governance interests. Strategic decisions may indirectly affect the value and adoption of SBT. |
| Founder & Early Participant Holdings | Founders and early contributors hold SBT under vesting arrangements. Following expiry of vesting schedules, these holders may transfer or sell tokens on secondary markets, which could affect market price and liquidity. |
| Governance Concentration | At publication, governance of Association Sbarter is exercised by its founders. Current concentration may create potential conflicts between founding members and other ecosystem participants. |
| Operational & Economic Incentives | Persons involved in development may hold SBT directly or indirectly. Such holdings may create incentives aligned with ecosystem growth but may also create conflicts where operational decisions could indirectly affect token market dynamics. |
The following fields are not applicable as this white paper is published exclusively in connection with admission to trading under Article 5 of MiCA, and no offer to the public is being made.
Part F – The SBT Token
Detailed characteristics, classification, tokenomics, and additional services of the SBT utility token.
The SBT token is not classified as an asset-referenced token (ART) or an electronic money token (EMT) under MiCA. It does not purport to maintain a stable value by referencing another value, right, or combination thereof including official currencies.
The SBT token is the native utility token of the Sbarter protocol. Its functionalities consist of:
- Use as the predefined token for creation of and participation in eligible skill-based digital challenges
- Automated settlement of challenge outcomes through autonomous smart contracts or Solana programs based on authenticated result data submitted by integrated VGPs acting strictly as technical oracles
- Payment of protocol-level and oracle verification service fees
- Governance participation only for persons admitted as eligible members of Association Sbarter who satisfy applicable statutory and compliance requirements — token possession alone does not confer membership or governance rights
Association Sbarter, in its capacity as issuer of SBT, does not provide crypto-asset services within the meaning of Regulation (EU) 2023/1114. The activities of Association Sbarter are limited to: issuance of the SBT token · ownership and stewardship of the intellectual property relating to the Sbarter protocol · governance oversight in accordance with its statutes · allocation of funds received in connection with token issuance for the development and promotion of the protocol’s mission.
All operational, technical, and commercial activities relating to deployment and management of the Sbarter protocol are conducted by Sbarter Ltd., a separate legal entity. Accordingly, Association Sbarter does not provide additional services to token holders beyond those expressly described in this white paper.
Austria · Belgium · Bulgaria · Croatia · Cyprus · Czech Republic · Denmark · Estonia · Finland · France · Germany · Greece · Hungary · Iceland · Ireland · Italy · Latvia · Liechtenstein · Lithuania · Luxembourg · Netherlands · Norway · Poland · Portugal · Romania · Slovakia · Slovenia · Spain · Sweden
Part G – Rights & Obligations
Rights attached to SBT, exercise of rights, issuer-retained tokens, transferability, and governance framework.
Holders of SBT do not acquire any ownership rights, equity interests, profit entitlement, repayment claim, or other financial claim against Association Sbarter, Sbarter Ltd., or any affiliated person. SBT is a utility crypto-asset designed solely to enable access to and interaction with the Sbarter protocol.
Holding SBT may enable a holder to:
- Use SBT as the protocol token for eligible challenge participation
- Pay protocol-level and oracle verification service fees
- Where admitted as an eligible member of Association Sbarter and satisfying applicable requirements, participate in governance matters falling within the competence of Association Sbarter
SBT token holders do not acquire any obligations by holding tokens. The exercise of rights associated with SBT is not subject to any additional conditions beyond compliance with applicable laws and protocol rules. Such rights relate exclusively to the use of SBT within the Sbarter protocol, including access to protocol features and, where eligibility requirements are met, participation in governance.
The most up-to-date rights are always available on the Association Sbarter website: sbarter.com/association/
The rights and functionalities attached to SBT may be amended only in accordance with applicable law, this white paper, the statutes of Association Sbarter, and the governance and decision-making procedures validly applicable to the relevant matter. No statement by any third party may amend the rights attached to SBT unless such amendment has been validly adopted in accordance with the documents and procedures referred to above.
Any material modification to the rights attached to SBT shall be disclosed in accordance with the notification and disclosure obligations applicable under Regulation (EU) 2023/1114. No modification shall create equity rights, redemption rights, repayment rights, or financial claims for token holders unless required by applicable law.
A portion of the SBT supply is allocated to categories administered by Association Sbarter and constitutes issuer-retained crypto-assets until released in accordance with the tokenomics framework. Tokens subject to lock-up are deposited into a Solana SPL vesting program, enforcing applicable cliff and vesting schedules through program-controlled accounts.
| Allocation | Supply | % | Vesting Schedule |
|---|---|---|---|
| VGP Allocation | 5,000,000,000 SBT | 20% | 12-month cliff · 24-month linear vesting |
| Marketing | 2,000,000,000 SBT | 8% | 6-month cliff · 36-month linear vesting |
| Reserve | 2,925,000,000 SBT | 11.7% | 48-month linear vesting |
| Liquidity | 1,875,000,000 SBT | 7.5% | Partial at TGE · 12-month vesting for remainder |
SBT enables eligible users to create and enter structured, performance-based digital challenges within integrated third-party video games. A predefined quantity of SBT is programmatically locked in accordance with the relevant smart contract or Solana program logic; tokens remain locked for the duration of the challenge; and upon receipt of authenticated gameplay outcome data from the relevant VGP acting as a technical oracle, the relevant on-chain program executes automatic redistribution in accordance with predefined rules. Redistribution occurs deterministically and without discretionary human intervention.
SBT may be used to pay protocol-level service fees and oracle verification service fees associated with infrastructure maintenance, result verification, smart contract execution, and network operations. Such fees are service fees only and do not entitle the holder, the issuer, Sbarter Ltd., or any VGP to participate in challenge outcomes or to receive profit-sharing rights.
Governance participation is available only to persons admitted as eligible members of Association Sbarter in accordance with its statutes and applicable compliance requirements. Governance participation requires: admission as a member of the Association · locking of SBT for governance purposes where applicable · compliance with the applicable governance framework. Token possession alone does not automatically confer membership or governance rights.
SBT is a utility token and is not redeemable by the issuer for fiat currency, other crypto-assets, or any fixed amount of goods or services. Its utility consists of use within the Sbarter protocol for eligible skill-based challenge participation, payment of protocol-level and oracle verification service fees, and conditional governance participation through Association Sbarter where statutory eligibility and compliance requirements are satisfied.
SBT is transferable on the Solana blockchain, subject to: applicable laws · vesting restrictions encoded in the Solana program · compliance requirements where applicable. Transfer of tokens does not automatically transfer membership status in the Association.
Part H – Underlying Technology
Information about the Solana blockchain, consensus mechanism, incentive structure, and CertiK security audit results.
The SBT token is issued as an SPL Token-2022 standard asset on the Solana blockchain. The SPL standard is a technical protocol for issuing and managing tokens, ensuring SBT compatibility with most wallets, exchanges, and decentralised applications (DApps). This protocol provides the foundation for secure transactions and smart contracts.
Solana uses Proof-of-Stake with Tower BFT and Proof-of-History, where leaders are pre-selected by stake. Transactions, including SBT transfers, receive sub-second confirmation and high throughput.
SBT is issued as an SPL Token-2022 on the Solana blockchain. Token issuance, transfers, vesting releases, and challenge-related on-chain settlement events are recorded on Solana. Smart contracts and Solana programs are used to lock tokens for eligible challenges, apply vesting conditions, and execute deterministic token redistribution after authenticated match outcome data is submitted by the relevant technical oracle.
The Sbarter protocol relies on a combination of token-based incentives, vesting mechanisms, and network-level fees to secure transactions and promote long-term, aligned participation. SBT tokens allocated to participants are subject to defined cliff and vesting schedules, which incentivise sustained engagement and reduce short-term speculative behaviour.
Governance participation is further incentivised through token-locking mechanisms, whereby eligible members may increase their governance influence by locking SBT tokens for extended periods, aligning decision-making power with long-term commitment to the protocol.
Protocol transactions — including challenge participation, escrow, settlement, and governance interactions — are executed via smart contracts deployed on the Solana blockchain. As such, users incur standard Solana network transaction fees. The Sbarter protocol itself does not impose additional protocol-level transaction fees on SBT transfers.
Where applicable, oracle fees payable in SBT compensate Video Game Providers acting as independent result verifiers, ensuring accurate outcome reporting and the integrity of challenge settlement. Any fees associated with fiat conversion or secondary market trading arise from independent third-party on-ramp providers or decentralised exchanges and are external to the protocol.
CertiK security audit of the SBT smart contract and SPL vesting program was performed on 26 March 2026.
CertiK found zero Critical, Major, or Medium security vulnerabilities in the Sbarter smart contracts. All 12 findings were successfully addressed: 4 Resolved · 7 Acknowledged · 1 Mitigated via Multi-Sig.
SBA-05 (Centralization Risk): mitigated via 2-of-4 multi-signature wallet controlled by Association Sbarter, ensuring no single point of failure. SBA-07 (Minor Risk): fully resolved by the development team. 10 Informational findings acknowledged as harmless edge cases.
Part I – Risk Factors
Comprehensive risk disclosure covering offer-related, issuer-related, crypto-asset, project implementation, and technology risks.
The admission to trading of the SBT token involves risks related to market volatility, liquidity, regulatory uncertainties, and trading conditions. The crypto-asset market is highly dynamic, and the price of the SBT token may experience significant fluctuations due to market sentiment, macroeconomic trends, and speculative activity.
There is no guarantee of sustained liquidity or that an active secondary market for the SBT token will develop or remain stable over time. Regulatory changes may impact trading conditions, exchange availability, or compliance requirements, potentially restricting access to the SBT token in certain jurisdictions or imposing additional obligations on holders.
During the initial phase, decision-making authority over the Sbarter protocol and the activities of Association Sbarter is primarily exercised by the founding team and designated governing bodies. Holders of SBT have limited ability to influence governance decisions during this initial phase, including decisions that may affect the development, functionality, or utility of the Sbarter protocol. The planned transition toward broader community participation is not guaranteed to develop exactly as currently envisaged.
Association Sbarter is structured as a non-profit entity and does not currently generate independent commercial revenues. Its ability to fund the development of the Sbarter protocol depends primarily on financial resources obtained through private placement allocations of SBT and other ecosystem funding mechanisms. If available financial resources prove insufficient, the Association may face limitations in executing its development roadmap, supporting ecosystem expansion, or fulfilling its functions as issuer of the SBT token.
The development and strategic direction of the Sbarter ecosystem depend in part on the continued involvement of its founders and key contributors. The loss, unavailability, or reduced involvement of key individuals could adversely affect the development of the Sbarter protocol, the implementation of its strategic roadmap, or the coordination of ecosystem activities.
Association Sbarter is established as a Swiss association pursuant to Articles 60–79 of the Swiss Civil Code, imposing certain governance and operational constraints. Changes to applicable Swiss law governing associations, or changes to the interpretation of such laws by competent authorities, could affect the governance structure or operational framework of Association Sbarter.
Association Sbarter is based in Switzerland and is subject to applicable Swiss legal and regulatory frameworks, including financial market regulations where relevant. Future regulatory developments or reinterpretations by Swiss authorities, including FINMA, could affect the regulatory treatment of the SBT token or the activities of Association Sbarter and could require modifications to the operational structure of the ecosystem.
The SBT token is a utility token with no enforceable obligations or financial claims against Association Sbarter or any third party. Its value and utility are dependent on network adoption, platform development, and ecosystem growth, rather than intrinsic financial guarantees.
| Risk Type | Description |
|---|---|
| Market & Liquidity | SBT price is subject to market fluctuations, market sentiment, trading activity, and macroeconomic factors. No guarantee of sustained liquidity or stable secondary market. |
| Blockchain & Transaction | SBT operates on Solana — subject to gas fees, network congestion, and potential disruptions impacting transaction costs and settlement times. |
| Smart Contract & Security | As an on-chain asset, SBT relies on smart contract functionality which may be exposed to vulnerabilities, exploits, or unforeseen technical failures. |
| Regulatory | Changes in crypto regulations, taxation, or trading laws could impact the availability, usability, or trading conditions of SBT in different jurisdictions. |
The Sbarter project operates in a legally sensitive environment spanning crypto-assets, platform operations, consumer protection, AML/KYC compliance, advertising restrictions, and the regulation of skill-based digital competitions. The legal treatment of skill-based digital challenges, crypto-assets, and related application-layer services differs across jurisdictions and may change or be reinterpreted over time.
Only challenge formats assessed as lawful for the relevant market may be made available, and certain jurisdictions, games, or features may be restricted or excluded. Sbarter Ltd. and Association Sbarter have obtained jurisdiction-specific legal analyses for selected markets and continue to monitor legal and regulatory developments.
Swiss counsel has analysed the current SBT structure, and prior correspondence with FINMA exists in relation to earlier project iterations. However, no assurance can be given that competent authorities, including Swiss authorities, will maintain the same interpretation for the current or future structure, or that future changes in law, guidance, or enforcement practice will not require modifications to the project or restrict operations in one or more jurisdictions.
Smart contracts are generally immutable and execute automatically without human intervention. Errors, vulnerabilities, or unintended behaviours in the smart contract code could result in the loss of funds, incorrect challenge settlements, or exploitation by malicious actors. While audited by CertiK, a security audit does not guarantee the complete absence of vulnerabilities, and previously undetected errors or novel attack vectors may be identified following deployment.
SBT is deployed on the Solana blockchain. The availability and performance of the Sbarter protocol are dependent on the continued operation, security, and stability of the Solana network. The Solana network has experienced periods of degraded performance and outages in the past. Any future network outages, forks, protocol upgrades, or security incidents could disrupt the Sbarter protocol, delay challenge settlements, or prevent token transfers. Neither Association Sbarter nor Sbarter Ltd. controls the development or governance of the Solana blockchain.
The Sbarter protocol relies on video game providers acting as oracles to submit verified challenge outcome data to the smart contracts. The accuracy and integrity of challenge settlements depend on the reliability and honesty of these oracles. Any failure, manipulation, or compromise of the oracle function — whether through technical error, dishonest conduct, or external attack — could result in incorrect challenge settlements and loss of funds for participants. The protocol has been designed to ensure that VGPs act exclusively as technical data submitters with no economic interest in challenge outcomes. However, the protocol cannot guarantee against all forms of oracle failure or manipulation.
Rapid growth in user activity could stress the Sbarter platform’s infrastructure, potentially leading to service degradation, downtime, or delayed transaction processing. Web2 infrastructure is hosted on Amazon Web Services (AWS), providing on-demand scalability and global availability. Backend systems are designed with redundancy and load-balancing capabilities, and the architecture is modular to support progressive integration. However, unexpected demand spikes, AWS service disruptions, or unforeseen technical failures could adversely affect user experience and platform reliability.
The Sbarter platform, its backend infrastructure, and the wallets and private keys of participants are potential targets for cyberattacks, including hacking, phishing, distributed denial-of-service attacks, and social engineering. A successful attack could result in loss of funds, theft of user data, or disruption of platform operations. While Sbarter Ltd. has implemented security measures, no cybersecurity framework can provide absolute protection against all attack vectors.
Participation in the Sbarter protocol requires the use of a non-custodial Solana-compatible wallet. The security of a participant’s SBT tokens is dependent on the security of their private keys and seed phrases. Sbarter Ltd. and Association Sbarter have no ability to recover lost or stolen private keys. Loss of access to a wallet — through loss of private keys, hardware failure, or theft — may result in the permanent loss of SBT tokens.
The blockchain and crypto-asset technology landscape is evolving rapidly. Technologies, protocols, and standards that are currently considered best practice may become outdated or be superseded by superior alternatives. There is no guarantee that the Sbarter protocol will remain technologically competitive over its intended operational lifetime, or that Sbarter Ltd. and Association Sbarter will have the resources to upgrade the protocol in response to technological developments.
| Risk | Mitigation Measure |
|---|---|
| Governance concentration | Two-phase governance model, voting concentration limits, and eligibility-based governance designed to reduce concentration over time |
| Financial dependency | Private placement proceeds, treasury planning, reserve allocations, and structured vesting schedules intended to support development over a multi-year horizon |
| Key person risk | Operational, technical, and governance responsibilities distributed across multiple persons and entities |
| Regulatory and legal risk | Jurisdiction-specific legal analyses obtained for selected markets; regulatory developments monitored on an ongoing basis; product availability restricted by market, game, format, or user category where required by law |
| Market adoption risk | Protocol designed for API-based integration without requiring changes to core gameplay, with low integration friction and no commitment by VGPs to adopt at scale |
| Token demand and valuation | SBT designed as utility-first with vesting and lock-up structures intended to moderate supply release |
| Fraud and verification risk | KYC/AML controls, fraud detection tools, transparent on-chain settlement, and dispute-handling procedures |
| Competition risk | Differentiation through skill-based challenge architecture, authenticated result submission, and deterministic settlement |
| Smart contract risk | CertiK security audit completed with zero critical findings; code architecture intended to reduce operational vulnerabilities |
| Solana blockchain risk | Solana selected for throughput, latency, and ecosystem compatibility; protocol remains dependent on continued Solana availability |
| Oracle integrity risk | VGPs structured as technical data submitters only, with deterministic on-chain settlement logic and no intended economic participation in challenge outcomes |
| Scalability and infrastructure | Modular architecture, redundancy, load-balancing, and scalable hosting arrangements (AWS) |
| Cybersecurity risk | Security measures, infrastructure monitoring, access controls, and periodic security reviews |
| Private key risk | Users required to use non-custodial wallets and are solely responsible for safeguarding private keys and seed phrases |
| Technology obsolescence | Protocol architecture intended to remain modular and upgradeable at the application layer |
Part J – Sustainability Indicators
Mandatory sustainability indicators on adverse impact on the climate and other environment-related adverse impacts of the consensus mechanism.
The Sbarter protocol relies on a combination of token-based incentives, vesting mechanisms, and network-level fees to secure transactions and promote long-term, aligned participation. SBT tokens allocated to participants are subject to defined cliff and vesting schedules, which incentivise sustained engagement and reduce short-term speculative behaviour.
Governance participation is further incentivised through token-locking mechanisms. Protocol transactions — including challenge entry, escrow, settlement, and governance interactions — are executed via smart contracts deployed on Solana. Users incur standard Solana network transaction fees. The Sbarter protocol does not impose additional protocol-level transaction fees on SBT transfers.
Oracle fees payable in SBT compensate Video Game Providers acting as independent result verifiers. Any fees associated with fiat conversion or secondary market trading arise from independent third-party providers and are external to the protocol.