4.6 Communication and disclosure plan

Issuers should include in the recovery plan a communication and disclosure plan outlining how the issuer intends to inform token holders and other stakeholders, including the public, about the implementation of the recovery options. The communication and disclosure plan should also include effective proposals to manage any potentially negative market reaction.

The communication and disclosure plan should clarify how the issuer intends to communicate:

• a) internally, in particular to staff, works councils and other staff representatives, if any; and
• b) externally, in particular to token holders, shareholders and other investors, competent authorities, financial markets and financial market infrastructures, other counterparties and the general public, as appropriate.

In the communication and disclosure plan issuers should also include how they will ensure the preservation of its token-related services, the foreseen timelines for recovering its operations and for the fulfilment of its obligations. The communication and disclosure plan should also cater for scenarios in which it is unlikely that the issuer will recover operations or will fulfil its obligations, thus leading to the activation of the issuer’s redemption plan.

The communication and disclosure plan should clarify the (mix of) communication channels and the strategies that the issuer intends to use during the recovery phase. In doing so, issuers should consider that:

• a) different stakeholders may have different communication needs;
• b) internal and external stakeholders may need to be informed at different stages; and
• c) different recovery options may warrant specific communication strategies.