OKX Middle East OKSOL Whitepaper

VIRTUAL ASSET WHITEPAPER

OKSOL

OKX Liquid Staked SOL

Issuer:

OKX Middle East Fintech FZE

VARA Licence Reference VL/23/12/003

Prepared under Part III and Schedule 1 of the VA Issuance Rulebook

Version 1.0

Date: 6 August 2026

REGULATORY DISCLAIMER

VARA has not taken any steps to verify the information set out in this whitepaper, including its accuracy and completeness, and has no responsibility for any loss arising from reliance on it. The liability for the content of this whitepaper lies solely with the Issuer, OKX Middle East Fintech FZE.

VARA has not made any representation and does not provide any warranties regarding any Issuer or Virtual Asset including, but not limited to, their fitness for purpose, suitability or regulatory status in any jurisdiction other than the Emirate of Dubai, UAE.

OKSOL is a Category 2 Virtual Asset. No Virtual Asset issued under Category 2 shall be deemed to have been approved by VARA, and the issuance of this whitepaper shall not be construed as an endorsement by VARA of the Issuer or of OKSOL.

A. Information about the Issuer

A.i  Name, legal structure, registered address and head office

A.ii  Date of incorporation or registration

The Issuer was incorporated on 15 September 2022.

A.iii  Parent company

The Issuer's parent company is OKX Global Holding Company Limited, incorporated in the British Virgin Islands.

A.iv  Identities, business addresses and functions of owners, management and members

The Issuer is part of the OKX group. Its owners, senior management and members, together with their business addresses (each at the Issuer's registered office in Dubai, UAE, unless otherwise notified) and their functions, are as follows:

A.v  Convictions and investigations

To the best of the Issuer's knowledge, and following due diligence enquiries, no individual involved in the issuance, including the Issuer's owners, management and members, has been convicted of any offence of dishonesty, fraud, financial crime, or any offence under laws relating to companies, banking, insolvency, money laundering or insider dealing. To the extent permissible under applicable laws, no such individual is subject to ongoing inquiries or investigations in respect of such offences.

A.vi  Business activities, regulatory authorisations and Licences of the Issuer and its group

The Issuer is a Virtual Asset Service Provider licensed by VARA under Licence reference VL/23/12/003, issued on 17 September 2024 (CMA Registration Number CMA-VASP-1001010-0008). The Issuer is authorised to provide the following Virtual Asset Services in and from the Emirate of Dubai (excluding the DIFC):

• VA Exchange Services, including VA Derivatives Trading;

• VA Broker-Dealer Services;

• VA Management and Investment Services; and

• VA Lending and Borrowing Services.

On 8 June 2026, VARA granted the Issuer a Limited Licence Approval supplementing Licence VL/23/12/003, permitting the Issuer to issue and distribute OKSOL as a liquid staking token. OKSOL is a Category 2 VA Issuance.

The Issuer forms part of the OKX group, a global group of companies engaged in the provision of Virtual Asset and related technology services across a number of jurisdictions, certain members of which hold authorisations from the relevant regulators in those jurisdictions.

A.vii  Financial condition over the past three years

The Issuer maintains a sound financial condition and holds capital and liquid assets in accordance with the prudential requirements applicable to it under the VARA Company Rulebook. The Issuer prepares financial statements and submits periodic financial and regulatory reporting to VARA. The Issuer's financial condition has remained stable, and the Issuer has at all times maintained compliance with the applicable capital and prudential requirements.

A.viii  Assessment of development, performance and position

The Issuer commenced its licensed Virtual Asset activities in Dubai following the grant of its VASP Licence and has since developed its regulated business in a controlled and measured manner consistent with the conditions of its Licence. The development, performance and position of the Issuer's business have been stable over the relevant period, and there have been no material adverse changes to its financial position. This assessment is consistent with the size and complexity of the Issuer's business.

A.ix  Governance arrangements

The Issuer maintains a governance framework consistent with the VARA Compulsory Rulebooks. The framework comprises a board of directors with oversight of the Issuer's strategy, risk and compliance, supported by management and control functions including the General Manager, the Compliance Officer and Money Laundering Reporting Officer, the Finance Officer, the Information Technology Officer, the Data Protection Officer and the Risk Officer. The Issuer operates a three lines of defence model and maintains documented policies covering, among other matters, conduct of business, risk management, anti-money laundering and counter-terrorist financing, technology and information security, outsourcing, conflicts of interest, complaints handling, business continuity and wind down. These arrangements are designed to ensure effective oversight, accountability and risk management across the Issuer's regulated activities.

A.x  Other Virtual Assets issued or other Virtual Asset Activities undertaken

In addition to OKSOL, the Issuer issues BETH, which is also a liquid staking token and a Category 2 VA Issuance and is the subject of a separate whitepaper. The Issuer also undertakes the Virtual Asset Activities described in paragraph A.vi above.

A.xi  Connection between the Issuer and the controller of the DLT

OKSOL is not issued on a public distributed ledger; it is an on-platform record maintained by the Issuer. The underlying SOL committed by clients is staked by the Issuer on the Solana network, a public, permissionless network that is not run, managed or controlled by the Issuer or by any Entity closely connected to the Issuer. There is no connection between the Issuer and any Entity or organisation that has control of the Solana ledger. The Issuer operates its own validators through which the underlying SOL is staked; participating as a validator does not give the Issuer any control over the Solana ledger itself.

A.xii  Entities involved in the issuance and operation

The following Entities are involved in the issuance and operation of the Virtual Asset:

B. Information about the Virtual Asset

B.i  Name, abbreviation or ticker

B.ii  Characteristics, features and uses

OKSOL is a liquid staking token issued by the Issuer that represents SOL staked through the Issuer's staking service. OKSOL is recorded as a balance within the Issuer's platform; it is not an on-chain token. When a client commits SOL for staking through the Issuer's platform, the Issuer credits OKSOL to the client's account on the platform. The number of OKSOL in issue is equal at all times to the number of SOL committed by clients for the staking service. The characteristics, features and uses of OKSOL are:

• it represents staked SOL on a one-to-one (1:1) basis;

• it entitles the holder to receive native Solana staking rewards, together with any priority fees and maximal extractable value rewards captured by the validators to which the underlying SOL is delegated, net of the Issuer's service fee;

• it is redeemable for the underlying SOL on a 1:1 basis through the Issuer's redemption process, as described in Section C;

• it may be held, transferred to other clients of the Issuer, and traded on the Issuer's platform; and

• it may be used as collateral for lending and margin products offered by the Issuer on the same platform.

OKSOL exists only as a record within the Issuer's platform and is available only on that platform. It is not represented on any public distributed ledger, cannot be withdrawn to an external or self-custodied wallet, and cannot be transferred off the Issuer's platform.

B.iii  Plans, milestones and resources

OKSOL is an established liquid staking token offered by the OKX group, and is offered by the Issuer in Dubai under the Limited Licence Approval referred to in paragraph A.vi. The Issuer has allocated the operational, technology, compliance and risk resources necessary to operate the staking service, the issuance and redemption of OKSOL, and the related reporting to VARA.

B.iv  Target market and restrictions

OKSOL is made available, on the Issuer's platform, to Retail Investors, Qualified Investors and Institutional Investors as defined in the VARA Compulsory Rulebooks, who have completed the Issuer's onboarding requirements and accepted the Issuer's staking terms and Terms of Service. OKSOL is not available to sanctioned persons, to persons in jurisdictions where the Issuer does not offer the service, or to any person not eligible to hold or transact in Virtual Assets under applicable law.

B.v  Trading platform, access and costs

Admission to trading of OKSOL is sought only on the OKX platform operated by the Issuer. Clients access the platform through the Issuer's web interface and mobile application after completing onboarding. The costs involved are the trading and related fees set out in the Issuer's published fee schedule. OKSOL is not admitted to trading on any other platform.

B.vi  Technical requirements to own or hold the Virtual Asset

OKSOL is held as a balance in the client's account within the Issuer's platform. Holding OKSOL requires an onboarded account with the Issuer. Because OKSOL is an on-platform record rather than an on-chain token, it is not compatible with any external or self-custodied VA Wallet and cannot be held outside the Issuer's platform.

B.vii  Issuance structure

B.viii  Planned use of proceeds or consideration

OKSOL is not issued for monetary proceeds. The consideration received by the Issuer is the SOL committed by clients for staking, which is staked through the validators described in Section A.xii in order to generate staking rewards. Client-committed SOL is used only for the staking service and is not otherwise deployed by the Issuer.

C. Information about the rights and obligations attached to the Virtual Asset

C.i  Characteristics and functionality, and any changes

OKSOL entitles the holder to the economic benefits of the staked SOL that it represents, namely the right to receive staking rewards net of fees and the right to redeem for the underlying SOL on a 1:1 basis. The Issuer has no current plans to change the functionality of OKSOL. Any material change to the functionality of OKSOL would be notified to clients and reflected in an updated whitepaper.

C.ii  Rights and obligations of the owner, and how they are exercised

OKSOL represents a contractual claim against the Issuer. The holder has the right to:

• receive Solana staking rewards and other rewards attributable to the staked SOL, net of the Issuer's service fee; and

• redeem OKSOL for the underlying SOL on a 1:1 basis.

These rights are exercised through the Issuer's platform in accordance with the Issuer's staking terms and Terms of Service. OKSOL does not confer any ownership, governance or voting rights in the Issuer or any group entity, nor any governance or voting rights over the Solana protocol.

C.iii  Whether rights differ by DLT or platform

OKSOL is recorded and used only on the Issuer’s platform and is not represented on any distributed ledger. Accordingly, the rights attached to OKSOL do not differ by distributed ledger or platform.

C.iv  Conditions under which rights and obligations may be modified

The rights and obligations attached to OKSOL are governed by the Issuer's staking terms and Terms of Service, which may be amended in accordance with their terms. Material amendments will be notified to holders in accordance with the Conduct of Business requirements of the VARA Compulsory Rulebooks, and holders may redeem their OKSOL before a material adverse change takes effect.

C.v  Subsequent issuances with a dilutive effect, and units retained by the Issuer

Each unit of OKSOL is backed by one unit of client-committed SOL. Subsequent issuances of OKSOL are made only against further SOL committed by clients and do not have a dilutive effect on existing holders. To the extent the Issuer or a member of its group holds OKSOL, it is created under the same one-to-one (1:1) staking mechanism that applies to all clients; the Issuer does not retain any OKSOL by way of pre-mine, reserved supply or special allocation.

C.vi  How and where the Virtual Asset can be purchased or sold after issuance

After issuance, OKSOL can be purchased or sold, or redeemed for SOL, only on the Issuer's platform. It cannot be purchased, sold or transferred on any other platform or off the Issuer's platform.

C.vii  Restrictions on transferability

OKSOL may be transferred only between onboarded clients of the Issuer, as a record within the Issuer’s platform, subject to the Issuer’s operational rules, including recipient KYC status, transfer limits and sanctions screening, and applicable law. Because OKSOL is an on-platform record rather than an on-chain token, it cannot be transferred to an external wallet or off the Issuer’s platform. A permitted transfer takes effect as an update to balances within the Issuer’s platform; no on-chain transaction is involved.

C.viii  Protection schemes

There is no protection scheme protecting the value of OKSOL or any investment in OKSOL. No government or industry compensation or deposit insurance scheme applies to OKSOL or to the underlying staked SOL.

C.ix  Nature and enforceability of rights, including redemption and claims against the Issuer

Each unit of OKSOL represents an enforceable contractual right against the Issuer to redeem for one unit of the underlying SOL through the Issuer's redemption process, and to receive staking rewards net of fees. The right of redemption subsists for so long as OKSOL is held and the staking terms remain in effect, subject to the unbonding mechanics described in paragraph C.xiv and to any suspension of redemption permitted under the staking terms (for example, in circumstances of force majeure, technical incident, or as required by applicable law or regulatory direction).

Validator performance on the Solana network affects staking rewards. Validators with poor uptime receive reduced rewards, and delegated stake may be redirected away from underperforming validators over time. As at the date of this whitepaper, Solana does not implement a protocol level slashing mechanism that destroys staked SOL for validator misbehaviour or downtime, unlike certain other proof of stake networks. The Issuer will update this disclosure if a slashing mechanism is activated on the Solana network in the future.

C.x Nature and enforceability of rights, including redemption and claims against the Issuer in the event of insolvency

In the event that the Issuer becomes insolvent or subject to any analogous proceeding, holders of OKSOL will have a claim against the Issuer in respect of their contractual right to redeem OKSOL for the underlying SOL. OKSOL does not constitute a deposit, and holders have no priority, security interest, or proprietary claim over the SOL held by the Issuer or its appointed staking infrastructure providers. Recovery in an insolvency, liquidation, or similar recovery or resolution process will depend on the assets available for distribution and the ranking of OKSOL holders' claims under the applicable insolvency law of the jurisdiction governing the Issuer, and may be partial or nil. No scheme of arrangement, recovery plan, or resolution mechanism specific to OKSOL holders currently exists."

C.xi Allocation of rights among owners

All OKSOL holders are subject to the same terms and conditions and are allocated identical rights, including the right to redeem OKSOL for the underlying SOL on a 1:1 basis and to receive staking rewards net of fees, as described in paragraph C.ix. No class or category of OKSOL holder is afforded preferential, subordinated, or otherwise differentiated rights. This uniform treatment reflects the Issuer's approach of applying a single, non discriminatory set of terms to all OKSOL holders regardless of holding size, date of acquisition, or channel of acquisition.

C.xii  Liquidity arrangements

Liquidity in OKSOL is provided through redemption for the underlying SOL on a 1:1 basis, and through trading on the Issuer's platform. The Entity responsible for these arrangements is the Issuer, OKX Middle East Fintech FZE.

C.xiii  Complaints contact and complaints-handling and dispute resolution procedures

Customers are not subject to any fees or charges for the submission or handling of complaints. Complaints in connection with OKSOL may be submitted to the Issuer through any of the following channels: the online “Contact Us” form at the foot of the OKX website; by email to support.uae@okx.com (generally responded to within one business day); by submitting a ticket through the contact page or the in-app support tool after logging in; or through LiveChat with a live agent via the website help centre. Where a complaint exceeds the scope of the Issuer's Customer Service Representatives or involves a third party, it is escalated to the relevant vendor management team and, if necessary, to the Issuer's Compliance team for resolution. The Issuer's Formal Complaint Handling Process is published at https://www.okx.com/help/complaints-handling-process.

C.xiv  Rights of redemption and how the Virtual Asset is redeemed

C.xv  Material legal or regulatory considerations

Holders should be aware of the following material legal and regulatory considerations applicable to owning, storing, transferring or using OKSOL:

• OKSOL is offered under a Category 2 VA Issuance and a Limited Licence Approval; the regulatory treatment of the Virtual Asset may change and the permissions granted to the Issuer may be modified or terminated by VARA;

• OKSOL may be held and transferred only on the Issuer's platform; and

• holders are responsible for compliance with the laws applicable to them, including any tax obligations, in their jurisdiction of residence.

C.xvi  Applicable law and competent court

The law applicable to OKSOL is the law of the Emirate of Dubai and the applicable federal laws of the United Arab Emirates, and the competent court is the Dubai Courts.

D. Information about underlying technology

D.i  Technology, DLT, protocols and technical standards

OKSOL is not issued on a distributed ledger and is not an on-chain token; it is recorded and maintained as a balance within the Issuer’s platform systems. The underlying asset that OKSOL represents is SOL, which the Issuer stakes on the Solana network. Solana is a public, permissionless Layer 1 distributed ledger that operates a delegated proof-of-stake consensus model supported by a Proof of History sequencing mechanism. The holding, recording and transfer of OKSOL are effected within the Issuer’s platform; the staking of the underlying SOL uses standard Solana network interfaces and protocols.

D.ii  Consensus mechanism

The underlying SOL is staked on Solana, which operates a delegated proof-of-stake consensus mechanism. Validators are selected to produce blocks in proportion to the quantity of SOL staked to them, including stake delegated to them by other holders. Block production is sequenced using the Proof of History mechanism. OKSOL itself is an on-platform record and is not issued on any distributed ledger; accordingly no variance in the rights of owners arises from differences between consensus mechanisms on different DLTs.

D.iii  Incentive mechanisms and applicable fees

The staking of the underlying SOL on the Solana network is secured by the delegated proof-of-stake (DPoS) consensus mechanism, under which validators are rewarded for participating in consensus and may incur penalties for misbehaviour or downtime. OKSOL holders receive the native Solana staking rewards, together with any priority fees and maximal extractable value rewards captured by the validators to which the underlying SOL is delegated, net of the Issuer’s service fee, which is set out in the Issuer’s published fee schedule. Network transaction fees on the Solana network apply to the staking of the underlying SOL in the ordinary way; transfers of OKSOL between clients occur within the Issuer’s platform and do not incur Solana network fees.

D.iv  DLT operated by or on behalf of the Issuer, and audits

OKSOL is not issued, transferred or stored using a distributed ledger; it is an on-platform record maintained by the Issuer. The Solana ledger, on which the underlying SOL is staked, is not operated by the Issuer or by any third party on the Issuer’s behalf; it is a public, permissionless network. The Issuer operates its own validator infrastructure that participates in the Solana network on the same basis as other validators. The Issuer’s validator infrastructure has not been the subject of an independent audit. The Issuer monitors validator performance on an ongoing basis through its own internal validator performance dashboard.

D.v  Environmental and climate-related impact

Solana operates on a proof-of-stake consensus mechanism, which is substantially less energy-intensive than proof-of-work networks. Per-transaction energy consumption is generally estimated to be a very small fraction of that of a proof-of-work transaction, although published estimates vary.

E. Information about the Licensed Distributor

All placement and distribution of OKSOL is carried out by the Issuer in its capacity as Licensed Distributor. The particulars of the Licensed Distributor are:

F. Information about any initial offer to the public of the Virtual Asset

OKSOL is not the subject of an initial offer to the public. OKSOL is issued continuously, on demand, in exchange for SOL committed by clients for staking, and is not offered through a public offering, token sale or comparable distribution event.