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B1 v1.1·Filed 12 Oct 2026Partial - 5 gaps

Contents

  1. Project & Team
  2. 01Description of Project
  3. 02Known Project Team
  4. 03DAO Structure
  5. 04Primary Foundation
  6. 05Primary Dev Co
  7. Token Supply & Allocations
  8. 06Initial Allocation
  9. 07Airdrop Process
  10. Transactions & Market Structures
  11. 08Market Maker Agreements & Deals
  12. 09CEX / DEX Agreements & Deals
  13. Financial Disclosures & Risks
  14. 10Prior Token Sales & Fundraising
  15. 11Previous Exploits Affecting The Native Token
  16. 12Material Risk Factors (Regulation, Technology, Token Economics)

This page was compiled by Blockworks using publicly available information reviewed consistent with the TTF, possibly together with information supplied directly by the project where provided. Project-supplied information may correct, update, or supplement the public record, and may not be independently verifiable; Blockworks presents it as provided and does not verify or warrant its accuracy. Because this page depends on what has been disclosed, it may be incomplete — certain categories are more likely to include undisclosed items (e.g., non-announced fundraisings or material relationships), and the absence of an entry should not be read as confirmation that none exists.

Project & Team

01Description of Project

Provide a concise narrative that clearly states each of (a)–(e) below.

  • (a) Problem the project solves — The problem the project is solving.
  • (b) Operational priorities — Provide a high-level description of how the project expects to support ongoing development and operations over time.
  • (c) High-level project overview — How the project works at a high level.
  • (d) Primary token functions — The primary functions of the token (e.g. gov participation).
  • (e) Control surface reliance — If any, briefly describe the anticipated or possible evolution of the protocol's governance/control model.

Response

(a) Problem the project solves

Stellar was launched as a decentralized protocol for sending and receiving money in any pair of currencies, so that a user can send from a Yen balance and have it arrive in Euros, Yen or bitcoin. Stellar now presents itself as a public blockchain for payments, asset tokenization, aid disbursements and on/off-ramps, with an average transaction cost of about $0.0007.

(Source: Introducing Stellar, Intro to Stellar)

(b) Operational priorities

The Stellar Development Foundation (SDF) funds ongoing development from the XLM it has held since 2014, when it was vested with authority to use XLM to enhance and promote Stellar. As of October 1 and 2, 2026, SDF reported 14,674,425,045 XLM across four account groups, namely SDF Development (2,220,529,166 XLM), Stellar Growth (5,553,800,546 XLM), Product and Innovation (3,536,498,114 XLM) and Assets and Liquidity (3,363,597,219 XLM). SDF sells XLM from the SDF Development account on Kraken, Coinbase, Bitstamp and through direct sales to pay operating expenses. Its 2026 strategy targets $1 billion of growth in network asset value, the signing of 15 new enterprises with at least 5 deployed in 2026, and greater liquidity depth.

Contents

  1. Project & Team
  2. 01Description of Project
  3. 02Known Project Team
  4. 03DAO Structure
  5. 04Primary Foundation
  6. 05Primary Dev Co
  7. Token Supply & Allocations
  8. 06Initial Allocation
  9. 07Airdrop Process
  10. Transactions & Market Structures
  11. 08Market Maker Agreements & Deals
  12. 09CEX / DEX Agreements & Deals
  13. Financial Disclosures & Risks
  14. 10Prior Token Sales & Fundraising
  15. 11Previous Exploits Affecting The Native Token
  16. 12Material Risk Factors (Regulation, Technology, Token Economics)

(Source: SDF Mandate, SDF 2026 Strategy)

(c) High-level project overview

Stellar nodes run Stellar Core, an implementation of the Stellar Consensus Protocol, to agree on transaction sets and apply them to the ledger, closing a ledger every 5 to 7 seconds. Consensus is reached through Federated Byzantine Agreement rather than mining, with each node choosing a set of other nodes it trusts not to collude. The protocol includes a built-in distributed exchange with order books, automated market maker pools added in Protocol 18 under CAP-38, and Soroban, a Rust-based smart contract platform launched with Protocol 20 on March 19, 2024.

(Source: Validators, Introducing Stellar, Intro to Stellar, Introducing Automated Market Makers on Stellar, Protocol Upgrades)

(d) Primary token functions

XLM, also called the lumen, is the native asset of the Stellar network. It pays transaction fees that prevent ledger spam, funds rent for smart contract data, and satisfies minimum account balances measured in base reserves of 0.5 XLM each. XLM carries no claim on fees, because fees collect in a fee pool that belongs to no account and that no one can access.

(Source: Lumens (XLM))

(e) Control surface reliance

Protocol upgrades and network settings, including fees, base reserve and Soroban configuration, change only when validators reach the same level of consensus required for transaction sets. SDF states that it does not control the Stellar network. In January 2024 SDF disarmed its own validators to postpone the Protocol 20 vote after a fee-bump bug was found, and said that upgrading the network is not something SDF does alone. SDF still maintains the Stellar codebase and controls about 29% of the 50,001,786,839.9 XLM in existence, so its software releases and treasury decisions remain the main practical influence on the network.

(Source: Upgrading the Network, Terms of Service, Our Decision to Disarm Validators, SDF Appoints Denelle Dixon, SDF Mandate, Lumens (XLM))

02Known Project Team

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

No separate Labs or DevCo exists for Stellar. The Stellar Development Foundation itself maintains the Stellar codebase and employs the engineering team (SDF Appoints Denelle Dixon, The SDF Team).

Labs/DevCo

No DevCo officer titles exist, and SDF's Chief Technology Officer Nicolas Barry and Chief Product Officer Tomer Weller hold their roles within the Foundation (The SDF Team).

No DevCo team exists to describe, and the engineering leadership is listed under the Foundation (The SDF Team).

Denelle Dixon

Foundation

CEO and Executive Director of the Stellar Development Foundation (The SDF Team)

Chief Operating Officer of Mozilla, where she led the fight for net neutrality and personal data control and worked on open Internet, encryption and privacy policy, before being appointed to lead SDF in March 2019 (SDF Appoints Denelle Dixon).

Jose Fernandez da Ponte

Foundation

President & Chief Growth Officer (The SDF Team)

Led PayPal's move into stablecoins and digital assets, including the launch of PYUSD, with experience across fintech, policy, emerging technology and work with regulators (Welcoming Jose Fernandez da Ponte).

Jed McCaleb

Foundation

Founder and Chief Architect, and member of the Board of Directors (The SDF Team)

Created the open-source technology behind Ripple and led Stellar development at launch, when he also sat on the founding board with Patrick Collison and Keith Rabois (Introducing Stellar).

David Mazières

Foundation

Founder and Chief Scientist (The SDF Team)

Head of Stanford's Secure Computer Systems group and creator of SFS and bcrypt when Stellar launched (Introducing Stellar).

Lin-Hua Wu

Foundation

Member of the Board of Directors (The SDF Team)

SVP and Chief Communications Officer at General Motors, as listed in the SDF board roster (The SDF Team).

Ronaldo Lemos

Foundation

Member of the Board of Directors (The SDF Team)

Professor of International and Public Affairs and Partner at PNM Advogados, and an adviser to the Foundation at Stellar's launch (The SDF Team, Introducing Stellar).

Ginger Baker

Foundation

Member of the Board of Directors (The SDF Team)

VP Product at Meta, as listed in the SDF board roster (The SDF Team).

Asiff Hirji

Foundation

Member of the Board of Directors (The SDF Team)

President of MoonPay, as listed in the SDF board roster (The SDF Team).

No DAO exists for Stellar. Protocol upgrades and network settings are decided by validator consensus under the Stellar Consensus Protocol, with no tokenholder vote (Upgrading the Network, Validators).

DAO/Onchain Governance

No onchain governance office exists, and the Tier 1 validator organizations that bear network safety and liveness hold no titled governance seats (Validators).

No DAO officeholders exist to describe, and SDF does not publish a named roster of validator representatives in its validator documentation (Validators).

03DAO Structure

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).

  • (a) IP ownership & control — State what IP the DAO owns or controls (e.g., codebases/repos, trademarks/brands). Note any license if relevant.
  • (b) Contract/admin powers — List onchain or administrative authorities and limits: pause/upgrade roles (e.g., multisig pause), governance-executor authorities, and the method of authority for each (e.g., veto, majority, super-majority).
  • (c) Locked-token rights (conditional) — If locking/staking for additional rights exists, explain the additional rights and what tokenholders can and cannot decide. If no locking mechanism exists, leave absent.
  • (d) Value accrual & holder rights — If any, describe the current rights of tokenholders over revenue distribution and the treasury.
  • (e) Dissolution authority — State who can dissolve/wind up the DAO and by what mechanism (e.g., onchain vote threshold, board resolution of a legal wrapper).

Response

(a) IP ownership & control

No DAO exists for Stellar, so no DAO owns or controls IP. The "Stellar" word trademark and the network logo belong to the Stellar Development Foundation, and the Stellar source code is open source under the Apache 2.0 license. The validator and upgrade documentation describes no DAO entity, DAO treasury or DAO-held repository.

(Source: Stellar Brand Policy, Upgrading the Network)

(b) Contract/admin powers

No DAO exists, and XLM is a protocol-native asset with no token contract, pause role or governance executor. Changes to protocol version, maximum transactions per ledger, base fee, base reserve and Soroban configuration settings take effect only when validators arm the same upgrade and reach the consensus level required for transaction sets, and only within 12 hours after the scheduled upgrade time. SDF showed the limit of its own authority in January 2024, when it disarmed its validators and said the outcome depended on what other validators chose to do.

(Source: Upgrading the Network, Validators, Our Decision to Disarm Validators)

(c) Locked-token rights (conditional)

No locking or staking mechanism for XLM exists. Validator participation in consensus and upgrade votes comes from running Stellar Core and being included in other nodes' quorum sets, not from holding or locking XLM, so holding XLM confers no additional rights.

(Source: Validators, Introducing Stellar)

(d) Value accrual & holder rights

XLM holders have no rights over revenue distribution or any treasury. Transaction fees collect in a fee pool that belongs to no account and that no one can access, and the roughly 14.67 billion XLM held by SDF are deployed at SDF's discretion under its mandate rather than by holders. The 2017 mandate states that SDF does not and will not ever profit from transaction fees.

(Source: Lumens (XLM), SDF Mandate, SDF Previous Mandate)

(e) Dissolution authority

No DAO exists, so no DAO dissolution mechanism exists. The network itself has no wind-down function, since it runs on independent servers operated by validators. The reviewed SDF mandate, terms of service and team pages do not describe how the Foundation itself could be dissolved or what would happen to its XLM in that case.

(Source: Terms of Service, SDF Mandate, The SDF Team)

04Primary Foundation

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.

  • (a) Entity — Type and jurisdiction.
  • (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional) and an explanation of any subsidiary entities.
  • (c) Powers over DAO, treasury, protocol-controlled resources, and token administration — If any, describe the current powers over DAO governance, treasury actions, protocol-controlled resources (e.g. revenue), token administration, or reward parameters, and the method/threshold for each.
  • (d) Powers over DevCo — Explain whether the foundation can exert direct or indirect influence over decision-making of the DevCo.
  • (e) Contract/admin powers — Pause/upgrade/governance-executor authorities and the method/threshold for each (e.g., veto/majority/super-majority; "3/5 multisig").
  • (f) Current economic arrangements and distribution policies — Describe any current governance-approved, contractual, or programmatic mechanisms, if any, by which protocol-controlled resources, treasury assets, fees, revenue, rewards, or token distributions may be directed to this entity, its equityholders, contributors, or other participants. If no such mechanism currently exists, state that explicitly. Do not discuss hypothetical future dividends, repurchases, or distributions unless formally adopted.

Response

(a) Entity

The Stellar Development Foundation, also known as Stellar.org, was incorporated in 2014 as a non-stock nonprofit corporation in the U.S. State of Delaware. It has no stock, no profits given to individuals and no private inurement. SDF describes itself as a non-profit that is not a charity, is self-funded, pays taxes and has no shareholders.

(Source: SDF Previous Mandate, SDF Mandate, Terms of Service)

(b) IP ownership & control

"Stellar" is a trademark of SDF, and use of SDF's brand assets in product, project, domain or social media names requires SDF's prior written consent. Stellar source code is governed by the Apache 2.0 license, and forks may not use the brand in a way that misrepresents their source or affiliation. SDF maintains Stellar's codebase. The reviewed mandate, brand policy and terms of service do not name any SDF subsidiary.

(Source: Stellar Brand Policy, SDF Appoints Denelle Dixon, SDF Mandate)

(c) Powers over DAO, treasury, protocol-controlled resources, and token administration

No DAO exists for SDF to direct. SDF controls its own XLM holdings of 14,674,425,045 XLM as of October 1 and 2, 2026, about 29% of supply, and reallocates funding support among its activities as ecosystem needs dictate, with no external approval threshold disclosed. SDF has no power to mint XLM or change fees on its own, since fees, base reserve and protocol versions change only through validator consensus. The 2017 mandate placed lumen distribution under the oversight of SDF's Expansion Board.

(Source: SDF Mandate, SDF Previous Mandate, Upgrading the Network, Lumens (XLM))

(d) Powers over DevCo

No DevCo exists for SDF to influence. SDF itself maintains the Stellar codebase and employs the engineering leadership, including Chief Technology Officer Nicolas Barry and Chief Product Officer Tomer Weller, so development decisions are made inside the Foundation.

(Source: SDF Appoints Denelle Dixon, The SDF Team)

(e) Contract/admin powers

SDF holds no pause, upgrade or governance-executor key over XLM or the network. It runs validators that vote on protocol upgrades alongside other validators, and an upgrade passes only with consensus at the level required for transaction sets. In January 2024 SDF disarmed its validators to postpone the Protocol 20 vote after a fee-bump bug was found in Stellar Core v20.1.0.

(Source: Upgrading the Network, Our Decision to Disarm Validators, Fee Bump Bug Disclosure)

(f) Current economic arrangements and distribution policies

SDF funds itself by selling XLM from the SDF Development account on Kraken, Coinbase, Bitstamp and through direct sales, and it reimburses that account for work funded by the Growth, Product and Innovation, and Assets and Liquidity accounts. Salaries are paid first from SDF Development. The Growth account funds grants, the Stellar Community Fund, Enterprise Fund investments and the seeding of ETFs and ETPs, and the Assets and Liquidity account funds market-making programs for key assets and grants to on/off-ramp providers. No protocol fee or revenue flows to SDF, since fees go to an inaccessible fee pool. SDF commits to a quarterly report accounting for XLM usage.

(Source: SDF Mandate, Lumens (XLM))

05Primary Dev Co

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.

  • (a) Entity — Type and jurisdiction.
  • (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional) and an explanation of any subsidiary entities.
  • (c) Powers over DAO, treasury, protocol-controlled resources, and token administration — If any, describe the current powers over DAO governance, treasury actions, protocol-controlled resources (e.g. revenue), token administration, or reward parameters, and the method/threshold for each.
  • (d) Powers over Foundation — Explain whether the DevCo can exert direct or indirect influence over decision-making of the Foundation.
  • (e) Contract/admin powers — Pause/upgrade/governance-executor authorities and the method/threshold for each (e.g., veto/majority/super-majority; "3/5 multisig").
  • (f) Current economic arrangements and distribution policies — Describe any current governance-approved, contractual, or programmatic mechanisms, if any, by which protocol-controlled resources, treasury assets, fees, revenue, rewards, or token distributions may be directed to this entity, its equityholders, contributors, or other participants. If no such mechanism currently exists, state that explicitly. Do not discuss hypothetical future dividends, repurchases, or distributions unless formally adopted.

Response

(a) Entity

No primary DevCo exists for Stellar. The Stellar Development Foundation, a Delaware non-stock nonprofit corporation, both issued the original XLM distribution mandate and maintains the codebase, and its team page lists the technology and product leadership as Foundation officers.

(Source: SDF Previous Mandate, SDF Appoints Denelle Dixon, The SDF Team)

(b) IP ownership & control

No DevCo exists, so no DevCo holds IP or subsidiaries. The Stellar trademark belongs to SDF and the source code is released under the Apache 2.0 license, which leaves no IP outside the Foundation and the open-source repositories.

(Source: Stellar Brand Policy)

(c) Powers over DAO, treasury, protocol-controlled resources, and token administration

No DevCo exists, so no DevCo holds powers over a DAO, treasury or token administration. The only disclosed XLM treasury is SDF's 14,674,425,045 XLM, and network parameters change only through validator consensus.

(Source: SDF Mandate, Upgrading the Network)

(d) Powers over Foundation

No DevCo exists, so no DevCo can influence the Foundation. SDF is governed by its own Board of Directors of Jed McCaleb, Lin-Hua Wu, Ronaldo Lemos, Ginger Baker and Asiff Hirji, and has no shareholders.

(Source: The SDF Team, SDF Mandate)

(e) Contract/admin powers

No DevCo exists, so no DevCo holds pause, upgrade or executor authority. XLM has no token contract with admin roles, and protocol changes require validator consensus.

(Source: Upgrading the Network, Lumens (XLM))

(f) Current economic arrangements and distribution policies

No DevCo exists, so no mechanism directs XLM, fees or revenue to a DevCo or its equityholders. Development is funded directly by SDF from its SDF Development account, and network fees go to a fee pool that no one can access.

(Source: SDF Mandate, Lumens (XLM))

Token Supply & Allocations

06Initial Allocation

Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.

  • (a) Launch supply totals — The total number of tokens issued at launch, the total number of tokens locked at launch or the total number of tokens unlocked at launch.
  • (b) Recipient categories & use of funds — The recipient categories with brief explanations as to how the category will use the tokens so an auditor can distinguish each bucket.
  • (c) Initial price per token (if applicable) — The initial price per token at TGE. If the token launched via a liquidity bootstrapping mechanism, auction, or other price-discovery process rather than a fixed offering price, describe that mechanism and the final market set price instead. If no fixed price was set, state so.
  • (d) Ticker / market symbol — The ticker/market symbol.
  • (e) Total supply & supply regime — The total supply and whether the supply is fixed (if not explain inflation rate or deflation rate).
  • (f) Initial vesting / release schedules — The initial vesting/release schedules (identify which categories/recipients are subject to vesting and the high-level timing logic).

Response

(a) Launch supply totals

At the genesis of the Stellar network, 100 billion lumens were created. Of these, 100,000,000,000 XLM were issued at launch, none were locked by the protocol, and all 100,000,000,000 were unlocked at the protocol level, held by SDF for distribution. SDF was to distribute 95 billion to the public for free and hold 5 billion for operations. No lockup applied to the network supply itself, and the only disclosed restriction was a voluntary agreement by the SDF founders and Stripe not to sell lumens they received for at least five years.

(Source: SDF Previous Mandate, Introducing Stellar)

(b) Recipient categories & use of funds

  • Category: Direct Sign-up Program
    • Allocation: 50%
    • Tokens: 50,000,000,000 XLM
    • Use: Free distribution to individuals with a low barrier to entry
  • Category: Partnership Program
    • Allocation: 25%
    • Tokens: 25,000,000,000 XLM
    • Use: Distribution through other nonprofits focused on financial inclusion
  • Category: Bitcoin Program
    • Allocation: 20%
    • Tokens: 20,000,000,000 XLM
    • Use: Free distribution to holders of bitcoin (19%) and XRP (1%) to encourage use of Stellar and exchange support
  • Category: SDF operations
    • Allocation: 5%
    • Tokens: 5,000,000,000 XLM
    • Use: Held by SDF for operational costs and periodically auctioned on exchanges

The 2017 mandate sets out these four buckets, with distribution overseen by SDF's Expansion Board. In November 2019 SDF ended the World Giveaway and Partner Giveaway programs and burned 50 billion of the 68 billion lumens still earmarked for them.

(Source: SDF Previous Mandate, SDF's Next Steps)

(c) Initial price per token (if applicable)

No fixed price was set. XLM was distributed for free rather than sold in a priced offering, and the launch announcement stated that 95% of the supply would be given away as quickly as possible.

(Source: Introducing Stellar)

(d) Ticker / market symbol

The ticker is XLM, and the asset is called the lumen. At launch in 2014 the asset was called "stellar".

(Source: Lumens (XLM), Introducing Stellar)

(e) Total supply & supply regime

The supply is now fixed at 50,001,786,839.9124767 XLM, and no more lumens will be created. Supply grew by 1% a year through an inflation mechanism until validators ended it on October 28, 2019 with Protocol 12 and CAP-26. In November 2019 SDF burned 55 billion lumens, 5 billion from its operating fund and 50 billion from the giveaway programs, by sending them to an account with no signers. The developer documentation records 55.4 billion XLM as locked by SDF in 2019, and SDF stated it would not burn any additional lumens.

(Source: Lumens (XLM), CAP-0026, Stellar Lumens, SDF's Next Steps)

(f) Initial vesting / release schedules

  • Category: SDF founders
    • Vesting or release logic: Voluntary agreement not to sell lumens received through employee grants for at least five years
    • Circulating treatment: Conditional. Counted as circulating once granted, subject to the voluntary five-year no-sale agreement.
  • Category: Stripe
    • Vesting or release logic: Voluntary agreement not to sell the 2 billion lumens received as loan repayment for at least five years, with any Stripe auction requiring buyers to accept the same five-year restriction
    • Circulating treatment: Conditional. Counted as circulating once received, subject to the voluntary five-year no-sale agreement.
  • Category: Public distribution buckets
    • Vesting or release logic: No vesting, with lumens given away through sign-up, partner and claim programs
    • Circulating treatment: No while held by SDF, and yes once given to recipients.
  • Category: SDF operations (2017 mandate)
    • Vesting or release logic: Held by SDF for operating costs and periodically auctioned on exchanges, with 5 billion lumens of this fund burned in November 2019
    • Circulating treatment: No while held by SDF, and yes once auctioned or spent.
  • Category: SDF Direct Development (2019 mandate)
    • Vesting or release logic: 12 billion lumens escrowed to unlock 3 billion XLM per year for four years
    • Circulating treatment: No while escrowed or held by SDF.

The five-year restriction comes from the 2017 mandate, and the escrow schedule comes from the November 2019 mandate.

(Source: SDF Previous Mandate, SDF's Next Steps)

07Airdrop Process

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.

  • (a) Planned but not yet executed airdrop — If the project has planned but not yet airdropped, commit to publishing a recipient wallet list in a public channel and provide it to Blockworks quarterly until the initial TGE airdrop is fully completed. Additionally, generally state the possible target user segments (e.g., "stakers of X," "Aave users") and the allocation method (e.g., proportional to ve-balance or net position).
  • (b) Executed airdrop — If the project has already airdropped, point to a per-address source such as CSV/TSV/JSON files, a Dune table, a full Merkle dump, GitHub repo files embedding per-address allocations, or RPC endpoints that expose claim/amount data; explorer links alone do not count. Additionally, clearly state covered user segments (e.g., "stakers of X," "Aave users") and the allocation method (e.g., proportional to ve-balance or net position).
  • (c) No airdrop planned or conducted — If the project does not plan to conduct an airdrop for TGE and has never conducted one, state so plainly (e.g., "We have never conducted an airdrop to date and do not plan to execute one").

Response

Planned but not yet executed airdrop

Not applicable. No new airdrop is planned, because SDF ended its giveaway programs in November 2019 and kept only 4 billion lumens for in-app distributions through Stellar-built apps that have already shown traction. SDF has made no commitment to publish quarterly recipient wallet lists for that pool.

(Source: SDF's Next Steps)

Executed airdrop

SDF ran several free distributions. The Bitcoin Program offered 16 billion lumens to bitcoin holders, pro rata to holdings at a June 26, 2017 snapshot, with claims opening June 27, 2017 through signed messages or through exchanges such as Kraken and Poloniex, and reserved 1 billion lumens for XRP holders with less than 7.5 million XRP as of May 2014. The bitcoin snapshot is the first block mined after midnight UTC on June 26, 2017, block hash 00000000000000000159c6d590497c65281934c9b3d530c5fb812f1beb96d15a, when about 16,215,950 BTC existed, and each address could claim 16,000,000,000 times its balance divided by 16,215,950 lumens between June 27 and August 27, 2017. Because the formula is fixed, the per-address allocation for every bitcoin address can be read from any Bitcoin node RPC at that block. The XRP cutoff was ledger 6,762,000, which closed on May 22, 2014, with eligible XRP holders receiving lumens pro rata at a 10 to 1 share. The Keybase spacedrop paid 100 million XLM a month, up to 2 billion XLM over 20 months, to Keybase users who registered before the announcement. Blockchain.com distributed up to 500 million XLM, announced on November 6, 2018 as worth $125 million, to its wallet users, giving $25 worth of XLM to each user who verified their identity, first come first served until the reserved supply ran out, and the 2017 mandate planned a Direct Sign-up Program to give lumens to individuals. Apart from the published June 26, 2017 bitcoin balance snapshot that set Bitcoin Program allocations, SDF has not published a per-address allocation file for these programs, so recipient amounts can otherwise be traced only through the public ledger.

Transactions & Market Structures

08Market Maker Agreements & Deals

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:

  • (a) Market maker's name — the market maker's name;
  • (b) Token allocation or loaned amount — the token allocation or loaned amount as a percentage of total supply;
  • (c) Duration/term of agreement — the duration/term of the agreement; and, where applicable,
  • (d) Name of agreement structure — label the financial vehicle being used in the agreement (i.e. loan, option/call, retainer model) without describing trading strategy or expected outcomes.

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

  • Market Maker Name: No named market-maker agreement for XLM is disclosed. SDF's mandate says the Assets and Liquidity account funds market-making programs for key assets, but it names no market maker and does not say whether XLM pairs are covered (SDF Mandate, An Updated Mandate for a Growing Stellar Ecosystem).
    • Token Allocation Committed: No XLM is disclosed as loaned or allocated to a market maker, and the Assets and Liquidity account held 3,363,597,219 XLM as of October 2, 2026 with no per-program breakdown (SDF Mandate).
    • Term Duration: No market-making term is disclosed in the mandate or the 2025 mandate update (SDF Mandate, An Updated Mandate for a Growing Stellar Ecosystem).
    • Structure Name: No agreement structure such as a loan, option or retainer is disclosed for any market-making program (SDF Mandate).

09CEX / DEX Agreements & Deals

Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:

  • (a) Exchange name / DEX pool — the exchange name (and, for DEX, the specific pool/pair);
  • (b) Token allocation for listing — the token allocation supplied or committed for listing as a percentage of total supply;
  • (c) Term Duration — the duration/term of any listing lockups, liquidity, or incentive programs; and, where applicable,
  • (d) Native-token listing fees — whether any listing fees were paid in native tokens, with amounts (tokens or % of supply), recipients, and any vesting or lock terms tied to the partnership.

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

  • Exchange Name: Kraken, Coinbase and Bitstamp, where SDF sells XLM from its SDF Development account to fund operations (SDF Mandate).
    • Token Allocation Committed: No XLM is disclosed as allocated or committed for a listing, and SDF describes these venues only as places where it sells XLM (SDF Mandate).
    • Term Duration: No listing lockup, liquidity or incentive term is disclosed for any exchange (SDF Mandate, Stellar for Exchanges).
    • Native Token Listing Fees: No listing fee paid in XLM is disclosed, and SDF's exchange page describes integration support without listing terms (Stellar for Exchanges).
  • Exchange Name: Stellar DEX order books and protocol-native AMM pools, which, as proposed in CAP-38, use constant product pools with a fixed 0.3% fee paid to liquidity providers (Introducing Automated Market Makers on Stellar).

Financial Disclosures & Risks

10Prior Token Sales & Fundraising

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:

  • (a) Series Name
  • (b) Early-Stage Investment Instrument used (i.e. SAFT, STAMP, SAFE, SAFE+Token Warrant, etc.)
  • (c) Date of sale (at least month & year)
  • (d) Number of tokens sold (or % of total supply)
  • (e) Vesting schedule

If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").

Response

  • Series Name: Stripe seed funding (SDF Previous Mandate, Introducing Stellar)
    • Investment Vehicle: A $3,000,000 loan from Stripe to SDF, later repaid in lumens rather than cash (SDF Previous Mandate).
    • Date Of Sale: Stripe's $3 million investment was announced on July 31, 2014, and the repayment date is not disclosed (SDF Previous Mandate, VentureBeat, Payment Processor Stripe Launches a New Currency, July 31, 2014).
    • Number of tokens sold: 2,000,000,000 lumens, or 2% of the 100 billion genesis supply (SDF Previous Mandate).
    • Vesting Schedule: Stripe voluntarily agreed not to sell the lumens for at least five years, and any Stripe auction required buyers to accept the same restriction, with net profits returned to SDF (SDF Previous Mandate).
  • Series Name: Operations reserve exchange auctions (SDF Previous Mandate)
    • Investment Vehicle: Periodic auctions on various exchanges (SDF Previous Mandate).
    • Date Of Sale: Ongoing under the 2017 mandate, with individual auction dates not disclosed (SDF Previous Mandate).
    • Number of tokens sold: Drawn from the 5% operations reserve of 5,000,000,000 lumens, with per-auction amounts not disclosed (SDF Previous Mandate).
    • Vesting Schedule: No vesting applied to auction buyers, and the mandate discloses no buyer restrictions (SDF Previous Mandate).
  • Series Name: SDF Development account sales (SDF Mandate)
    • Investment Vehicle: Sales on Kraken, Coinbase and Bitstamp and direct sales to counterparties that are not named (SDF Mandate).
    • Date Of Sale: Ongoing, with no sale dates disclosed (SDF Mandate).
    • Number of tokens sold: Per-sale amounts are not disclosed. The account's original balance of 11,954,850,982 XLM stood at 2,220,529,166 XLM on October 2, 2026, a figure that also reflects operating payments and inter-account reimbursements (SDF Mandate).
    • Vesting Schedule: No vesting terms for buyers are disclosed. The 2019 mandate escrowed the 12 billion lumen Direct Development allocation to unlock 3 billion XLM per year for four years (SDF Mandate, SDF's Next Steps).

11Previous Exploits Affecting The Native Token

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").

  • (a) Date & component affected — Date (YYYY-MM or YYYY-MM-DD), chain(s)/component affected.
  • (b) Exploit vector summary — Plain-language summary of the exploit vector (what the hack was).
  • (c) Quantified impact — Quantified impact (assets/tokens affected or a clear "no loss of funds" statement).
  • (d) Remediation/response taken — Remediation/response taken (patches, upgrades, governance actions, compensation).
  • (e) Current status — Current status (resolved, in litigation, under investigation, refunded, etc.).
  • (f) References (optional) — References (optional): link(s) to post-mortem/advisory/PR.

Response

(a) Date & component affected

2017-04, Stellar mainnet, in the Stellar Core merge account operation (the doApply function of MergeOpFrame). Network incidents that did not affect XLM supply or balances, in April 2021, January 2024 and October 2025, are covered in §12(b).

(Source: Cointelegraph, Stellar Patched an Inflation Bug, crypto.news, Stellar Quietly Patched a 2.25 Billion XLM Inflation Bug)

(b) Exploit vector summary

An attacker exploited a concurrency bug in the merge account operation to create XLM that should not have existed. The illicit XLM was moved to exchanges and likely sold during the first half of 2017. The incident became widely known when Messari published research on it on March 27, 2019.

(Source: crypto.news, Stellar Quietly Patched a 2.25 Billion XLM Inflation Bug, Coinspeaker, Stellar Inflation Bug, )

12Material Risk Factors (Regulation, Technology, Token Economics)

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?

This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.

(Source: We're Distributing 16 Billion Lumens to Bitcoin Holders, Keybase Stellar Lumens Spacedrop, crypto.news, Blockchain Wallet Is Giving Away $125 Million Worth of Stellar Lumens, November 6, 2018, Bringing Lumens to Millions, SDF Previous Mandate)

No airdrop planned or conducted

Not applicable. SDF conducted the Bitcoin Program, Keybase and Blockchain.com distributions described above.

(Source: We're Distributing 16 Billion Lumens to Bitcoin Holders)

  • Token Allocation Committed: No SDF allocation of XLM to DEX or AMM pools is disclosed, although the Assets and Liquidity account may fund onchain liquidity incentives (SDF Mandate).
  • Term Duration: No term is disclosed for any DEX liquidity program (SDF Mandate).
  • Native Token Listing Fees: No native-token listing fee applies, since the proposal allowed anyone to deposit into a pool through a single operation (Introducing Automated Market Makers on Stellar).
Cointelegraph, Stellar Patched an Inflation Bug

(c) Quantified impact

About 2.25 billion XLM were created, worth roughly $10 million at the time and equal to about 25% of circulating supply in April 2017. The impact was dilution of supply until SDF offset it.

(Source: Cointelegraph, Stellar Patched an Inflation Bug, crypto.news, Stellar Quietly Patched a 2.25 Billion XLM Inflation Bug)

(d) Remediation/response taken

The bug was patched in Stellar Core, and Stellar said it had noted the bug and its exploitation twice in release notes. SDF burned an equal amount of XLM from its community reserve so that holders would not be diluted and the projected supply would stay accurate. After the 2019 reports, Stellar said its disclosure standards had grown and committed to a full accounting of SDF's lumens by the end of 2019.

(Source: Coinspeaker, Stellar Inflation Bug, crypto.news, Stellar Quietly Patched a 2.25 Billion XLM Inflation Bug, Cointelegraph, Stellar Patched an Inflation Bug)

(e) Current status

Resolved. The bug was patched in 2017 and the supply was offset by the SDF burn. The cited reports do not mention any recovery, prosecution or restitution.

(Source: Cointelegraph, Stellar Patched an Inflation Bug, Coinspeaker, Stellar Inflation Bug)

(f) References (optional)

The cited reports reference only the Stellar Core release notes and Messari's March 27, 2019 research report.

(Source: Cointelegraph, Stellar Patched an Inflation Bug, crypto.news, Stellar Quietly Patched a 2.25 Billion XLM Inflation Bug, Coinspeaker, Stellar Inflation Bug)

  • 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

    (a) Regulatory, Legal & Tax Risks

    Impact of Regulatory Change on TGE and Listings:

    XLM has been distributed since 2014 and has no pending TGE, so regulatory risk falls on continued trading. SDF states that it does not offer securities-related services in the United States or to U.S. persons and is not registered with the SEC. A change in how regulators classify XLM or SDF's sales could limit exchange support, including the Kraken, Coinbase and Bitstamp venues SDF uses to sell XLM for its operating budget.

    (Source: Terms of Service, SDF Mandate)

    Entity-Level Regulatory Impact:

    SDF is a Delaware nonprofit that pays taxes and states that it is not a money transmitter, does not hold custody of users' private keys or lumens, and does not control the network. New licensing rules for token issuers, treasury holders or software publishers could require SDF to change how it sells XLM, makes grants or runs validators. SDF's 2026 strategy targets enterprises, NGOs and government agencies, which increases its exposure to rules in many jurisdictions, and its mandate funds global policy advocacy to address that risk.

    (Source: Terms of Service, SDF Mandate, SDF 2026 Strategy)

    Tokenholder Tax Treatment:

    Tax treatment is uncertain for XLM received through the Bitcoin Program, the Keybase spacedrop and other free distributions, for inflation payouts received before October 2019, and for XLM paid out through SDF grants. SDF states that it does not provide tax advice. Tokenholders are responsible for understanding and meeting their own tax obligations in their jurisdictions.

    (Source: Terms of Service, Lumens (XLM), Keybase Stellar Lumens Spacedrop)

    Jurisdictional & User Access Restrictions:

    The network is open to anyone, but SDF's terms require users of its services to represent that they are not in an embargoed region, including Sudan, Crimea, North Korea, Iran and Cuba, and are governed by California law with exclusive venue in San Francisco County courts. The 2017 Bitcoin Program excluded residents of New York, Georgia, New Hampshire, Connecticut and sanctioned nations. These limits restrict who can use SDF services and can push users in those regions toward third-party wallets and venues.

    (Source: Terms of Service, We're Distributing 16 Billion Lumens to Bitcoin Holders)

    (b) Protocol, Technology & Security Risks

    Bugs and Design Flaws:

    Stellar Core bugs have disrupted the network several times. On April 6, 2021 an issue took several validating and Horizon nodes offline, including SDF nodes, and validators upgraded to Protocol 16 with a fix on April 10, 2021. In January 2024 a bug in Stellar Core v20.1.0 sent fee-bump refunds to the wrong account, and it was caught before Protocol 20 went live. A state archival bug introduced on June 1, 2025 went live with Protocol 23 on September 3, 2025, was found on October 9 and resolved on October 23, 2025, and left 84 of 478 corrupted data entries unrepaired, which led to the Protocol 24 stability upgrade.

    (Source: Protocol 16 Upgrade Guide, Fee Bump Bug Disclosure, State Archival Issue Post-Mortem, Protocol Upgrades)

    Security Measures & Their Limitations:

    SDF runs a bug bounty on HackerOne covering the Stellar protocol and Core, SDF-maintained repositories and stellar.org properties, with payouts set by severity and fixes taking up to 90 days. Protocol 23 passed a security audit on August 21, 2025 with no state archival findings, yet the archival bug was already in the code, which shows that audits can miss state-handling errors. Network safety and liveness also depend on the Tier 1 validator organizations, so a coordinated failure or a shared software bug among them could halt the network.

    (Source: Bug Bounty, State Archival Issue Post-Mortem, Validators)

    (c) Token Economics, Unlocks & Incentive Risks

    Critical Economic Assumptions:

    XLM has no staking yield and no fee share, so its value rests on demand for fees, smart contract rent and minimum balances of 0.5 XLM per base reserve as network use grows. SDF holds 14,674,425,045 XLM, about 29% of the 50,001,786,839.9 XLM supply, and funds its operations by selling XLM, so a lower XLM price shortens SDF's runway while SDF sales add supply to the market. Liquidity for network assets depends on DEX, AMM and CEX venues and on SDF-funded market-making and liquidity programs.

    (Source: Lumens (XLM), SDF Mandate)

    Governance Control over Monetary Policy & Rewards:

    Tokenholders cannot vote on monetary policy. Validators can change the base fee, base reserve and Soroban settings through network upgrades, and CAP-26 disabled inflation in a way that allows a future protocol change to restore it. SDF alone decides how its four accounts are spent and can reallocate funding support among its activities as it judges ecosystem needs. SDF said in 2019 that it would burn no additional lumens, but no protocol rule prevents it from accelerating sales or grants that add circulating supply.

    (Source: Upgrading the Network, CAP-0026, SDF Mandate, SDF's Next Steps)