Regulatory framework

Compliance isn't an afterthought for Steady, it is the foundation the entire product was built on. Rather than launch first and address regulation later, we structured Steady around European-focused compliance from day one. This section explains the regulatory framework Steady operates under, who can use it, and the disclaimers every prospective holder should understand.

This section describes Steady's regulatory structure in general terms for informational purposes. It is not legal, financial, or investment advice. Prospective investors should conduct their own due diligence and consult their own advisors.

How Steady is Structured

The STDY Token is structured as a subordinated bearer bond (qualifiziert nachrangige Inhaberschuldverschreibung) issued by Steady Protocol (Europe) GmbH under German law, and qualifies as a financial instrument under MiFID II.

This classification is the cornerstone of Steady's regulatory positioning. Because STDY qualifies as a MiFID II financial instrument, it falls under the European Union's most established and rigorous regime for financial instruments — subject to the investor-protection standards of MiFID II and the EU Prospectus Regulation (2017/1129).

Why This Framework

Structuring Steady as a MiFID II financial instrument was a deliberate choice, and it carries several advantages:

• Higher investor protection. MiFID II's investor-protection standards are widely considered higher than those of the alternative crypto-asset frameworks. For institutional investors, that's a meaningful distinction.
• Institutional familiarity. MiFID II is a framework institutional investors already understand, trust, and operate within. A MiFID II-classified instrument is easier to allocate to and integrate into existing portfolios.
• Regulatory clarity. Anchoring Steady in a well-established framework provides legal clarity that newer, less mature regulatory regimes may not yet offer.

Relationship to MiCA

Steady does not fall under MiCA (the EU's Markets in Crypto-Assets Regulation). The reason is structural: MiCA explicitly excludes MiFID II financial instruments from its scope. Because STDY is classified as a MiFID II financial instrument, MiCA's regime does not apply — instead, the higher-standard MiFID II and EU Prospectus Regulation framework applies.

Licensing

Based on its structure and the external legal opinion underpinning it, Steady does not require a banking licence, an e-money licence, or investment-fund approval:

• Banking licence (KWG): Not required. The qualified subordination clause (Nachrangigkeit) excludes deposit-taking classification.
• E-money licence (ZAG): Not required. STDY is not e-money — it has no monetary value function, no payment use case, and is not accepted by third parties as a means of payment.
• Investment-fund approval (KAGB): Not required. There is no pooled investment strategy and no discretionary investment management; the qualified subordination excludes fund classification.