Supply change procedure: documents to prepare
A supply change procedure adjusts how many tokens exist after issuance, through minting, burning, or a cap revision. Before any change takes effect, the issuer assembles a defined document set, notifies the relevant venue or authority, and waits out a fixed review window. Missing a document restarts the clock, regardless of how minor the change appears.
Why the procedure matters in practice
The procedure exists because a supply change affects every holder at the same moment. A reviewing body checks that disclosure keeps pace with the new supply figures, that existing holders are treated equally, and that no public announcement precedes the filing. Once review starts, the issuer cannot withdraw the request silently — a formal notice is required to close the file cleanly.
This is why the point of no return sits earlier than most issuers expect. It falls at the moment the filing is accepted for review, not at the moment new tokens are minted or old ones burned. An issuer that announces the change before acceptance has already created a disclosure problem that the filing itself cannot fix.
What to prepare
The document set differs by trading venue, but a core file is consistent across venues that admit tokenised instruments. Five documents open a complete file; a sixth confirms it was executed correctly.
| Document | Prepared by | Confirms |
|---|---|---|
| Updated whitepaper or supply annex | Legal team | New supply figures and their effect on existing tokens |
| Token holder resolution | Corporate secretary | Formal consent to the change, recorded and dated |
| Custody and subprocessor confirmation | Operations team | Custody chain remains unbroken through the change |
| Market notice | Compliance function | Public disclosure timed to the filing, not before it |
| Audit trail | Finance team | Minting or burning log reconciled against the ledger |
- Draft an updated whitepaper or supply annex — the issuer's legal team prepares this first, since every later document references it.
- Assemble the token holder resolution — the corporate secretary or equivalent officer collects consent records, whether by vote or by written approval.
- Prepare the custody and subprocessor confirmation — the operations team requests written confirmation from local delivery partners; the underlying arrangement is described in Subprocessors, including local delivery partners in detail.
- Draft the market notice — the compliance function writes a short notice describing the change for the venue's public feed.
- Compile the audit trail — the finance team attaches the minting or burning log, timestamped and reconciled against the ledger.
- Submit the complete file — the authorised signatory files the set with the venue or authority in a single submission, not in parts.
Who decides and how long it takes
The decision sits with two bodies, not one. The trading venue that admitted the token reviews the market notice and the custody confirmation. The authority supervising the issuer reviews the whitepaper annex and the holder resolution. Each body sets its own review period and publishes it in its own procedural guidance, so the two clocks rarely align.
In practice, the file only closes once both bodies confirm receipt and raise no further query. A silent authority is not an approved authority. An issuer that hears nothing once the published period has passed should request written confirmation rather than assume approval by default.
Common scenarios
If the change only adjusts an internal cap without altering the number of tokens in circulation, the holder resolution can sometimes be replaced by a board resolution. Check the venue's own threshold before assuming this shortcut applies to your file.
If the token is admitted on more than one venue, each venue's file is separate. A single submission does not cover both, even when the underlying supply change is identical across markets.
If a subprocessor holds part of the custody chain, its written confirmation must predate the market notice, not follow it. Filing out of order is a common and avoidable cause of restart.
What this procedure does not cover
This procedure does not cover the initial issuance file, which follows a separate route with its own document set. It does not cover a change of jurisdiction for the issuer itself, and it does not decide whether a given supply change is commercially advisable — that question sits outside a procedural page.
For adjacent questions, the instant reports layer gives a narrower, jurisdiction-specific read. A counterparty check on a specific partner named in the custody confirmation is covered in Counterparty in Ireland.
A document-level check on the whitepaper annex itself, before it is filed, is covered in Document in Spain.
Where the token is instead admitted through a venue based outside the EU, the starting question is covered in Jurisdiction in United Arab Emirates.
Verified
Checked: 10 February 2025. This page describes the process only. No article or regulation number is cited here, because the national implementing measures behind a supply change are not mapped in the firm's registry for every jurisdiction where a token can be admitted. Confirm the current filing template directly with the venue or the supervising authority before submission.
FAQ
How long does supply change procedure take in practice?
There is no single figure. Each reviewing body publishes its own period and applies it only once the file is complete; an incomplete file does not start the clock. Treat the published period as a floor, not a promise, and query status in writing once it has passed.
Which documents are needed to start?
Five documents open the file: the updated whitepaper or supply annex, the token holder resolution, the custody and subprocessor confirmation, the market notice, and the audit trail. A file missing any one of these is returned before review begins, not queried during it.
What happens if the other side does not respond?
Silence is not approval. If the reviewing body issues no query and no confirmation once its published period has passed, request written confirmation of receipt and status. Escalate to a formal follow-up before assuming the change has taken effect.
Related reading
The supply change file mirrors much of the market-facing paperwork used elsewhere in this practice. Reviewing both files together avoids duplicate drafting: Secondary market arrangement step by step.
What to do first
If the issuer is preparing to offer the token in more than one country at the same time, the supply change file is only one part of a larger sequence. Start with What to do first in this situation.