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Token TransparencyCoW Protocol
COW ·B2 v2.2 ·CompleteComplete
Token

Project & Team

01

Description of Project

Provide a narrative description of the purpose of the project.

CoW Protocol is an intent-based trading protocol deployed on Ethereum and other supported EVM-compatible chains. Users authorise orders specifying the assets, amounts, price constraints, validity period and other applicable conditions under which they are willing to trade.

Eligible orders are processed through an off-chain competition in which independent solvers compute candidate solutions. Candidate solutions may match compatible user orders directly or source liquidity from on-chain or other available liquidity sources. Eligible solutions are assessed under the applicable competition rules, and the transaction corresponding to the selected solution may then be submitted for on-chain settlement.

If the transaction is included and successfully processed by the relevant blockchain, the GPv2Settlement smart contract validates and processes the authorised fills, transfers and interactions. A settlement cannot validly require a user to accept an economic outcome outside the conditions authorised in that user's order.

CoW Protocol is designed to mitigate certain forms of MEV, including front-running and sandwiching, through mechanisms including batch auctions and solver competition. It does not guarantee execution, price improvement or complete protection from MEV.

Users retain control of their wallets and assets until settlement. No CoW entity takes custody or discretionary control of user assets as part of the ordinary trading process. During a successful settlement, the relevant smart contracts transfer the amounts authorised by users in accordance with the applicable approvals and order constraints.

02

Known 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.

Labs / DevCo

Full Name

Official Title

Prior Experience

Anna George

Co-Founder

Previously Senior Product Manager at Gnosis. CoW Protocol was incubated within Gnosis before spinning out as an independent project.

Foundation

Full Name

Official Title

Prior Experience

Glenn Kennedy

Director of CoW Foundation

20+ years in offshore governance and corporate structuring. He focuses on independent directorships, entity oversight, and governance advisory for Cayman Islands investment funds and management firms.

Leeward Supervisors

Supervisor of CoW Foundation

Cayman Islands professional services firm acting as independent supervisor. Oversees director activities and Foundation compliance.

DAO / Onchain Governance

Full Name

Official Title

Prior Experience

DAO/onchain governance leadership does not exist

Governance is exercised through the CoW governance process, including public CoW Improvement Proposals and COW token-holder voting through the cow.eth Snapshot space [COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW]. Implementation of approved decisions is undertaken through the applicable Safes, legal entities or other designated mechanisms depending on the subject matter of the proposal.

03

DAO Structure

Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so for each sub question. Even if there is no DAO, there must be an answer to (d). Address the lettered items below.

  • (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 on-chain 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) Current tokenholder governance rights and economic arrangements — If any, describe the current governance rights of tokenholders and any presently operative rights or arrangements relating to treasury actions, fee-routing, rewards, buybacks, or other protocol-controlled resources. If none, state that explicitly.
  • (e) Control surface reliance — If any, briefly describe the anticipated or possible evolution of the protocol's governance/control model.
  • (f) Dissolution authority — State who can dissolve/wind up the DAO and by what mechanism (e.g., on-chain vote threshold, board resolution of a legal wrapper).

(a) IP ownership & control

Pursuant to CIP-64 and the legal structure established under it, CoW Foundation is the designated owner and manager of intellectual property rights originating from or created for CoW DAO, subject to applicable third-party rights and open-source licences.

This includes CoW-related brands and trade marks and intellectual property created for CoW DAO by entities within the legal structure. Intellectual property created by CoW Core Limited in connection with its CoW-related activities is transferred to CoW Foundation pursuant to the applicable IP assignment arrangements.

A substantial part of the CoW Protocol codebase is publicly available under open-source licences, including Apache, GPL and other licences depending on the relevant repository. Open-source licensing grants rights to users under those licences; it does not by itself mean that the underlying copyright is unowned.

Ownership of intellectual property should be distinguished from technical control over deployed smart contracts. CoW Foundation's ownership of relevant source-code IP does not, by itself, give CoW Foundation the ability to pause, upgrade or otherwise control a deployed smart contract.

(b) Contract/admin powers

CoW governance is conducted through COW token-holder proposals and voting through the cow.eth Snapshot space. Approved decisions are implemented through the relevant Safe, legal entity or technical mechanism where implementation is required.

The principal currently disclosed control surfaces include:

CoW DAO Main Safe. Ethereum address 0xcA771eda0c70aA7d053aB1B25004559B918FE662. The Safe has a 3/5 signing threshold and is used to implement matters falling within its mandate following applicable governance approval [COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW; execution through CoW DAO Main Safe: 3/5].

GPv2Settlement. The deployed production GPv2Settlement implementation is non-upgradeable and non-pausable. Settlement submission is, however, restricted to callers satisfying the applicable solver-authentication mechanism.

GPv2AllowListAuthentication. Solver authentication is provided through the GPv2AllowListAuthentication component. The authenticator maintains the solver allow-list. Unlike GPv2Settlement, GPv2AllowListAuthentication is deployed through an upgradeable proxy. The manager can add or remove solvers, and the manager can be replaced by the proxy owner or by the manager itself.

  • Add/remove solvers**:** Solver Controller / Solver Voucher Safe
  • Change Manager: Proxy Owner (CoW DAO Main Safe)

Solver Controller / Solver Voucher Safe. Ethereum address 0x423cEc87f19F0778f549846e0801ee267a917935, threshold 4/15. It administers solver admission and removal under the applicable DAO-approved participation and bonding rules**** [DAO governance mandate: COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW; operational execution through Solver Controller / Solver Voucher Safe: 4/15]. Operational responsibility is delegated to CoW Core Limited within that mandate.

Solver Payouts Safe. Ethereum address 0xA03be496e67Ec29bC62F01a428683D7F9c204930, threshold 4/11. It is used for solver reward distributions under the governance-approved solver-reward framework, including CIP-20 and applicable successor CIPs, including CIP-85 [COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW; operational execution through Solver Payouts Safe: 4/11]. Operational responsibility for reward calculation and distribution is delegated to CoW Business Limited within that mandate.

COW token supply. The COW token permits inflation of up to 3% of total supply, subject to the contract mechanics and a minimum interval of 365 days. Any decision to activate inflation is subject to CoW governance and the applicable implementation process.

Neither CoW Foundation nor CoW Core Limited holds unilateral pause or upgrade authority over GPv2Settlement or the COW token contract.

(c) Locked-token rights (conditional)

NA

(d) Current tokenholder governance rights and economic arrangements

COW is a governance token. CoW governance is conducted through the cow.eth Snapshot space, with voting power determined by the applicable governance rules, including COW holdings and eligible vested-but-unclaimed vCOW at the relevant snapshot block.

Subject to the applicable governance process, COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW, COW token holders may approve or reject CIPs addressing matters including protocol parameters, fee policies, solver participation and bonding rules, solver incentives, treasury actions, grants, partner programmes and other matters within CoW governance.

Governance may also approve mandates concerning the entities established under CIP-64, including appointments or changes to those entities. Where a governance decision requires a formal corporate action, the decision must be implemented through the appropriate corporate mechanism in accordance with the relevant entity's constitutional documents and applicable law. A Snapshot vote does not itself constitute the corporate act of appointing a director, removing a supervisor or dissolving a company.

Current economic arrangements include protocol-level fees determined under applicable governance decisions; solver rewards under CIP-20; grants and security expenditure; partner-related fees and reward programmes; treasury-management activity; and governance-approved COW buybacks.

CoW DAO has authorised COW token buybacks under CIP-36 and CIP-48. CoW Business Limited operationally executes the authorised transactions within its mandate.

Repurchased COW remains available for DAO-directed uses, including future solver-reward initiatives, subject to applicable governance decisions.

There are currently no dividends, equity repurchases or distributions of profit to natural persons or external equityholders arising from CoW DAO governance.

(e) Control surface reliance

The current legal structure allocates defined functions to CoW Foundation, CoW Core Limited, CoW Business Limited and CoW Hosting Limited pursuant to CIP-64 and subsequent governance-approved mandates.

Those allocations are not intended to make any one entity the general operator or controller of CoW Protocol. Where governance determines that a mandate should be changed, transferred or terminated, the relevant governance and corporate steps may be taken to implement that change.

Changes affecting a legal entity remain subject to the entity's constitutional documents, applicable law and any duties owed by its directors or other officeholders.

(f) Dissolution authority

CoW governance may approve a proposal directing that all or part of the legal structure established under CIP-64 be reorganised or wound down [COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW].

Such a governance vote would constitute the governance authorisation for the proposed action. It would not itself dissolve a Cayman Islands or British Virgin Islands entity. It allows the Director to wind down the Foundation. Any dissolution, director change, supervisor change or other corporate action must also be implemented through the formal procedure required by the relevant entity's constitutional documents and applicable law.

04

Primary Foundation

For the Primary Foundation do the following independently. If a Foundation does not exist, state so for each sub question. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definition: The primary Foundation can be explained as the entity which was directly/indirectly involved in the issuance of the native token at launch. If the original Foundation has been dissolved and in its place a "new Foundation" was created, then detail the "new Foundation".

  • (a) Entity — Type and jurisdiction.
  • (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional)
  • (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).
  • (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.

(a) Entity

CoW Foundation is the Primary Foundation. It is a Cayman Islands foundation company.

(b) IP ownership & control

Pursuant to CIP-64, CoW Foundation is the designated owner and manager of intellectual property rights originating from or created for CoW DAO, subject to applicable third-party rights and open-source licences.

This includes the relevant CoW brands and trade marks and IP assigned to CoW Foundation by entities in the legal structure. CoW-related IP created by CoW Core Limited is transferred to CoW Foundation pursuant to the applicable IP assignment arrangements.

Relevant software repositories are made available under their respective open-source licences. The existence of an open-source licence does not itself transfer ownership of the underlying copyright.

IP ownership is separate from administrative control of deployed contracts. CoW Foundation does not acquire a pause, upgrade or transaction-control power over a deployed contract merely because it owns or manages intellectual property associated with the relevant code.

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

CoW Foundation was established under CIP-64 to perform legal, treasury, administrative and coordination functions for CoW DAO within defined mandates.

It does not originate CoW governance decisions and does not have unilateral authority to amend DAO governance, the COW token supply or GPv2Settlement.

CoW Foundation manages certain DAO financial assets within its treasury-management mandate. Treasury-management functions, including administration of allocated funds, are conducted through the Treasury Committee established under CIP-62, including support from kpk. The CIP-62 treasury mandate was established through a COW token-holder vote on Snapshot, subject to a minimum quorum of 35 million COW tokens voting, and CIP-62 fund allocation has been substantially executed to date.

COW token holders continue to determine material treasury, fee, solver-reward and related governance parameters through the applicable governance process, exercised via a Snapshot vote among COW token holders and subject to that same minimum quorum of 35 million COW tokens voting.

CoW Foundation has no unilateral authority to alter the COW token contract or GPv2Settlement and does not hold a direct administrative key allowing it to pause or upgrade those contracts.

(d) Powers over DevCo

CoW Core Limited is a British Virgin Islands company limited by guarantee. CoW Foundation is its sole member and guarantor and acts as its corporate director.

CoW Foundation therefore has the corporate powers arising from that formal relationship, subject to applicable BVI law and the relevant constitutional documents.

Operationally, CoW Core performs development and technical functions pursuant to DAO governance-approved mandates. CoW Foundation coordinates implementation of mandates across the legal structure and provides funding under applicable approved budgets, but does not thereby acquire every technical or protocol function performed by CoW Core.

(e) Contract/admin powers

CoW Foundation is a Cayman Islands Company Foundation mandated by CoW DAO to act as the DAO's legal interface. It does not have unilateral authority over DAO governance, has no authority over the COW token supply or the settlement contract, and does not hold direct admin keys over the production settlement contract or the COW token contract.

The production settlement contract and the COW token contract remain under DAO multisig authority.

CoW Foundation owns the Operational CoW DAO Safe (CIP-43) - an OPEX dedicated safe - and mandates the Core Team and Foundation Operator to operationalize that safe for the bug bounty program, ETH flow funding, and smart contracts. The Operational CoW DAO Safe has a 2/3 signer setup, with signers representing the Director, the Foundation Operator and the Core Team. Authority for those actions comes from a COW token-holder majority via Snapshot, execution is carried out by the relevant multisig, and proposals require a minimum quorum of 35 million COW tokens voting.

CoW Foundation does not hold any authority or admin power over the DAO's smart contracts, neither does it have any upgrade / freeze / pause power over them. The CoW Foundation is bound to token governance, executing decisions in the real world that are appointed or defined by governance.

The Operational CoW DAO Safe is a mere gas and bounty OPEX safe and is not to be confused with the CoW DAO main safe.

(f) Current economic arrangements and distribution policies

CoW Foundation receives and manages assets for the purposes authorised under its mandate, including treasury assets and amounts transferred to it by related entities under the applicable arrangements. Treasury assets may also generate yield under the Treasury Committee mandate established under CIP-62.

Under CIP-64, the running-cost budget for the four-entity legal structure was estimated at approximately USD 130,000 for the first ten months of operation and approximately USD 180,000 per year thereafter for the entire structure, subject to the applicable budget terms, including the Director's permitted discretion and reallocation between the entities. These amounts relate to the running costs of the legal structure and are not the Service Agreement budget for substantive services.

Separately, CIP-79 approved a USD 12.6 million Service Agreement No. 5 budget for calendar year 2026. CoW Foundation allocates that approved service budget quarterly among CoW Foundation, CoW Core Limited, CoW Hosting Limited and CoW Business Limited in line with their respective workstreams and mandates. Each legal entity then subcontracts the Core Team Service Provider for its respective workstream and compensates the Service Provider monthly in arrears. The CIP-79 service budget is separate from the CIP-64 running-cost budget for the legal structure.

Other governance-approved uses of DAO resources include grants, security audits and bug bounties, solver rewards, partner programmes, treasury-management activity and contributor incentive programmes.

Under CIP-83, CoW DAO approved a 50 million COW replenishment of the CoW Team Grant Allocation through a four-year stream. CIP-83 also established a performance-based incentive tier of up to 100 million COW, subject to the applicable milestone conditions.

CoW DAO has also authorised COW token buybacks under CIP-36 and CIP-48, operationally executed by CoW Business Limited within its mandate.

There are no current distributions of profits, dividends or equity to natural persons or external equityholders through CoW Foundation.

05

Primary DevCo

For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly across each sub-question. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definition: The primary DevCo can be explained as the entity which was directly/indirectly involved in the issuance of the native token at launch. If the original DevCo has been dissolved and in its place a "new DevCo" was created, then detail the "new DevCo".

  • (a) Entity — Type and jurisdiction.
  • (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional)
  • (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.

(a) Entity

The Primary DevCo is CoW Core Limited, a British Virgin Islands company limited by guarantee.

CoW Core performs development and technical functions relating to CoW Protocol and associated infrastructure within its governance-approved mandates.

CoW Core has no unilateral or shared governance-executor authority

(b) IP ownership & control

Pursuant to CIP-64, CoW Core Limited does not retain ownership of CoW-related intellectual property created for CoW DAO. CoW Core does not own or control CoW-related IP

Intellectual property developed by CoW Core in connection with its CoW-related activities is transferred to CoW Foundation pursuant to the applicable IP assignment arrangements, subject to third-party rights and open-source licences.

CoW Core may develop, maintain or contribute to software distributed under open-source licences. The applicable licence governs use of that software; CoW Core's technical contribution does not mean that it owns the wider CoW Protocol intellectual-property portfolio.

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

CoW Core performs development and technical-operational functions within DAO governance-approved mandates. These include work relating to backend infrastructure, the orderbook, Autopilot, the Reference Driver, solver research and development, analytics and solver-participation infrastructure.

CoW Core has delegated operational responsibility for solver admission and removal through the Solver Controller / Solver Voucher arrangement, subject to DAO-approved solver eligibility and bonding rules. Solver approval or removal from listing is executed through the Solver Controller Safe, which carries the same 4/15 signer threshold set out in Q3b.

CoW Core Limited does not hold any governance-executor authority. It cannot alter, control or manage the COW token supply. It has no token administration power. CoW Core cannot pause or upgrade GPv2Settlement, or vary DAO-defined solver eligibility rules outside its mandate.

CoW Core does not have authority over treasury actions or protocol-controlled resources outside the specific operational functions delegated to it under applicable mandates. CoW Core Limited has no signing authority through the CoW DAO Main Safe's 3/5 threshold.

Solver reward calculation and distribution are operationally managed by CoW Business Limited under the governance-approved solver-reward framework, including CIP-20 and applicable successor CIPs, including CIP-85. CoW Core may provide technical systems, data or analytics used in connection with those processes but does not hold the payout mandate

(d) Powers over Foundation

CoW Core Limited exists as a British Virgin Islands Company Limited by Guarantee. CoW Core does not exert decision-making influence over CoW Foundation: CoW Foundation is CoW Core’s sole guarantor and corporate director, CoW Core operates strictly under mandates issued by CoW DAO via the governance mechanism, and CoW Core has no power over the Foundation.

(e) Contract/admin powers

  • CoW Core does not hold authority to pause GPv2Settlement
  • CoW Core does not hold authority to upgrade GPv2Settlement
  • CoW Core does not hold governance-executor authority

(f) Current economic arrangements and distribution policies

CoW Core's corporate running costs form part of the structure-wide running-cost budget established under CIP-64.

Separately, under CIP-79, CoW Foundation allocates part of the USD 12.6 million 2026 Service Agreement No. 5 budget to CoW Core for the workstreams falling within CoW Core's mandate and compensates the Service Provider monthly in arrears. The 2026 allocation to CoW Core workstreams is USD 5.8 million, covering backend and smart contracts, solvers, and DevOps/infrastructure. The USD 5.8 million is a service-provider/workstream budget and should not be characterised as CoW Core's corporate running-cost budget.

CoW Core does not receive protocol-generated resources dynamically as dividends or distributions, and there are no current dividends or distributions to natural persons or external equityholders.

06

Affiliated Protocol Contributor

Definition (for this section): An Affiliated Protocol Contributor (APC) is a non-issuer company - not the protocol's primary Foundation or DevCo - that materially contributes to the protocol's code, operations, governance, or funding. For example, Blockworks Advisory would be considered an APC of Ethena because it materially contributes to its operations through Ethena's risk council. Provide a structured description per APC. If no APCs exist, state that explicitly across each sub-question. Items below apply per APC.

  • (a) Identity & role — Legal name, entity type, jurisdiction, and role (e.g., core development, security, infrastructure, market making, operations).
  • (b) Parameter control & scope — For each existing APC, if any, what major protocol parameters the APC controls; include the method of authority (e.g., veto, majority, super-majority). If none, say so.
  • (c) Contract/admin powers — For each existing APC, if any, provide the pause/upgrade powers (e.g., multisig pause), governance-executor authorities and limitations; include the method of authority for each (e.g. veto, majority, super-majority). If none, say so.
  • (d) Compensation and material economic arrangements — For each existing APC, if protocol-generated resources or economic value is dynamically routed to the APC, describe the arrangement. If applicable, include the resource sources, routing mechanism, payment frequency, and duration. If no protocol resources or resources-linked economics are routed to the APC, state that explicitly.

(a) Identity & role

APC #1: CoW Business Limited
Legal name: CoW Business Limited. Entity type: BVI limited liability company organised as a company limited by shares, sole shareholder CoW Foundation, with CoW Foundation as corporate director. Jurisdiction: British Virgin Islands.
Role: commercial relationships including CEX listings, market makers, partner integrations and fee agreements under CIP-61, as amended by CIP-75; operational management of protocol payment safes; solver reward calculation and distribution underthe governance-approved solver-reward framework, including CIP-20 and applicable successor CIPs, including CIP-85; COW token buybacks under CIP-36 and CIP-48; MEV Blocker related payments.

APC #2: CoW Hosting Limited
Legal name: CoW Hosting Limited. Entity type: BVI company limited by guarantee, sole member CoW Foundation, with CoW Foundation as corporate director. Jurisdiction: British Virgin Islands.
Role: UI hosting and maintenance including CoW Swap and CoW Widget, domain ownership, user support and token list management.

APC #3: kpk (formerly karpatkey)
Legal name: Karpatkey Foundation, trading as "kpk" (formerly "karpatkey"). Entity type: Cayman Islands company operating as an onchain asset management firm, spun out of the Gnosis ecosystem and governed by the kpk DAO. Jurisdiction: Cayman Islands.
Role: provides treasury management services to the CoW Treasury Safe (0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669) to generate yield on idle treasury funds, in coordination with the Treasury Committee under CIP-62 and under CoW Foundation's treasury management mandate. Maintains the public CoW DAO treasury dashboard at app.syncrone.fi/public/cow and publishes monthly treasury reports on forum.cow.fi.

APC #4: Leeward Management Limited
Legal name: Leeward Management Limited. Entity type: Cayman Islands corporate services firm providing independent directorship and fiduciary services. Jurisdiction: Cayman Islands.
Role: provides the natural-person Director for CoW Foundation, serves as Secretary of the Foundation handling secretarial work and AML for funds received, and was mandated by the Mooderator CIP (CIP-64) to incorporate the four legal entities on behalf of CoW DAO.

APC #5: Leeward Supervisors Limited
Legal name: Leeward Supervisors Limited. Entity type: Cayman Islands professional services firm acting as independent supervisor. Jurisdiction: Cayman Islands.
Role: acts as Supervisor of CoW Foundation, providing independent oversight of Director activities and compliance with the Articles of Association, with authority to remove the Director for gross negligence, to initiate investigations independently, and an obligation to respond to concerns raised by interested parties.

APC #6: Wintermute
Legal name: Wintermute. Contracting entities in the Wintermute group are Wintermute Trading Ltd, incorporated in England and Wales, and Wintermute Asia Pte Ltd, incorporated in Singapore. Entity type: private limited company. Jurisdiction: England and Wales / Singapore.
Role: market maker for COW, engaged under the market maker mandate held by CoW Business Limited, with a 0.75% of supply commitment under a one-year loan and option structure.

APC #7: Keyrock
Legal name: Keyrock SA. Entity type: Belgian société anonyme. Jurisdiction: Belgium.
Role: market maker for COW, engaged under the market maker mandate held by CoW Business Limited, with a 0.25% of supply commitment under a one-year loan and option structure.

(b) Parameter control & scope

For the disclosed non-issuer service-provider APCs, no major protocol-parameter control is held, and no veto, majority, or super-majority method of protocol-parameter authority applies.

  • kpk**(**Karpatkey) provides treasury management services to the CoW Treasury safe to generate yield on idle treasury funds, in coordination with the Treasury Committee and under the Foundation’s treasury management mandate. Karpatkey does not control protocol parameters; its scope is limited to treasury yield strategies within the Treasury Committee’s CIP-mandated authority. It is a co-signer on the CoW Treasury safe, but it is only one part of the treasury committee and does not unilaterally control strategy or allocations.
  • Leeward Management Limited provides the natural-person Director for CoW Foundation, serves as Secretary, handles secretarial work and AML for funds received, and was mandated to incorporate the four legal entities on behalf of CoW DAO. It has no protocol-parameter control and no on-chain admin authority. Its authority is limited to corporate secretarial, AML, and director duties, with director-level authority over CoW Foundation subject to Supervisor oversight and removability by CoW DAO governance.
  • Leeward Supervisors Limited acts as Supervisor of CoW Foundation and provides independent oversight of director activities and compliance with the Articles of Association, including authority to remove the director for gross negligence and initiate investigations independently. It has no protocol-parameter control and no on-chain authority; its authority is off-chain supervisory authority over the Foundation’s director.

(c) Contract/admin powers

CoW Business Limited. Holds no pause or upgrade authority over the GPv2Settlement contract or the COW token contract, and no unilateral authority over DAO governance or token administration. CoW Business applies parameters set by CIP and controls no protocol parameters itself; it cannot vary on-chain fee parameters. Ultimate authority over funds in all safes below rests with CoW DAO. Delegated authority (CIP-64: majority):

  • Solver Payouts safe, 0xA03be496e67Ec29bC62F01a428683D7F9c204930, Ethereum. Threshold 4/11. This is the safe referred to as the Payout Safe and is also the recipient of fees collected from the settlement contract. Permitted actions: calculation and execution of solver reward payouts under the governance-approved solver-reward framework, including CIP-20 and applicable successor CIPs, including CIP-85. Limitations: the reward formula is fixed by the applicable governance-approved reward framework, leaving no discretion over amounts beyond applying the formula; cannot redirect funds outside the approved payout scope. Method of authority: the applicable solver-reward CIPs (majority).
  • COW token buybacks. Executed through market transactions on the open market via TWAP orders. Permitted actions: weekly revenue-funded repurchase of COW. Limitations: mandate covers the entirety of solver rewards emitted in the week, capped at 120% of solver rewards; cannot mint; repurchased tokens are held at the DAO's disposal and any reuse for future solver reward initiatives requires governance approval. Method of authority: CIP-36 (majority) and CIP-48 (majority).
  • Partner fee agreements and partner-related payments. Permitted actions: negotiation and signing of fee agreements with partners on behalf of CoW DAO, and payment of amounts due. Limitations: bound by the fee framework, ranges and caps set in CIP-61 as amended by CIP-75; cannot exceed the approved maximum partner share or vary the on-chain fee parameters, which are set by CIP. Method of authority: CIP-61 and CIP-75 (majority).
  • Market maker relationships. Permitted actions: negotiation and administration of market-making agreements, including the loan and option structures with Wintermute and Keyrock. Limitations: supply commitments are limited to those approved by CIP, currently 0.75% and 0.25% of supply for one-year terms; CoW Business cannot commit additional supply without a further CIP. Method of authority: CIP mandate CIP-64: majority.
  • MEV Blocker related payments. Permitted actions: settlement of amounts arising from the MEV Blocker arrangement. Limitations: within the mandate and budget approved by CIP. Method of authority: CIP-64 (majority).

CoW Hosting Limited. None. Holds no pause, upgrade, parameter-setting or governance-executor authority over the GPv2Settlement contract, the COW token contract or any other CoW Protocol contract, and is not a signer on any safe holding protocol funds or COW. Its control surface is off-chain only: ownership and DNS administration of the protocol's domains, hosting and deployment of the CoW Swap and CoW Widget frontends, and curation of the token list. Those functions can restrict or alter access to the hosted interfaces but cannot alter on-chain protocol behaviour, order settlement or user funds. Method of authority: mandate from CoW Foundation as sole member and corporate director, amendable or revocable by CIP; Director appointment and removal by COW token holder majority via Snapshot.

kpk. Holds no pause, upgrade, parameter-setting or governance-executor authority over any CoW Protocol contract.

  • CoW Treasury Safe, 0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669, Ethereum. Threshold 3/5. kpk is one co-signer alongside CoW DAO signers. Permitted actions: execution of treasury yield strategies and POL management within the Treasury Committee's mandate. Limitations: signing authority only; cannot act without two further signers; scope is constrained by a role-based permissions policy restricting permitted destinations and interactions; no authority over the COW token contract or the settlement contract; is one part of the Treasury Committee and does not unilaterally control strategy or allocations. The investment policy statement is public and regularly updated. Method of authority: CIP-62.

Leeward Management Limited. None. Holds no pause, upgrade, parameter-setting or governance-executor authority over any CoW Protocol contract, and is not a signer on any safe holding protocol funds or COW. Its authority is off-chain and corporate: Director and Secretary duties for CoW Foundation under the Foundation's incorporation documents, exercisable subject to oversight by the Supervisor. Method of authority: appointment by COW token holder majority via Snapshot; removal by the same majority, and removal for gross negligence by the Supervisor.

Leeward Supervisors Limited. None. Holds no pause, upgrade, parameter-setting or governance-executor authority over any CoW Protocol contract, and is not a signer on any safe. Its authority is off-chain supervisory authority over the Foundation's Director, comprising oversight of Director activities and compliance with the Articles of Association, removal of the Director for gross negligence, and initiation of independent investigations. Method of authority: appointment and removal by CoW DAO governance via Snapshot.

Wintermute and Keyrock. None. Neither holds pause, upgrade, parameter-setting or governance-executor authority over any CoW Protocol contract, and neither is a signer on any safe holding protocol funds. Each relationship is contractual only, governed by a market-making agreement administered by CoW Business Limited. Method of authority: contract, within the supply commitment approved by CIP.

(d) Compensation and material economic arrangements

CoW Business Limited. CoW Business's corporate running costs form part of the structure-wide running-cost budget under CIP-64.

Separately, under CIP-79, USD 3.0 million of the 2026 Service Agreement No. 5 budget is allocated to CoW Business workstreams. Revenue collected by CoW Business, including partner fees and protocol service fees is included in treasury management. No dividends or distributions to natural persons are in operation.

No compensation-linked dynamic routing of protocol resources to CoW Business exists: it handles protocol revenue operationally but retains none of it as compensation.

CoW Hosting Limited. CoW Hosting's corporate running costs form part of the structure-wide running-cost budget under CIP-64.

Separately, under CIP-79, USD 1.5 million of the 2026 Service Agreement No. 5 budget is allocated to CoW Hosting workstreams.

No dividends or distributions to natural persons are in operation. No protocol-generated resources or resource-linked economics are dynamically routed to CoW Hosting Limited.

kpk. Compensation is a hybrid fee comprising a fixed services component and a performance component calculated as a percentage of returns above a hurdle rate set separately per asset type. The fee sits within, and below, the ceiling previously approved by CIP for treasury management services; the specific commercial terms are contained in the services agreement and are not published.
Source of payment: CoW DAO treasury assets held in the CoW Treasury Safe under the Core Treasury Mandate. Routing mechanism: payment by discrete transaction from the CoW Treasury Safe (0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669), each requiring the 3/5 signing threshold. There is no automated, contract-level or standing payment authority. Payment frequency: periodic, settled by transaction from that safe and reflected in the monthly treasury reports published on forum.cow.fi. Duration: for the term of the treasury management mandate under CIP-62, continuing until amended or revoked by CIP.
No protocol-generated resources or resource-linked economics are dynamically routed to kpk. Protocol fee revenue does not flow to kpk, and its compensation is not a share of protocol fees, solver rewards or partner fees. The performance component is calculated on treasury investment returns, not on protocol revenue. This remains the only disclosed APC arrangement with a performance-linked economic component.

Leeward Management Limited. Fee-for-service, paid in fiat from the operational budget allocated by CoW DAO under CIP-58 and the auto-renewing annual operational budget. A one-time setup cost of approximately $50,000, plus or minus 10%, was borne by the service provider under CIP-58. No token-based compensation. No protocol-generated resources or resource-linked economics are dynamically routed to Leeward Management Limited.

Leeward Supervisors Limited. Fee-for-service, paid in fiat from the operational budget. No token-based compensation. No protocol-generated resources or resource-linked economics are dynamically routed to Leeward Supervisors Limited.

Wintermute. Committed 0.75% of total supply under a one-year loan and option structure administered by CoW Business Limited. The commitment is a loan of COW with an associated option, not a grant or fee. No cash fee funded from protocol resources is disclosed, and no protocol-generated resources or resource-linked economics are dynamically routed to Wintermute.

Keyrock. Committed 0.25% of total supply under a one-year loan and option structure administered by CoW Business Limited, on the same basis. No protocol-generated resources or resource-linked economics are dynamically routed to Keyrock.

Separately, CoW DAO operates a paid affiliate program under CIP-84 under which referrers and providers of volume receive a share of fees generated by the DAO. This filing does not identify company participants in that affiliate program as APCs.

Token Supply & Allocation

07

Initial Allocation

Download the Worksheet, enable macros, complete the Initial Allocation sheet, then use Convert To CSV to export the file for import here. To make edits after importing, update the worksheet, use Convert To CSV again, then re-import the new CSV. The table is the final answer.

Ticker

Date

Allocation Category Name

Recipient Type

Allocation %

Allocation Tokens

TGE Unlock %

TGE Unlock Tokens

Cliff Months

Cliff Unlock %

Linear Vesting Months

Cadence Months

Circulating Treatment

Notes on what each category is used for

If applicable: Contract / Wallet address

COW

2022-02-11

CoW DAO Treasury

Treasury

44.40%

444,000,000

100.00%

444,000,000

0

0.00%

0

1

Conditional

CoW DAO Treasury: funds protocol development, solver rewards, grants and DAO operations; all COW minted at deployment was sent to the CoW DAO. Not subject to the 4-year linear vest. Conditional because CoW DAO excludes treasury holdings from circulating supply until spent (Circulating = Total - Unvested - DAO Treasury Holdings). Source: https://docs.cow.fi/governance/token ; https://github.com/gnosis/cow-token

COW

2022-02-11

Team

Insiders

15.00%

150,000,000

0.00%

0

0

0.00%

48

1

No

Team: core contributor compensation and long-term alignment. Received vCOW at TGE, vesting linearly over 4 years from deployment, convertible 1:1 into COW once vested. Source: https://docs.cow.fi/governance/token

0xD057B63f5E69CF1B929b356b579Cba08D7688048

COW

2022-02-11

GnosisDAO

Ecosystem

10.00%

100,000,000

0.00%

0

0

0.00%

48

1

Conditional

GnosisDAO: allocation to the parent DAO from which CoW DAO was spun off (GIP-13). Received vCOW at TGE with the 4-year linear vest. Conditional because tokens vest into a separate DAO treasury and require a governance spend before reaching public hands. Source: https://docs.cow.fi/governance/token ; https://forum.gnosis.io/t/gip-13-phase-2-cowdao-and-cow-token/2735

0xD057B63f5E69CF1B929b356b579Cba08D7688048

COW

2022-02-11

CoWmunity Airdrop

Community

10.00%

100,000,000

100.00%

100,000,000

0

0.00%

0

1

Conditional

CoWmunity Airdrop: retroactive distribution to early CoW Protocol / GNO-holder users. Not subject to the 4-year linear vest - fully available at TGE. Conditional because tokens required an eligibility-based Merkle claim before entering circulation. Source: https://docs.cow.fi/governance/token ; https://github.com/gnosis/cow-token

0xD057B63f5E69CF1B929b356b579Cba08D7688048

COW

2022-02-11

CoWmunity Investment

Community

10.00%

100,000,000

0.00%

0

0

0.00%

48

1

No

CoWmunity Investment: community investment round purchased at TGE (paid claims in USDC/GNO/native token via the vCOW contract). Received vCOW subject to the 4-year linear vest. Source: https://docs.cow.fi/governance/token ; https://github.com/gnosis/cow-token

0xD057B63f5E69CF1B929b356b579Cba08D7688048

COW

2022-02-11

Investment Round

Private / VC

10.00%

100,000,000

0.00%

0

0

0.00%

48

1

No

Investment Round: early/private investor round providing funding for protocol growth; initial price $0.15 per token. Received vCOW at TGE subject to the 4-year linear vest. Source: https://docs.cow.fi/governance/token

0xD057B63f5E69CF1B929b356b579Cba08D7688048

COW

2022-02-11

CoW Advisory

Insiders

0.60%

6,000,000

0.00%

0

0

0.00%

48

1

No

CoW Advisory: advisors supporting protocol strategy and growth. Received vCOW at TGE subject to the 4-year linear vest. Total supply at TGE 1,000,000,000 COW; supply is not hard-capped - the COW contract lets CoW DAO mint up to 3% of total supply per year, min once every 365 days. Source: https://docs.cow.fi/governance/token ; https://github.com/gnosis/cow-token

0xD057B63f5E69CF1B929b356b579Cba08D7688048

08

Vesting Insider Tokens

If there are no post-TGE token compensation plans, state explicitly they do not exist across each sub-question. If there are, explain each of (a)–(b) below.

  • (a) Post-TGE employee lock as % of total supply — State the current total amount of tokens locked attributable to post-TGE employees, expressed as a percentage of total supply.
  • (b) Typical post-TGE vesting schedule — Describe the standard vesting terms used for post-TGE grants, including: cliff length (or "no cliff"), vesting frequency (e.g., monthly/quarterly), and total duration.

(a) Post-TGE employee lock as % of total supply

Post-TGE token compensation plans exist.

As of 18 August 2026, tokens locked attributable to post-TGE contributors equal 5.0% of total supply (50,000,000 COW of 1,000,000,000). This is the CoW Team Grant Allocation replenishment approved under CIP-83. The four-year stream began in February 2026, so no individual grant funded from it has completed vesting and less than 0.1% of total supply has vested to date.

Of that 5.0%: the portion already streamed into the Team Grant Allocation is held either as unvested individual grants or pending attribution by the CoW Team Grant Allocation Committee, and the remainder is still in the DAO treasury and not yet streamed. Tokens remain under DAO control until streamed, and unvested amounts can be cancelled by governance at any time.

Excluded from the 5.0%: the Performance-Based Incentive Tier. Milestone 1 was met on February 2026 revenue and 25,000,000 COW (2.5% of supply) was transferred in May 2026. Those tokens are not subject to vesting and are therefore not counted as locked. The remaining three milestone tranches (up to 7.5% of supply) are unearned, remain in the treasury, and expire if not reached within four years of CIP-83's execution.

Also excluded: the original team allocation approved at TGE (15% of supply). Its four-year grants completed vesting by February 2026, and the unallocated residual of roughly 2.5% of supply is pool capacity rather than locked grants

(b) Typical post-TGE vesting schedule

Standard post-TGE grant schedule for individual grants attributed from the CoW Team Grant Allocation:

  • Total duration: four years
  • Cliff: no cliff
  • Vesting frequency: continuous streaming
  • Start: the grant start date set by the CoW Team Grant Allocation Committee at attribution
  • Mechanism: on-chain vesting positions created through the allocation module attached to the relevant CoW DAO Safe

This is a separate schedule from how CoW DAO funds the allocation. Under CIP-83, the 50M COW replenishment is delivered from the DAO treasury into the CoW Team Grant Allocation as a four-year linear stream with no cliff. The "no cliff" applies to that treasury-to-allocation stream, not to individual grants.

Performance-Based Incentive Tier tranches follow neither schedule. They are funded by one-off transfers into the same Safe when a revenue milestone is met and are not subject to vesting.

09

Disclosure of Token Advisory Billings

Disclose current token-based compensation for external advisors and service providers (e.g., legal, marketing, technical, growth) funded from the on-chain treasury. Do not disclose individual payments to advisors receiving fiat-only compensation. If there are no advisors contracted in tokens then state across each sub-question that no token-based advisory compensation exists.

  • (a) Existence — Whether any such token-based payments or advisory commitments exist (or explicitly state that no token-based compensation for advisory commitments exist).
  • (b) Total token allocation — For all existing token-based advisors, disclose the total token allocation across all advisory services.
  • (c) Payer entity — For each existing token-based advisor, share the payer entity (e.g., Foundation, Labs/DevCo, DAO/treasury).
  • (d) Description of advisory/services — For each existing token-based advisor, provide a brief description of the advisory/services (e.g., "legal and regulatory advisory," "growth and BD support," "security advisory").

(a) Existence

Token allocation commitments are disclosed for market maker relationships managed by CoW Business Limited: Wintermute has a 0.75% of supply commitment under a 1-year loan-and-option structure, and Keyrock has a 0.25% of supply commitment under a 1-year loan-and-option structure. No ongoing token-based advisory billings or commitments exist beyond the initial 0.6% CoW Advisory allocation distributed at TGE on a four-year linear vest to strategic advisors.

(b) Total token allocation

No current token-based advisory compensation exists. Beyond the initial 0.6% CoW Advisory allocation distributed at TGE on a four-year linear vest to strategic advisors, there are no ongoing token-based advisory billings or commitments. Leeward Management Limited and Lemma Solutions are compensated in fiat from the operational budget, not in COW tokens, and CoW DAO does not engage KOLs or influencers under token-based compensation arrangements.

(c) Payer entity

No current token-based advisory compensation exists. Beyond the initial 0.6% CoW Advisory allocation distributed at TGE on a four-year linear vest to strategic advisors, there are no ongoing token-based advisory billings or commitments. External service providers Leeward Management Limited and Lemma Solutions are compensated in fiat from the operational budget, not in COW tokens, and CoW DAO does not engage KOLs or influencers under arrangements involving token-based compensation. Accordingly, there is no payer entity for any existing token-based advisor.

(d) Description of advisory/services

No current token-based advisory compensation exists. Beyond the initial 0.6% CoW Advisory allocation distributed at TGE on a 4-year linear vest to strategic advisors, there are no ongoing token-based advisory billings or commitments; Leeward Management Limited and Lemma Solutions are compensated in fiat from the operational budget, not in COW tokens.

10

KOL Marketing Activities

Disclose ongoing KOL/influencer relationships that partially or fully received tokens for payment. You do not need to disclose KOL/influencers that do not receive tokens for payment. If no KOL engagements exist, state for each sub-question that no KOL engagements exist.

  • (a) Existence & scope — State plainly whether KOLs receive tokens for payment.
  • (b) Usernames & roles — List usernames/handles (with platforms) for KOLs that received token-based compensation and describe the nature of their activities. Legal names are not required.
  • (c) Token allocation & vesting/locks — Provide the aggregate token amount across all such arrangements and summarize vesting, lock, or release terms.

(a) Existence & scope

KOLs and influencers do not receive COW tokens for payment. CoW DAO does not engage KOLs or influencers under arrangements involving token-based compensation, and any creator partnerships do not include COW token payments.

(b) Usernames & roles

No KOL/influencer engagements receiving token-based compensation exist; accordingly, there are no usernames, handles, platforms, or related KOL activities to disclose.

(c) Token allocation & vesting/locks

No KOL/influencer engagements involving token-based compensation exist. Accordingly, there is no aggregate token allocation across such arrangements and no vesting, lock, or release terms to disclose.

11

Labelled Unissued & Operational Token Wallets

For each wallet that holds Unissued Tokens or is essential to operations (e.g., foundation, operations, treasury, investor reserve), disclose:

  • (a) A category label explaining the wallet's primary function.
  • (b) chain the wallet is on.
  • (c) The unique address of the wallet.
  • (d) The mechanism of control (e.g., DAO, multisig).
  • (e) One verification link to a blockchain explorer.

Definition: Unissued Supply = tokens authorized by the contract but not yet issued to any party; where they sit (treasury or mint authority) does not change that they are unissued. For instance: if a token has a total supply cap of 1B, and 400M tokens have been issued to investors, the team, and users (whether vested or unlocked), then those 400M count as issued supply. The remaining 600M are authorized but unissued supply, even if they are already minted into a DAO treasury wallet.

Title

Primary Function

Chain

Address

Control Mechanism

Explorer Link

CoW DAO (Main)

Main DAO safe bound to COW token holder votes on cow.eth Snapshot.

Ethereum

0xcA771eda0c70aA7d053aB1B25004559B918FE662

Safe multisig executing COW token holder Snapshot outcomes

Solver Payouts

Executes solver payouts per CIP-20 and receives collected fees from the settlement contract; operational responsibility is delegated to CoW Business Limited.

Ethereum

0xA03be496e67Ec29bC62F01a428683D7F9c204930

Safe multisig under DAO authority

Solver Voucher

Adds and removes solvers from the settlement contract allow-list per DAO-defined bonding rules and converts collected protocol fees to ETH; operational responsibility is delegated to CoW Core Limited.

Ethereum

0x423cEc87f19F0778f549846e0801ee267a917935

Safe multisig under DAO authority

CoW Treasury (yield-generating)

Yield-generating treasury wallet managed with Karpatkey support to generate yield on idle treasury funds under the CoW Foundation treasury management mandate via Treasury Committee (CIP-62).

Ethereum

0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669

Safe multisig with CoW DAO and Karpatkey

CoW DAO (Gnosis Chain)

CoW DAO main safe on Gnosis Chain.

Gnosis Chain

0xcA771eda0c70aA7d053aB1B25004559B918FE662

Safe multisig under DAO authority

Grants Committee

Grants DAO Committee wallet responsible for funding CoW Grants and operating under CoW Foundation mandate.

Gnosis Chain

0xCA1F000D520c21C47E6c634DD31b92b91A6338bD

5-member committee Safe multisig

Grant Funds

Wallet for the Volume-based Partner Reward Program – COW with DAO clawback.

Gnosis Chain

0xbD96C4Fe53f1d89a8Bdb3522BCEDfB20b5601b69

Joint DAO + Grants Committee multisig

vCOW Vesting Contract

Holds unvested vCOW supply that converts 1:1 to COW upon vesting.

Ethereum

0xD057B63f5E69CF1B929b356b579Cba08D7688048

immutable teamController address able to cancel unvested team positions via stopClaim. No other privileged role exists and the contract is not upgradeable. The claim window closed in 2022 and the four-year linear vest completed in February 2026, so the contract is fully vested and the power is now inert.

vCOW Vesting Contract

Holds unvested vCOW supply that converts 1:1 to COW upon vesting.

Gnosis Chain

0xc20C9C13E853fc64d054b73fF21d3636B2d97eaB

immutable teamController address able to cancel unvested team positions via stopClaim. No other privileged role exists and the contract is not upgradeable. The claim window closed in 2022 and the four-year linear vest completed in February 2026, so the contract is fully vested and the power is now inert.

Operational CoW DAO Safe (CIP-43)

OPEX-dedicated safe, operationalized by the Core Team and Foundation Operator for the bug bounty program, ETH flow funding and smart contracts, owned by CoW Foundation. Part of protocol operations; any COW held in this safe is considered non-issued supply.

Ethereum

0x46861c73480d35AA285f1420Ba80e76766F9885c

3/5 safe with community leaders as non signers that coordinate through governance forum and have a mandate to comply with governance decisions

CoW TWAP Safe

Subsidiary safe to the Treasury Safe to perform TWAP operations

Ethereum, Gnosis Chain

Mainnet : 0x523732d31B4432BcDD4BaaD108f7EBE54AD478b0
GC: 0x14195ACF6839e324Dad4057bF906E045914750d5

Treasury committee (3/6)

Residual Balancer safe

Safe to receive BAL tokens received under a token swap agreement with Balancer Foundation (CIP-69). The assets have since been moved to the main Treasury safe

Ethereum

0x3E2897E71E504B0510Bed7983579280b32ac1CA5

Treasury Safe and CoW DAO Main safe (1/2)

Transactions & Market Structures

12

Market 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. 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).

If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for (b).

Market Maker Name

Token Allocation Committed

Term Duration

Structure Name

Wintermute

0.75% of supply

1 year

Loan and option

Keyrock

0.25% of supply

1 year

Loan and option

13

Exchange 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.

Exchange Name

Token Allocation Committed

Term Duration

Native Token Listing Fees

There are no centralized or decentralized exchange listing agreements or deals involving a COW token allocation, lockup, or native-token listing fee. CEX listings for COW were not contingent on token-based payment from CoW DAO.

None

None

None

14

Liquidity Deals and Market Activity

If a category does not exist or is not applicable, make that clear in plain language.

  • (a) Token repurchases or secondary-market accumulations (if any) — Source of funds, treatment (burn, treasury retention, POL, redistribution, or other), policy controller (who can change the secondary-market accumulation strategy), and whether those tokens may be re-used, re-issued, or permanently removed from circulation.
  • (b) Protocol-owned liquidity (POL) (if any) — Where deployed, total token or dollar size across deployments, policy controller (who can change the POL strategy), and unwind/exit policy.
  • (c) Liquidity deals / purchased TVL (if any) — The total size across all deals, and where the capital participates - no counterparty names needed.
  • (d) Token-secured loans/lines (incl. against unissued tokens) (if any) — Principal, gross position size, collateral, counterparties, and unwind/exit policy.

(a) Token repurchases or secondary-market accumulations (if any)

CoW DAO operates a COW token buyback program authorized under CIP-36 and CIP-48. Buybacks are executed by CoW Business Limited through market transactions and are based on weekly revenue-funded open-market TWAPs. The Core Team has a DAO mandate to buy back the entirety of solver rewards emitted in the week and may buy up to 120% of solver rewards. Tokens bought back are held at the DAO’s disposal for funding future solver rewards initiatives, creating a self-funded flywheel under governance approval. COW token holders control changes to the strategy through the CIP process, including authority over treasury actions, fee routing, solver reward parameters, protocol parameters, treasury actions, fee policies, solver bonding rules, partner agreements, and grants. No burn or permanent-removal treatment is disclosed; the disclosed treatment is treasury/DAO retention for potential reuse in future solver rewards initiatives.

(b) Protocol-owned liquidity (POL) (if any)

CoW DAO holds protocol-owned liquidity (POL) in COW pairs. All POL pools are owned by the CoW Treasury address 0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669.

Deployment chains and venues. POL is deployed across Ethereum Mainnet, Gnosis Chain, Base, Arbitrum and BSC, following a February 2026 consolidation in which liquidity was migrated out of legacy positions, ranges were tightened and allocations were rebalanced across those five chains. Current deployment venues are Uniswap and PancakeSwap. CoW DAO

Aggregate size. As of the 1 August 2026 00:00 UTC period-end snapshot, POL positions total $560,631, comprising $450,585 on Uniswap and $110,046 on PancakeSwap. That is 2.9% of the $19.12M actively managed treasury. A residual Balancer safe and the CoW TWAP Safe are tracked on the treasury dashboard but sit outside the Core Treasury Mandate and are excluded from that figure. Figures are published monthly in the CoW DAO treasury reports on forum.cow.fi and on the treasury dashboard at app.syncrone.fi/public/cow. CoW DAOCoW DAO

Unwind and exit policy. There is no fixed unwind schedule or pre-committed exit date. Adjusting, rebalancing, migrating or exiting any POL position is a Treasury Committee decision under the mandate approved in CIP-62, executed by transaction from the CoW Treasury Safe, which has a 3/5 signing threshold. kpk provides treasury management services under the Foundation's treasury management mandate and in coordination with the Treasury Committee, is a co-signer on that Safe, and does not unilaterally control strategy or allocations. Amending or revoking the mandate itself requires a CIP. Position-level composition can be reviewed at https://dune.com/kpk/cow-token-analysis.

(c) Liquidity deals / purchased TVL (if any)

No TVL-oriented liquidity deal or purchased TVL arrangement exists.

(d) Token-secured loans/lines (incl. against unissued tokens) (if any)

No token-secured loans or lines exist at the DAO level, including against unissued COW. Principal, gross position size, collateral, counterparties, and unwind/exit policy are not applicable.

Resource Disclosures

15

Prior 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.").

Series Name

Investment Instrument

Date Of Sale

Number of tokens sold

Vesting Schedule

Private Sale Investment Round

Onchain virtual token, where participants deposited funds (USDC and ETH) in a smart contract and received vCOW (a non-transmitable asset, vesting over 4 years).  With CIP-5 vCOW become swappable 1:1 to COW and holders could swap between both assets.

Feb 2022

10% of total supply (100,000,000 COW, distributed via vCOW)

4-year linear vest from TGE/deployment; no cliff because vCOW was not transferable.

CoWmunity Investment

Onchain virtual token, where participants deposited funds (USDC and ETH) in a smart contract and received vCOW (a non-transmitable asset, vesting over 4 years).  With CIP-5 vCOW become swappable 1:1 to COW and holders could swap between both assets.

Feb 2022

10% of total supply (100,000,000 COW, via vCOW)

4-year linear vest from TGE/deployment; no public cliff because vCOW was not transferable.

16

Operational Funding, Economic Flows, and Resource Provisioning

Provide a narrative description of the Project's material funding sources, economic flows, and operational provisioning, broken out by entity: Foundation, Lab/DevCo, and DAO. If an entity does not exist, state that explicitly.

  • (a) Entity existence — Explicitly state whether each of Foundation, Lab/DevCo, and DAO exists.
  • (b) Material sources of funding or economic inflows — For each existing entity, describe its primary sources of operational funding or economic inflows, if any (e.g., service fees, grants, donations, treasury reserves, token reserves, staking rewards, validator/sequencer income, partnership payments, retained revenue, or other protocol-related receipts).
  • (c) Operational use of resources — For each existing entity, briefly describe how those resources are generally used (e.g., development, operations, security, ecosystem support, grants, liquidity support).
  • (d) Onchain Resource Usage — For each existing entity, provide links to public dashboards and token holder relations reports that help explain on-chain financial activity, treasury activity, fee flows, rewards, or other protocol-controlled resources. Make certain to explain what each link is for.

(a) Entity existence

Foundation exists: CoW Foundation exists as a Cayman Islands Company Foundation. Lab/DevCo exists: CoW Core Limited exists and conducts development. DAO exists: CoW DAO exists as an unincorporated, governance arrangement governed by COW token holders via Snapshot at cow.eth.

(b) Material sources of funding or economic inflows

CoW DAO exists as an unincorporated governance arrangement governed by COW token holders via Snapshot at cow.eth. CoW governance directs specified DAO-controlled resources and approves mandates concerning treasury assets, protocol-related fees and other resources within its governance scope. Those assets and flows are held, received or administered through the relevant Safes, contracts or legal entities. This should not be read as stating that CoW DAO legally owns every asset or economic flow generated anywhere in the broader CoW ecosystem. DAO-level economic sources include the 44.4% initial CoW DAO Treasury allocation for long-term governance, ecosystem growth, grants, partnerships, solver rewards, and retained protocol resources; historical token-sale funding consisting of a February 2022 private sale covering 10% of total supply (100,000,000 COW) and a February 2022 CoWmunity Investment that sold 10% of total supply, for total prior token sales of 20% of total supply; protocol fees collected at the settlement contract level, including price-improvement fees, volume-based fees, reduced fees on correlated pairs, and service fees from solvers and partners; and yield generated by Karpatkey on idle treasury funds in the CoW Treasury safe

CoW Foundation exists as a Cayman Islands Company Foundation. Its economic inflows include profit generated from its related entities, including revenue from CoW Business Limited partner fee agreements and commercial integrations that flows back to CoW Foundation as profit, and treasury yield on assets under management. Under CIP-64, the four-entity legal structure has a separate running-cost budget estimated at USD 130,000 for the first ten months and USD 180,000 per year thereafter for the entire structure, subject to the applicable Director discretion and reallocation mechanisms. Separately, under CIP-79, CoW Foundation administers the USD 12.6 million 2026 Service Agreement No. 5 budget, allocates it quarterly among the four legal entities in line with their workstreams and mandates.

CoW Core Limited, functioning as the Lab/DevCo entity, exists as a BVI Company Limited by Guarantee. CoW Core's corporate running costs form part of the structure-wide CIP-64 budget. Separately, under CIP-79, USD 5.8 million of the 2026 Service Agreement No. 5 budget is allocated to workstreams contracted through CoW Core. CoW Core may also receive service fees for analytics or solver-related services where applicable.

CoW Hosting Limited exists as a BVI Company Limited by Guarantee. Its corporate running costs form part of the structure-wide CIP-64 budget. Separately, under CIP-79, USD 1.5 million of the 2026 Service Agreement No. 5 budget is allocated to workstreams contracted through CoW Hosting.

CoW Business Limited exists as a BVI Limited Liability Company / company limited by shares. Its corporate running costs form part of the structure-wide CIP-64 budget. Separately, under CIP-79, USD 3.0 million of the 2026 Service Agreement No. 5 budget is allocated to workstreams contracted through CoW Business. CoW Business also generates revenue from partner fee agreements under CIP-61, as amended by CIP-75, and commercial integrations; that revenue flows back to CoW Foundation as profit.

(c) Operational use of resources

CoW DAO exists as an unincorporated, governance arrangement governed by COW token holders via Snapshot at cow.eth; DAO funds support solver rewards, the CoW Grants program, security audits, partner reward programs, and retained treasury for long-term operations, with solver rewards being the largest recurring outflow.

Foundation funds support ecosystem promotion, treasury management, grants administration, legal protection of the protocol and contributors through the Defense Reserve, tooling and coordination across entities, and community management.

CoW Core funds support solver operations management, backend infrastructure including the orderbook, autopilot, and Reference Driver, solver R&D, and analytics.

CoW Hosting funds support UI hosting and maintenance, including CoW Swap and CoW Widget, domain ownership, user support, and token list management.

CoW Business funds support solver reward calculation and distribution operations, COW buyback execution, partner relationship management, CEX listings, market maker relationships, and fee-agreement negotiation.

(d) Onchain Resource Usage

CoW DAO exists as an unincorporated, governance arrangement governed by COW token holders via Snapshot at cow.eth. The main DAO-facing resources for on-chain resource usage are: https://dune.com/cowprotocol, which shows protocol volume, settlement counts, fees collected, and solver performance; https://forum.cow.fi, which contains all CIPs, financial reports, and treasury reports; https://snapshot.org/#/cow.eth, which shows historical votes and proposals; and https://docs.cow.fi/governance/multisigs, which lists the operational multisigs. These resources explain protocol fees collected at the settlement contract level and DAO-funded uses including solver rewards, the CoW Grants program, security audits, partner reward programs, and retained treasury for long-term operations.

CoW Foundation exists as a Cayman Islands Company Foundation. Foundation-related treasury activity can be reviewed through https://forum.cow.fi for financial and treasury reports, https://app.syncrone.fi/public/cow for Karpatkey’s CoW DAO treasury dashboard, and https://dune.com/kpk/cow-token-analysis for CoW Treasury Committee POL positions. Karpatkey generates yield on idle treasury funds in the CoW Treasury safe, and POL pools are owned by the CoW Treasury address 0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669. Foundation funds support ecosystem promotion, treasury management, grants administration, legal protection of the protocol and contributors through the CIP-50 Defense Reserve, tooling and coordination across entities, and community management.

The Lab/DevCo and operational entities disclosed are CoW Core Limited, CoW Hosting Limited, and CoW Business Limited. The entities' corporate running costs form part of the structure-wide CIP-64 running-cost budget. Separately, under CIP-79, CoW Foundation allocates the 2026 Service Agreement No. 5 budget among the legal entities. Their operational activity is explained through the shared public resources above, especially https://forum.cow.fi for CIPs, financial reports, and treasury reports, https://docs.cow.fi/governance/multisigs for operational multisigs, and https://dune.com/cowprotocol for protocol volume, fees, and solver performance. For 2026, the CIP-79 workstream allocations are USD 5.8 million to CoW Core, USD 1.5 million to CoW Hosting, USD 3.0 million to CoW Business and USD 2.3 million to Foundation workstreams. These workstream allocations and are separate from the legal structure's CIP-64 corporate running-cost budget.

17

Previous 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 — Link(s) to post-mortem/advisory/PR.

(a) Date & component affected

No prior incidents directly affecting the COW token, token supply, tokenholder balances, the COW token contract, minting controls, burn mechanics, or custody of token supply have occurred as of 2026-09-04.

(b) Exploit vector summary

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04, so there is no exploit vector to summarise. No incident has involved unauthorised minting, unauthorised burning, alteration of tokenholder balances, compromise of the COW token contract, or compromise of custody of token supply

(c) Quantified impact

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04. There has been no loss of COW tokens, no loss of tokenholder balances, and no unauthorised change to total supply. Quantified impact is zero tokens and zero dollars in respect of the native token.

(d) Remediation/response taken

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04, so no remediation or response in respect of the native token has been required or undertaken.

(e) Current status

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04, so there is no incident status to report. No incident affecting the COW token, its supply, its contract, or tokenholder balances is open, under investigation, or unresolved.

(f) References

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04, so no post-mortems, advisories, or pull requests relating to a native-token incident exist.

18

[Optional] Offchain Foundation Or DevCo Income Statement

Provide a single income statement, expense summary, or comparable operating statement for the primary Foundation or Developer Company. A consolidated or entity-level presentation is acceptable. Balance Sheet and Statement of Cash Flows may be included but are not required. This item is intended to provide transparency into offchain operating resources and expenditures only.

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. CoW Protocol is solely responsible for the content, accuracy, and legality of its disclosures.

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