Holder communication procedure: documents to prepare
A holder communication procedure needs four categories of documents before it starts. These are a verified holder register, notice templates aligned with the token terms, a disclosure pack explaining the change, and a log to record delivery and responses. Missing any one of these delays the timeline and weakens the audit trail issuers rely on later.
Why the paperwork comes first
Token issuers rarely treat holder communication as a discrete procedure. In practice, it is a chain of documents that must exist before any message goes out, and that must survive scrutiny afterwards. A written procedure turns a vague plan into a file that a compliance officer, an auditor or a questioning holder can check line by line, without asking the team to reconstruct events from memory.
The documents matter more than the wording of any single message. A notice sent without a matching register entry, or a disclosure pack that contradicts the token terms, creates a gap that is far harder to close after the fact than before.
Stages, documents and timing
| Stage | Document produced | Who prepares it | Typical timing |
|---|---|---|---|
| Preparation | Holder register extract, eligibility flags | Registrar or transfer agent | 2–5 business days |
| Drafting | Notice text, disclosure pack | Legal or compliance team | 3–7 business days |
| Dispatch | Delivery log (email, portal, on-chain message) | Communications lead | 1 business day |
| Response window | Query log, amendment record | Compliance team | set in the notice, commonly 10–20 business days |
| Closure | Closure memo | Original signatory | 1–3 business days after the window ends |
The timing above is operational, not statutory. It reflects what a well-run file looks like once the notice has been drafted and the register is clean. A messy register at the start adds days to every stage that follows.
What to prepare, in order
- Pull the holder register and flag every entry whose contact details failed the last verification cycle. The registrar owns this step.
- Draft the notice text once, and route it through legal review before any other document depends on its wording. Legal or compliance signs off here.
- Build the disclosure pack that explains why the communication is happening and what each holder needs to do next. Compliance drafts this alongside the notice.
- Set up the delivery log before the first message ships, not after. The communications lead owns the log from the first entry.
- Fix a response window and state the deadline inside the notice text itself, not in a separate memo. The signatory decides the length of the window.
- Prepare a closure memo template in advance, so nobody drafts it under time pressure once the window closes. The same signatory uses it at the end.
Who decides and how long it takes
The person who signs the notice is the one who authorises closure, not the compliance team that drafted the disclosure pack. This keeps accountability with a single named signatory rather than spreading it across a working group.
Compliance decides when the response window has genuinely closed. That decision depends on the query log, not on the calendar alone: an open dispute can hold the file even after the stated deadline passes. A procedure that runs cleanly, from register pull to closure memo, typically takes three to five weeks. A procedure with a disputed notice or a fragmented register can run considerably longer.
Common forks
If holders are recorded across more than one register style, for example a custodial exchange list alongside an on-chain wallet list, reconcile the two before drafting the notice. Doing this afterwards means resending messages to holders who were missed the first time.
If a holder address bounces, or a wallet shows no on-chain activity for an extended period, keep the failed-delivery record separate from the ordinary response log. A silent holder and a non-responsive one are not the same entry, and treating them as identical breaks the audit trail later.
If a holder disputes the content of the notice, route the dispute to compliance immediately and pause the closure memo until it is resolved. Closing the file while a dispute is open undermines the entire point of keeping a query log.
What this procedure does not cover
This page sets out the documents and the sequence for holder communication. It does not cover redemption mechanics for holders who choose to exit once notified; that runs as a separate file with its own steps and its own timing.
It does not cover the national delivery formalities that apply to a specific holder's jurisdiction, and it does not decide how a registrar should be chosen. Those questions sit outside this procedure and need their own answer before the notice goes out.
Verified
This procedure reflects our internal templates and file notes, checked against recent engagements before publication. It does not rest on any single external register, and we update it whenever a new engagement exposes a gap in the sequence above.
If you need to confirm what can be established about a specific counterparty before running this procedure, our evidence work on Counterparty in Czechia shows the kind of file we build around a single party.
The same applies to a document you are relying on for the notice: Document in Netherlands and its limits sets out what a single document can and cannot prove.
Jurisdiction matters as well, and Jurisdiction in Ireland and its limits covers what can be confirmed about a place of incorporation or operation before you send anything to holders there.
If you are curious how a team runs a procedure like this day to day, our page on Working with this team in practice describes it directly, without the case-file language.
Related reading
A holder communication procedure often runs alongside redemption once holders start to exit. See Redemption process design step by step for the parallel file and its own document set.
FAQ
How long does holder communication procedure take in practice?
A clean file, from register pull to closure memo, typically takes three to five weeks. A disputed notice or a fragmented register extends this well beyond that range.
Which documents are needed to start?
Start with a verified holder register, a notice text cleared by legal review, and a disclosure pack that matches the token terms. Nothing else can safely begin until these three exist.
What happens if the other side does not respond?
A non-response is logged, not ignored. The notice's own stated consequence applies once the window closes, and compliance decides whether the silence needs a further step before the file can be closed.