Notification to the supervisor: stages and deadlines
Notification to the supervisor is the step that turns a drafted token offering into a filing the regulator can act on. It sits between internal sign-off and the point where the offer can lawfully reach the public. The process runs as a fixed sequence: file preparation, submission, acknowledgement, a review window, and either entry into force or a request for clarification.
Stages at a glance
| Stage | What happens | Point of no return |
|---|---|---|
| Preparation | The white paper, governance documents and marketing materials are assembled and cross-checked for consistency. | No — the file can still be reworked freely. |
| Submission | The file is filed with the supervisor through the designated channel by an authorised signatory. | No — an incomplete filing is treated as not submitted. |
| Acknowledgement | The supervisor confirms receipt and opens an internal reference for the file. | No — acknowledgement is administrative, not approval. |
| Review | The supervisor examines the file and may raise questions or request corrections. | Partial — the clock pauses while clarification is pending. |
| Entry into force | The notification takes effect and the offer or trading activity may proceed on the agreed terms. | Yes — material changes after this point require a fresh notification. |
What changes once the file is submitted
Before submission, terms can be adjusted at will. After submission, the file becomes the reference version, and any material change to it resets the review rather than amending it in place. A supervisor's request for clarification does not restart the process, but it does pause the clock until the issuer responds. An incomplete or inconsistent filing is not reviewed at all — it is returned, and the review period begins only once a complete version is on file.
This has a direct effect on planning. Marketing, listing arrangements and investor communication should be scheduled around entry into force, not around the submission date. Treating submission as the finish line is the most common source of delay we see.
What to do
- Compliance team assembles the file: white paper, governance documents, risk disclosures and marketing materials, checked against one another for consistency.
- Legal counsel reviews the file for completeness before it leaves the building — this is where most avoidable delay is caught.
- Where the file includes personal data on beneficial owners or key individuals, the handling of that data should follow a written Data processing agreement overview rather than an informal arrangement between teams.
- Authorised signatory submits the notification through the supervisor's designated channel.
- Compliance team monitors the file for acknowledgement and for any request for clarification, and logs the date each communication is received.
- Legal counsel drafts and files any response to a clarification request within the review window, and confirms entry into force before marketing activity begins.
Who decides
The supervisor is the sole decision-maker on the file. There is no separate hearing and no oral submission stage — the review is conducted on the documents filed. The forum for any query is written correspondence through the same channel used for submission. Internally, the decision to submit rests with the authorised signatory, on the recommendation of legal counsel; the decision to proceed with marketing rests with whoever holds that mandate under the issuer's own governance, but it should not be exercised before entry into force is confirmed.
Common forks
- If the file is incomplete on submission, then it is treated as not filed, and the review period does not begin until a complete version is submitted.
- If the supervisor raises a clarification request, then the review clock pauses until the response is filed, and the sequence resumes from that point.
- If the issuer changes the white paper materially before entry into force, then the existing notification is superseded and a fresh filing is required.
- If the offer is aimed at more than one jurisdiction, then each supervisor's file and timeline should be tracked separately rather than assumed to run in parallel.
Sources and limits
This page describes sequence and responsibility. It does not set out statutory day-counts, fee schedules or the cross-border passporting mechanics that can attach to a notification — those depend on the specific national regime and are outside what a procedural overview can respondsibly state without becoming stale.
Where the file names a counterparty that needs independent verification before submission, our Counterparty in Cyprus report sets out what can and cannot be established from public sources.
Where a supporting document originates outside the European Union and needs a documented basis before it is relied on, our Document in United States report covers what such a document can support.
Where the offer also touches a jurisdiction outside the notification regime described here, our Jurisdiction in Singapore report sets out the boundaries of what can be confirmed for that market.
Verified
This page reflects current supervisory filing practice for token issuance notifications. It is reviewed on a regular cycle as procedure and supervisory expectations evolve, and it is not a substitute for confirming the current filing channel and file format directly with the supervisor before submission.
Related publications
The stage that follows notification is marketing review. See Marketing review step by step for how that sequence runs once entry into force is confirmed.
FAQ
How long does notification to the supervisor take in practice?
There is no single fixed period that applies to every file. The timeline runs from a complete submission to entry into force, and it lengthens whenever the supervisor raises a clarification request or the file needs to be resubmitted. A file that is complete and consistent on first submission moves through the review window without interruption.
Which documents are needed to start?
At minimum: the white paper, governance and risk documentation, and the marketing materials intended for use once the offer opens. Any personal data on beneficial owners or key individuals should be gathered under a documented data processing basis rather than assembled informally.
What happens if the supervisor does not respond?
Acknowledgement of receipt is administrative and usually prompt; a substantive response is a different matter. If no clarification request and no entry into force confirmation arrive within a reasonable period, the file should be followed up in writing through the same channel used for submission, with the reference number from acknowledgement quoted in full.