Provide a concise narrative that clearly states each of (a)–(e) below.
Response
BAT is presented as a blockchain-based digital advertising and attention token intended to reduce fraud and misaligned incentives in digital advertising by connecting advertisers, publishers, and users in a more direct marketplace. BAT Overview White Paper BAT FAQ
Public materials show ongoing operational emphasis on running Brave Rewards and Brave Ads, supporting creators and publishers, expanding BAT utility across premium services and partner commerce, and continuing Brave-operated browser and rewards services across supported regions and account types. Most recent operational priorities are set out in BAT Roadmap 3.0 (November 2024): (i) disintermediating BAT flows through the platform, (ii) expanding self-custody options for payments and contributions, (iii) growing BAT utility across Web3 and multi-chain, and (iv) launching Brave Rewards 3.0 with on-chain payouts, quests, surveys, multipliers, and a Rewards Offer Wall, introduced in 2025. BAT Overview User Terms Brave Rewards FAQ Transparency Feed BAT Roadmap 3.0 Rewards 3.0 Partner Program
At a high level, Brave Browser users can opt into Brave Rewards, earn BAT for viewing or interacting with privately matched ads, and use BAT for contributions, creator support, and other ecosystem uses, while advertisers use the platform to place ads and publishers or creators can receive BAT through Brave-operated services Brave browser passed 115 million monthly active users and 49 million daily active users as of May, 2026. With with a DAU-to-MAU ratio that hovers around 42%. BAT Overview Brave About User Terms Publisher Terms Advertiser Terms Verified Creator Help
Public sources describe BAT as a utility token used as a unit of account for advertising and attention-based services, for user rewards, for contributions to creators and publishers, and for ecosystem uses such as Brave Premium, DEX swaps via Brave Wallet, NFT marketplace use, and .brave domain purchases; the cited materials do not describe BAT as conveying governance, equity, revenue-share, or similar holder rights. BAT FAQ What is BAT and SPL-BAT BAT Overview
The cited public record shows a service surface centered on Brave-operated browser, rewards, and advertising products, with access and functionality varying by region, operating system, account connection, and partner availability; no public onchain DAO or tokenholder governance control surface was identified in the cited sources. The BAT ERC-20 contract is immutable with no owner, no admin role, no mint function, no pause or freeze, and no upgrade proxy. For off-chain control, Brave Rewards backend, custodial integrations with Uphold, Gemini, bitFlyer, and ZebPay, and the Solana payout infrastructure that distributes already-bridged SPL-BAT to users is operated centrally by Brave. User Terms Brave Rewards FAQ Brave About
For each existing entity: Labs/DevCo (e.g., Founder, CEO, CTO, COO), Foundation (e.g., President, Executive Director, CFO, COO), and DAO / onchain governance leadership (if applicable) list the: (a) full names, (b) official titles, (c) and prior experience of key team members. For any non-existent entity, explicitly mention it does not exist. External links may be included but they will not factor into the score.
Response
Full Name | Entity | Official Title | Prior Experience |
|---|---|---|---|
Brendan Eich Brave About BAT Overview | Labs | Founder & CEO. Brave About BAT Overview | Creator of JavaScript and co-founder of Mozilla. Brave About BAT Overview |
Brian Bondy Brave About BAT Overview | Labs | Founder & CTO. Brave About BAT Overview | Formerly of Khan Academy and Mozilla. Brave About |
Luke Mulks Brave About BAT Overview | Labs | VP, Business Operations; co-author of the BAT whitepaper. | Background in ad-tech; host of The Brave Technologist podcast. |
Yan Zhu Brave About BAT Overview | Labs | Chief Information Security Officer | Senior staff technologist at the Electronic Frontier Foundation worked on HTTPS Everywhere, Privacy Badger, and the Let's Encrypt core team. |
Blockworks note: Labs/DevCo |
Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so. Address the lettered items below. Even if there is no DAO, there must be an answer to (d).
Response
No DAO or onchain governance entity exists for BAT.
No DAO or onchain governance entity exists for BAT. The BAT ERC-20 contract is verifiable on-chain and is non-upgradable, non-mintable, with no privileged admin role; after the ICO finalized no party can mint, freeze, blacklist, or pause BAT on Ethereum. BAT Overview User Terms Advertiser Terms
No DAO or onchain governance entity exists for BAT.
No DAO or onchain governance entity exists for BAT.
No DAO or onchain governance entity exists for BAT.
Blockworks note: No DAO or onchain governance entity exists for BAT.
For the Primary Foundation do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
No foundation entity exists for BAT.
No foundation entity exists for BAT.
No foundation entity exists for BAT.
No foundation entity exists for BAT.
No foundation entity exists for BAT.
No foundation entity exists for BAT.
Blockworks note: No foundation entity exists for BAT.
For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
Brave Software International SEZC is identified in the cited terms as a Cayman Islands company. User Terms Publisher Terms Advertiser Terms
BAT ownership and IP are controlled by Brave Software International.
No DAO or onchain governance entity exists for BAT.
No foundation entity exists for BAT.
The BAT ERC-20 contract is immutable with no owner, no admin role, no mint function, no pause or freeze, and no upgrade proxy. For off-chain control, Brave Rewards backend, custodial integrations with Uphold, Gemini, bitFlyer, and ZebPay, and the Solana payout infrastructure that distributes already-bridged SPL-BAT to users is operated centrally by Brave. User Terms Brave Rewards FAQ Brave About
Brave users who participate in Brave Ads receive 70% of advertising revenue in BAT purchased with advertiser dollars or other fiat currency. Transparency Feed
Blockworks note: The cited public record identifies Brave Software International SEZC as the operating company for Brave Rewards services and as a Cayman Islands company. User Terms Publisher Terms Advertiser Terms
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
The cited sale materials describe a 1.5 billion BAT launch supply, with up to 1 billion BAT created for sale and 500 million BAT pre-allocated to the company before the sale period began. Public sources also state that sold tokens were immediately transferable and that there was nolockup period except for the development pool. Sale OverviewSale OverviewToken Sale TermsWhite Paper
Public sale disclosures state that 1 ETH purchased 6,400 BAT, equal to 0.00015625 ETH per BAT The sale opened at 8AM PST on May 31, 2017 at Ethereum block 3,798,640. BAT FAQ Token Sale Terms White Paper
BAT. Sale Overview BAT FAQ What is BAT and SPL-BAT
The cited materials describe BAT as having a total supply cap of 1.5 billion tokens with no planned follow-on sale. As of May, 2026, circulating supply is approximately 1,495,724,657 BAT, equivalent to roughly 99.71% of the maximum supply per CoinMarketCap. Sale Overview BAT FAQ White Paper, BAT on CoinMarketCap
Public sources state that sold BAT were immediately transferable, the development pool was the only expressly locked pool at sale launch, and user-growth distributions were structured for release over time through grants and incentives rather than immediate unrestricted distribution. BAT FAQ states that unclaimed UGP tokens return to the pool after 90 days, while the token sale terms state that BAT received from the User Growth Fund and not transacted within 6months returns to the fund. BAT FAQToken Sale TermsSale Overview Contract addresses (for reference)
Address each of the following sub-items based on the project's airdrop status. If a sub-item does not apply to the project's situation, state that explicitly.
Response
Projects must disclose all material terms of market-making arrangements that affect token liquidity. If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. For each market maker, include in a table:
If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for this item.
Response
Blockworks note: No active or historical market maker agreements exist for BAT.
Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:
If the project has no agreements or deals with CEX or DEX, state that explicitly; doing so earns full credit; cash/fiat fee amounts are not required for this item.
Response
Blockworks note: The Brave team declined to disclose any active or historical CEX / DEX agreements or deals.
Disclose all prior token sales by the Project — including fundraising rounds, any material OTC sales to investors, and any discounted market-maker sales. For each sale, provide:
If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").
Response
Blockworks note: BAT explicitly states no follow-on BAT sale is planned. Brave has purchased BAT on the open market via Gemini, Uphold, and Coinbase to fund Brave Ads payouts; these purchases are disclosed at the Transparency Feed. BAT FAQ, Transparency Feed.
If any, list prior exploits or incidents that directly affected the token, token supply, tokenholder balances, token contract, minting controls, burn mechanics, or custody of token supply. This question is not asking about general protocol, application, or smart contract exploits unless the incident directly affected the native token itself. If no prior incidents, state this explicitly (e.g., "No exploits affecting tokenholders or protocol funds as of YYYY-MM-DD").
Response
Blockworks note: The BAT ERC-20 contract has not been exploited; the Wormhole-bridged SPL-BAT contract on Solana has not been exploited; and Brave Rewards' custodial settlement infrastructure (Uphold, Gemini, bitFlyer, ZebPay) has not had a publicly disclosed compromise affecting BAT custody. Brave operates a public HackerOne bug-bounty program. Brave on HackerOne, BAT contract on Etherscan
Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.
(a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:
Impact of Regulatory Change on TGE and Listings: (If applicable) How could evolving or conflicting laws and regulations affect your ability to complete the TGE, deliver tokens to purchasers, and list or maintain the token on trading venues in key jurisdictions?
Entity-Level Regulatory Impact: (If applicable) How could regulatory or legal changes impact your core entities (Foundation, DevCo, DAO, affiliated service providers), including enforcement actions, licensing requirements, or forced changes to structure or operations?
Tokenholder Tax Treatment: (If applicable) What uncertainties exist around how tokenholders may be taxed, and make clear that tokenholders are responsible for understanding their own tax obligations?
Jurisdictional & User Access Restrictions: (If applicable) If the project restricts access for certain jurisdictions or user types (e.g., U.S. persons, sanctioned countries, retail vs. professional), what are those restrictions and what risks do they create for users and for the project?
(b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:
Bugs and Design Flaws: (If applicable) What bugs, design flaws, or implementation errors could exist in your core protocol code, smart contracts, and any bridges, rollups, or oracles that you depend on, and how could these lead to loss of funds or disruption of the protocol?
Security Measures & Their Limitations: (If applicable) What security measures have you taken (audits, formal verification, bug bounties), and what types of failures might these measures still fail to detect or prevent?
(c) Token Economics, Unlocks & Incentive Risks — Describe how the token's economic design and supply schedule could affect holders by answering, at a minimum, questions like:
Critical Economic Assumptions: (If applicable) Which economic assumptions (e.g., staking yields, fee revenue, liquidity incentives, MEV capture, demand for blockspace) are critical for protocol security, utility, and governance, and what happens if those assumptions fail?
Governance Control over Monetary Policy & Rewards: (If applicable) To what extent can governance change monetary policy, fee parameters, or reward allocations (e.g., inflation rate, treasury flows, incentive programs), and how could such changes adversely affect tokenholders?
Response
Brave Rewards access and functionality can vary by region, provider availability, and legal restrictions, and some countries are not eligible to participate in Brave Rewards. User Terms Brave Rewards FAQ The user, publisher, and advertiser terms also condition use on compliance with applicable law, embargo and sanctions restrictions, and required licenses or governmental authorizations. User Terms Publisher Terms Advertiser Terms BAT-specific disclosures further state that BAT is not intended to be a digital currency, security, commodity, or similar financial instrument and that users remain responsible for determining and remitting applicable taxes. BAT FAQ Token Sale Terms What is BAT and SPL-BAT
The BAT and Brave Rewards surface depends on Brave browser and rewards infrastructure, partner wallet or custodial integrations, privacy-preserving ad matching, and anti-fraud controls, which means implementation, logging, or partner-integration failures can affect user balances, reward flows, or platform availability. BAT Overview User Terms Browser Privacy Notice The July/August 2020 brave://rewards-internals incident shows that BAT-related logging mistakes could expose sensitive reward-linked credentials, even though Brave reported fixes, token invalidation, and no known malicious use or real impact from the August case. 2020 Incident Brave's engineering policy also states that work related to money, BAT, cryptography, sensitive user information, and logs sent to Brave or third parties requires security/privacy review, which indicates an acknowledged operational security surface that still depends on review discipline and implementation quality. Security Reviews
BAT has a fixed 1.5 billion supply, over 99% of which BAT says is already in circulation. BAT Overview Sale Overview BAT utility and reward flows also depend on continued advertiser spending, Brave-operated rewards mechanics, partner integrations, and the programmatic use of advertiser dollars or other fiat currency to purchase BAT for rewards, while users in Brave Ads receive 70% of advertising revenue according to the transparency feed. Transparency Feed Brave Rewards FAQ Public sale materials also show that launch-era distribution included a user growth pool and development pool with structured release conditions, which means historical allocation design and platform incentive policy remain relevant to BAT's economic profile. Sale Overview BAT FAQ Token Sale Terms
This Token Transparency Filing is provided for general informational purposes only. Blockworks reviews completeness only and does not verify or warrant the accuracy of individual answers. Basic Attention is solely responsible for the content, accuracy, and legality of its disclosures.
