GIP 128 progress report -- Q1 2026

[Kenk]

Overview

Q1 2026 built on the growth seen in Q4 across the product ecosystem. Gnosis App, Pay, and Business all shipped significant infrastructure upgrades, with Pay launching v2 to unlock a major distribution opportunity. We also introduced the Ethereum Economic Zone (EEZ), co-developed with ZisK and co-funded by the Ethereum Foundation. The quarter also saw key hires made across all teams, strengthening capacity ahead of Q2.

Gnosis App

Strategy & Direction

After gathering insight Gnosis App is shifting from a neobank-first approach with Circles as a secondary feature to a Circles-first approach with a neobank under the hood.

This is a deliberate move. The crypto neobank space is crowded, and European fintech is already mature (e.g. Revolut, Monzo, N26). Competing head-on there is undifferentiated. Leading with Circles allows us to stand out in a way that better aligns with the team’s strengths.

This approach allows us to scale globally faster, avoiding the need to localize deeply across languages and cultural contexts from day one. In Q2, both product and marketing efforts reflect this shift.

Product Highlights

• New Circles-Focused Onboarding

  • We introduced a redesigned onboarding flow built around Circles, making it easier for new users to understand and engage with the ecosystem from day one. This replaces the more generalist onboarding and reflects our sharpened product direction.

• Circles Referral Invites

  • We improved the Circles invite experience by introducing referral invites so users can more easily generate and share referral links. This was put to use at events including EthCC, where it proved effective as a lightweight growth and activation tool in real-world settings.

• Expanded Marketplace Offers

  • New offers have been added to the Marketplace, including physical offers for the first time, broadening the real-world utility of Circles for our users.

• Trust Score

  • We introduced the Trust Score in-app, giving users visibility into their standing within the Circles trust graph. This brings a meaningful piece of the Circles protocol to the surface in a way that is accessible to mainstream users.

• Virtual Card Designs

  • Virtual cards are now displayed in the app with a refreshed Gnosis App design, improving the overall feel and coherence of the payments experience.

• Introducing the G NFT

  • We launched the G NFT, awarded to users who contribute to the Gnosis App and wider ecosystem.

  • Holders receive extra cashback and additional perks within the app, creating a new layer of community recognition and incentivisation aligned with our Circles-first direction.

GTM Highlights

• Implemented new user research processes across the pipeline including structured interviews (125 conducted), an onboarding call system for ongoing product insights, in-person university roadshows, quantitative surveys, and identification of 150+ European power users as potential multipliers.

• Launched TikTok & Instagram handles and hiring for a dedicated Gnosis App social media lead.

• Implemented Meta ads funnel to test narratives and CAC for paid ads.

• Launched the G-NFT (bonus cashback) campaign to incentivize backing & referrals.

• Onboarded marketing agency to kickstart high volume UGC creator videos on Tiktok to increase top of the funnel and other areas.

People

Q1 brought team changes across the team. Engineering gained a new Tech Lead and front-end developer, with the previous Tech Lead shifting to a Research Lead role focused on bleeding-edge web3 topics for Gnosis App. Design saw two members leave and added one. The team is recruiting a part-time social media creative for short-form content on TikTok and Instagram.

What’s next

Next up for Gnosis App: scaling marketing across Europe with UGC, referral campaigns, an ambassador programme, and new distribution channels – all increasingly powered by AI.

Metrics

• Daily Active users (DAU)

  • ~1000

• Active card users

  • ~500

• Backers (users who have deposited 100$ to provide liquidity to their Circles)

  • ~680

Gnosis Pay

Strategy & Platform Direction

Gnosis Pay is evolving from a consumer-first MVP into a scalable B2B2C payments platform. In Q1, the team rebuilt the platform ground-up for its first B2B partner improving infrastructure reliability, payment reversals, and privacy. Additionally they added a new end-user authentication layer for crypto-native partners and reworked the smart contract layer to support a broader partner ecosystem.

V2 is now in integration and internal testing, with the partner expected to begin a phased rollout in Q2.

Product Highlights

• Gnosis Ramps Beta:

  • On the 18th March Gnosis Ramps was introduced in the US, UK, EU, Argentina and Brazil with a full launch in May. Ramps is an API integration for on/off ramping in any jurisdiction.

• Gnosis Pay v2 launch:

  • Gnosis Pay V2’s clearing and settlement flow is progressing, nearing first transaction, alongside BIN tokenisation, V2 webhook release, a support dashboard, transaction disputes handling, and plans to replicate the process with Rain for USA and Canada.

• Documentation update:

  • V2 changes reflected in documentation.

• Apple Pay & Google Pay:

  • Went live in early April, after heavy development in Q1.

• Geographic expansion:

  • Gnosis Pay received operating capabilities in the following jurisdictions - Brazil, Mexico, Argentina, Colombia, Bolivia, Paraguay, Uruguay, UAE, Thailand, Philippines, South Africa, Kenya, Nigeria, Ghana, Malaysia, Japan, Australia, Bangladesh, Tanzania, Rwanda, and Uganda.

Team shifts

A Senior Web3 Developer joined the team to focus on smart contract development and infrastructure.

Metrics

User overview

• Total sign-ups: Q1 2026: 179,754 (Q4 2025: 147,469)

• Cards activated: Q1 2026: 94,418 (Q4 2025: 71,322)

• Active users in Q1 2026: 11,663 (-20.7% QoQ) (Q4 2025: 14,695, +17.3% QoQ)

Transaction Activity

• Payment transactions in Q1 2026: 554,114 (-11.3% QoQ) (Q4 2025: 621,480, +6.7% QoQ)

Transaction Volume

• Total processed in Q1 2026: $27M (Q4 2025: $32.5M)

• Currency mix dynamics: Q1 2026: EUR 79%, GBP 4%, USD 17%

Gnosis Business

Strategy & Platform Direction

A big focus in Q1 was deployment of an onboarding flow to allow users to make a payment in under 3mins, regardless of whether they are using mobile or desktop.

After a heavy focus on development in Q1, the release of Gnosis Business Lite will happen in Q2, with a heavy focus on the freelancers segment.

Product Highlights

• Gnosis Business Lite, a lightweight, mobile-first tier aimed at freelancers and solopreneurs, who need to send and receive payments, off-ramp to fiat, and manage funds without the complexity of a full treasury product.

• Gnosis Unified Transaction Ledger (GUTL) architected: an AI-queryable financial history layer. A structured, single-feed transaction ledger underpinning Lite, designed so that every financial event is tagged, dated, exportable and natively queryable by AI agents and agentic workflows.

Gnosis Ramp

The Gnosis Business team launched Gnosis Ramp in beta in March 2026, a stablecoin fiat on/off-ramp orchestration layer, soon to be marketed under the Gnosis Pay stack.

The core problem it solves: fintechs with a stablecoin strategy that need global coverage end up stitching together a different ramp provider for every corridor. Europe via one partner, India via another, Brazil via a third. Every provider has its own API, compliance requirements, and failure modes. The maintenance burden compounds with every new market, and the coverage gaps are felt directly by end users.

Gnosis Ramp replaces that with a single integration across a global network of ramp partners.

Key capabilities

• One API, global coverage. Access multiple ramp providers and currencies through one integration, built and maintained once. Launch globally from day one; deepen corridor coverage over time.

• KYC sharing. Sumsub integration enables KYC and KYB verification once, with identity and business data shared across ramp partners. One verification, multiple providers.

• Full control. Gnosis Ramp is an orchestration partner, not a black box. Businesses retain control over commercial terms, compliance processes, and user data privacy.

• Built-in resilience. A single ramp provider is a single failure point. Gnosis Ramp adds multi-provider redundancy, with seamless failover if a provider goes down or loses liquidity.

Beta coverage

• FX markets: Europe, United States, Argentina, Brazil

• Ramp providers integrated:

  • Avenia: Fiat-to-crypto onramp service focused on seamless and quick settlements. It provides infrastructure for accessible crypto transactions worldwide.

  • Bridge: Stablecoin platform that handles receiving, storing, converting, issuing, and spending stablecoins. It supports developers in enabling global money transfers through a unified API.

  • Latamex: Crypto-to-fiat gateway tailored for Latin America. It allows users to buy and sell cryptocurrencies using local currencies via simple integrations for exchanges and wallets

  • Noah: Supplies payment infrastructure for fiat, bitcoin, and stablecoin rails via APIs and hosted checkouts. It facilitates compliant settlements and global payouts, including virtual bank accounts.

Full public launch scheduled for end-May / June 2026:

• FX markets: India, Singapore, Vietnam, Malaysia, UAE, Mexico and more

For more details on this launch, refer to https://www.gnosis.io/blog/gnosis-ramp-beta

Metrics

Total volume accounted for (trailing past 12 months): $1B+
Cumulative GTV (trailing past 12 months): $174M

Q1 2026

• Jan: $14.1M

• Feb: $9.1M

• Mar: $9.6M

Circles Protocol

**
End of Q4 2025: approx. 11,000 registered accounts | approx. 3,700 active minters | approx. 550 backers
End of Q1 2026: approx. 11,269 registered humans | approx. 2,903 active minters | approx. 665 backers | approx. 291,417 trust links

**
End of Q4 2025:** ~11,000 registered humans | ~3,300 active minters (excluding blacklisted accounts)| ~550 backers**
End of Q1 2026:** ~15,000 registered humans | ~4,100 active minters (excluding blacklisted accounts) | ~665 backers |
*Edited 23 April 2026 to correct Q1 registered/minter figures. Original values retained via strikethrough for transparency.

—

Growth Summary

Registered accounts grew >30% in Q1 and backers grew 20.9%, from ~550 to 665, reflecting steady trust network formation. The number of non-blacklisted active minters grew by ~25%. Additionally, it is worth noting that Circles Protocol started to filter blacklisted accounts from metrics in Q1 2026 which are reflected in this report and will be used moving forwards.

One open question: how to frame the relationship between Circles and a broader currency union model. Alignment is in progress.

Product Highlights

Marketplace

Physical goods fulfilment became operational in Q1. Order infrastructure is stable: a fulfilment postmortem was completed and resolved, offer descriptions confirmed, and order monitoring tooling is in place. The framework is available for external builders and is being used within pilot communities. The next phase focuses on Group-scoped offer catalogues.

Mini App Store

A shortlist of nine concepts was assembled from ETHGlobal Cannes 2026 and mapped to Circles Group mechanics: shared expense pots, vouched peer credit, local civic campaigns, skill exchange, NFC group identity, and group governance. Being formatted as inspiration cards for the Group Creator Toolkit.

The first working mini app shipped this week. The XMTP x Circles integration is a proof of a messaging-native Circles experience, where trust and group context travel with the conversation. A WebSocket upgrade for the transaction routing layer is in progress, improving real-time responsiveness for mini app interactions.

Invitations

The Invitation Manager shipped in Q1. It manages precharged referral links with group pre-assignment, UTM tracking, and redemption stats. Currently serving both IRL campaigns and digital outreach.

Infrastructure

Transaction reliability held stable through Q1. The CRC/ETH pair maintained its price floor with low volatility, trading between 0.008 and 0.012 ETH and supporting consistent swap operations in Gnosis App. Infrastructure capacity is sufficient for current volume. No critical failures.

—

Team

Marketing Manager role filled in late Q1. Q1 scope: narrative testing, booth materials, pilot proposals, gnosis.io content, and Group Creator adoption messaging. Q2 focus: Group Creator Toolkit rollout and post-pilot narrative refinement.

Gnosis Chain

Technical Updates

Gnosis scheduled the Fusaka hard fork on Chiado testnet for March 16, 2026 (epoch 1353216), giving the community a chance to validate protocol changes ahead of mainnet.

Gnosis Chain mainnet will activate the Fusaka hard fork on April 14, 2026.

Additionally, since Fusaka testnet launch all devnets and shadow forks happen internally, representing advances in the technical capabilities of the team.

Other updates:

• Transparency and Balancer response

  • On the transparency front, the team published a full post-mortem on the Balancer exploit and the December 2025 recovery hard fork, documenting what happened and how the protocol responded.

• dApp Security

  • dApp facing security saw a new audit workflow, package trust policies, locked dependency versions, and patches across several packages.

• Testing (EEST, Hive)

  • Extended Ethereum’s execution-specs to support Gnosis-specific behaviour, enabling post-merge test fixture generation and client validation via Hive.

• Ethereum Economic Zone

  • The Gnosis Chain team has been supporting Gnosis’s involvement with the Ethereum Economic Zone, providing technical input as part of the Gnosis & ZisK development team.

• Documentation

  • Documentation releases v0.17.22 through v0.18.1 covered everything from bridge updates and RPC provider changes to faucet additions and Erigon instruction fixes.

Team

A new Core Developer joined the team to focus on Geth.

Marketing

In Q1 the marketing team focused on executing against the brand and marketing strategy set out in Q4, including ongoing optimisation across all activities and continued development of key assets like the website. We also continued to support user acquisition across all Gnosis products but with particular focus on the rollout of Gnosis App, ramping up narrative testing and supporting the launch of new social channels. The final key deliverable for Q1 was the launch of EEZ at EthCC and our own brand activation in Cannes.

Specific activities included:

• EEZ brand development, website, and social channels

• EEZ launch: including video, events, and alliance activation

• Gnosis brand activation at EthCC: Booth + VIP Dinner

• Gnosis Ramp launch under the Gnosis Pay brand

• Visual identity and website improvements

• Refreshed product boilerplates and improved updates flow

• Internal product update automation and agent enrichment

• DAO hub created and forum and communications refresh ready to be implemented

Team Onboarding:

It was a busy quarter for the growth of the Marketing team. A Head of DAO & Ecosystem, Circle Marketing Manager and Gnosis Business Marketing Manager joined the team. Additionally a Head of Content will be joining shortly.

HR & Finance

[Details to be added once processed]

Added April 29th:

Category	Budgeted	Actual
Product Development	$3,875,000.00	$3,812,976.00
Core and Infrastructure	$900,000.00	$1,045,436.00
BD & Dev Rel	$962,500.00	$439,034.00
Marketing and Design	$508,750.00	$473,358.00
Legal	$406,250.00	$299,819.00
Finance	$147,500.00	$215,640.00
Personnel Overheads	$375,000.00	$212,129.00
Other Personnel	$341,875.00	$356,500.00
Total Q1	$7,516,875.00	$6,854,892.00

See a full breakdown: https://drive.google.com/file/d/1iCifuc60h9bMZmg0g9D9yuYIf_0TcTUD/view?usp=sharing

[Wismerhill]

Thanks for the report. A few observations and questions.

Having now read all three quarterly reports (Q3 2025, Q4 2025, Q1 2026) side by side, I want to be direct about what the data shows.

The capital allocation question

Effective circulating supply of GNO, after excluding DAO holdings (DAO and Ltd - which are both non-circulating), is approximately 1.3M tokens. On-chain treasury value net of GNO holdings sits around $203M, putting on-chain NAV at roughly $157 per GNO. This does not include off-chain investments (VC portfolio, Safe stake, and others) worth in excess of $20M, which remain undisclosed in detail but would push NAV meaningfully above $170. GNO trades at ~$120, a discount of at least 23% to on-chain NAV alone, and likely 30%+ once off-chain assets are included. The discount has been widening, not narrowing.

The DAO has now disbursed roughly $22.5M to Gnosis Ltd over three quarters. Total revenue across all products in that period is likely under $400K. That is a return of less than 2 cents on every dollar deployed. Meanwhile, that same $22.5M used for buybacks at current prices would have retired roughly 187,500 GNO, approximately 14.4% of effective circulating supply, permanently and immediately accretive to every remaining holder.

That is not an abstract comparison. It is the minimum bar Gnosis Ltd needs to clear to justify its budget. And right now it is not remotely close.

On framing

The report opens with “Q1 2026 built on the growth seen in Q4.” Here are the actual numbers:

• Gnosis Pay active users: 11,663, down 20.7% QoQ

• Gnosis Pay transactions: 554,114, down 11.3% QoQ

• Gnosis Pay volume: $27M, down 17% from $32.5M

• Circles active minters: 2,903, down 22% from 3,700

• Gnosis Business monthly volume: $14.1M in January, $9.1M in February, $9.6M in March

• Gnosis App DAU: ~1,000, with ~500 active card users

Every single user-facing metric declined. There is no growth in this report. Presenting contraction as growth is not a matter of framing or interpretation. It is misleading, and it erodes whatever trust remains between Gnosis Ltd and the GNO holders funding its operations.

On declining transparency

The Q3 report set a reasonable standard: a budget vs. spend table ($5.5M spent against $7.5M budgeted), Gnosis Pay revenue ($119,865 actual vs. $206,849 projected), headcount (129 to 135), and Gnosis Business active user counts. Since then, disclosure has been systematically stripped out:

• Q4 dropped the budget table but still reported Pay revenue ($131K) and headcount (130 to 132)

• Q1 has removed revenue, removed the budget table, removed headcount, and removed Gnosis Business active user counts - we can attribute this to metrics being really concerning, or not being tracked on a month-to-month basis

This is not an oversight. The reporting is getting less transparent in lockstep with the metrics getting worse. When you are spending $7.5M of other people’s money per quarter and your response to declining performance is to disclose less, that is a serious governance problem.

On the Gnosis App: three pivots, 1,000 users

The Gnosis App has undergone a complete strategic reversal in nine months:

• Q3 2025: pivoted away from Circles-focused wallet toward a neobank, Circles as a rewards layer

• Q4 2025: doubled down on neobank-first, launched in Ireland, student events, “money-app” positioning

• Q1 2026: reversed to Circles-first with neobank under the hood, citing “the crypto neobank space is crowded”

The neobank space was equally crowded in Q3 and Q4 when the team chose that strategy. Each pivot means new onboarding, new marketing, new hires, new positioning, and discarded work from the prior quarter. Three pivots in, the result is 1,000 DAU and 500 active card users. Meanwhile the report lists a new Tech Lead, a front-end developer, a Research Lead, a social media creative, an onboarded marketing agency, Meta ads spend, TikTok and Instagram launches, university roadshows, and 125 structured interviews.

The volume of activity is not the issue. The absence of any result is. At 1,000 DAU, the Gnosis App is not a product in search of product-market fit. It is a product that has demonstrated it does not have it, three times over, with three different strategies.

On Gnosis Pay

Sign-ups (179,754) and activations (94,418) are meaningless when only 11,663 users were active. That is an 88% dormancy rate, during a subsidized cashback programme. The Dune dashboard shows weekly volume plateaued around $2.1M after peaking near $2.5M. Growth has flatlined while users are literally being paid to transact.

Q4 framed declining EUR/GBP volumes as “improved incentive efficiency.” Q1 reveals active users dropped another 21% and transactions fell 11%. That was not efficiency. It was the beginning of churn that is now clearly visible.

Gnosis Pay has real infrastructure (Visa, regulatory approvals in 20+ countries, a B2B2C platform). The optionality may be worth preserving. But let’s be honest about scale: $131K revenue in Q4 against a product team, compliance, Visa integration costs, and cashback subsidies that likely run into the millions per quarter. The unit economics are deeply negative and the user base is shrinking.

On Gnosis Business

Active business plans: 57 (Q1 2025), 51 (Q2), 28 (Q3), 17 (Q4). Q1 2026 stopped reporting the number. Volume fell from $14.1M in January to $9.1M in February within the same quarter. The user base has contracted over 70% in a year.

The response to this collapse is to build “Gnosis Business Lite” for freelancers and an “AI-queryable ledger.” This is not a serious response to a product that is failing. It is feature development for the sake of justifying continued headcount.

On product triage

Gnosis Chain maintenance is necessary infrastructure. Gnosis Pay has optionality worth preserving at a right-sized budget. Everything else, the Gnosis App (1,000 DAU), Circles (declining engagement), Gnosis Business (70%+ user loss), Gnosis VPN, Gnosis AI, is consuming meaningful resources against a $30M annual budget with no credible path to generating value for GNO holders. I want to understand whether anyone at Gnosis Ltd has seriously considered shutting down or pausing any of these, or whether the assumption is that the DAO treasury exists to fund perpetual experimentation regardless of results.

---

Questions:

1. Revenue: Q3 disclosed Gnosis Pay revenue at $119,865. Q4 disclosed $131K. Q1 discloses nothing. What was total revenue across all Gnosis Ltd products in Q1, and why was this line removed from the report?

2. Budget vs. spend: Q3 included a clear budget vs. spend table ($5.5M against $7.5M). It has been absent for two quarters. What was total Q1 spend, broken down by product line in the same format as Q3?

3. Headcount and compensation: Q3: 135. Q4: 132. Q1: unlisted despite hiring across every team. What is current headcount and what share of the $7.5M quarterly budget goes to compensation?

4. Gnosis App total cost: Three pivots, 1,000 DAU. What is the total cumulative spend on the Gnosis App since inception, and has leadership considered pausing this product rather than funding a fourth strategy?

5. Gnosis Pay post-subsidy: 88% card dormancy during active cashback. What does Gnosis Ltd project for active users and volume if the programme is not renewed after June 30th?

6. Gnosis Business active users: This metric was reported every quarter (57, 51, 28, 17) until Q1 when it disappeared. What is the current number, and at what point does the team consider winding this product down?

7. NAV and VC portfolio: Three quarterly reports, zero progress on NAV disclosure despite GIP-146 passing Phase 2 with 87% support. On-chain NAV already shows at least a 23% discount before off-chain assets are counted. The VC portfolio has been requested for over two years. When specifically will each be published?

8. Renewal framework: GIP-128 comes up for renewal this year. I propose the following for community discussion:

   • Revenue and budget vs. spend restored to Q3 format for every future report

   • Any product showing two consecutive quarters of declining active users triggers a mandatory DAO review before continued funding

   • A minimum share of the annual budget redirected to programmatic buybacks if product revenue fails to exceed a defined threshold

   • Renewal structured as an affirmative opt-in vote, not a default continuation

   Does Gnosis Ltd have an alternative proposal?

---

$22.5M deployed. Revenue under $400K. Every product metric declining. A Gnosis App with 1,000 users after three strategic pivots. A Gnosis Business product that has lost 70% of its users. Quarterly reports that disclose less each time. And a NAV discount that widens while the team hires more people and launches TikTok accounts.

The same $22.5M would have retired 14.4% of effective circulating supply through buybacks, permanently increasing every remaining holder’s claim on the treasury. Instead, GNO holders received feature lists, strategic pivots, and progressively less transparency about how their capital is being spent.

The burden of proof for GIP-128 renewal should not be on the community to justify saying no. It should be on Gnosis Ltd to justify saying yes. Based on three quarters of evidence, that case has not been made.

[ernst]

Appreciate the challenge. Responding to the main themes below.

On capital allocation: the comparison of ‘$22.5M deployed vs what buybacks would have achieved’ is problematic because they operate on inherently different time horizons. Returning capital via buybacks instead of building products is not the strategy of Gnosis Ltd. We care about GNO holder value, but the focus of the current program is on long‑term ecosystem development rather than short‑term, purely financial‑engineering measures. Both have a raison d’etre but the DAO funded Gnosis Ltd to develop products and infrastructure based on a goal of sustainable value generation. The north star metric here is user growth. This is a longer path and comes with iteration, uncertainty, and unfortunately also some periods where results lag expectations.

On performance: yes, some metrics are down. There are specific reasons for that, and we are actively addressing them. For example, Gnosis Pay was rebuilt from the ground up to support a B2B2C model. During that transition, onboarding to v1 was effectively paused while v2 was not yet live, which impacts short-term usage metrics. V2 is now in testing, including with external partners; one of these partners has a substantial non‑crypto‑native user base, and we will share more details once we are legally able to do so. Similarly, Gnosis Business is underperforming and we are working with the leadership team on improvements with the understanding that we are prepared to make hard decisions if needed that include shutting down or refocusing products that do not justify continued investment.

On the Gnosis App and “pivots”: changing direction based on user research is not a failure mode, it is how product development works. The difference here is that you are seeing it in public. We run extensive user testing and adapt based on what we learn. That does not always look clean, but it is preferable to sticking to a strategy that data does not support.

On transparency: I want to address head-on any suggestion that we’re deliberately hiding information. That’s not how we operate and not how we intend to. Our interests here are fully aligned with the community’s, and the work is better when it’s scrutinized. Incomplete reports reflect timing, not intent. Some data points in the latest report weren’t ready at publication and will be added within the next 2 weeks, as has been done in prior updates. We completely agree that reporting should be consistent and complete, and we’ll improve on this going forward.

Finally, on the broader framing: NAV per token is an important metric and somewhat reflects current conviction. We are very aware of it. However, the strategy for Gnosis as a project has always been focused on long-term value creation. A DAO vote would be required to change that focus and that is something that anyone can propose.

[Wismerhill]

Friederike, thanks for the reply. A few points back.

On capital allocation

Framing buybacks as “short-term, purely financial-engineering measures” in opposition to “long-term value creation” is a false dichotomy that does not survive contact with how serious capital allocators operate.

Apple has spent over $700 billion on buybacks since 2012 while simultaneously running one of the largest R&D programs in corporate history, at roughly $30 billion per year. Tim Cook has stated explicitly that Apple only repurchases when management believes the stock is undervalued, and that buybacks are a core part of returning value to shareholders, not an alternative to it. Berkshire Hathaway operates under the same discipline. Buffett has written at length that repurchases below intrinsic value are among the highest-return capital decisions a firm can make. Neither company is accused of short-termism. Both are held up as exemplars of long-term capital discipline.

The reason is mathematical. When a share trades below NAV, buybacks are accretive to long-term NAV per share. They are not in tension with building value. They are a mechanism of building value, when the market provides the opportunity. Any investment in new products must clear a hurdle rate higher than the guaranteed return from buybacks at the prevailing discount. At 23 to 30%+, that hurdle is high. With total disclosed revenue under $400K against $22.5M deployed, the current portfolio is nowhere near clearing it. A rational capital allocator would redirect spend until it can.

This is not a hypothetical the DAO has yet to debate. GIP-148 already gave Noca discretionary buyback authority up to $5M per quarter. The community has already decided buybacks are part of the strategy. Framing them as “not the strategy of Gnosis Ltd” sidesteps a decision the DAO has already made and leaves Gnosis Ltd presuming an authority over capital allocation that the DAO did not grant.

On “prepared to make hard decisions”

I want to take this claim at face value and test it against the record.

Gnosis Business active users: 57, 51, 28, 17, undisclosed. Four consecutive quarters of decline, over 70% contraction. No shutdown. No team reduction. New feature work shipped (Business Lite, GUTL).

Gnosis App: 1,000 DAU after three strategic reversals in nine months. No pause. Instead a new Tech Lead, new front-end developer, new Research Lead role, social media creative hire, marketing agency onboarded.

Circles: active minters down 22% in the same quarter it was repositioned as the lead product of the Gnosis App. No change in scope or team size.

Overall headcount: 127 at GIP-128 filing, 135 at end Q3, 132 at end Q4, undisclosed in Q1 despite visible hiring across every team.

The revealed preference is that no hard decision has been made across three quarters of declining metrics. “Prepared to make hard decisions” is not a track record. It is a forward-looking claim. If the claim is genuine, it should be specific and pre-committed. At what Gnosis Business active user count does the product get shut down? Ten? Five? Zero? What DAU threshold triggers a pause on the Gnosis App rather than pivot number four? At what quarterly revenue miss does Gnosis Pay trigger a structural budget review? Without pre-committed thresholds, “prepared to make hard decisions” is indistinguishable from spending first and reconsidering only if pressure forces the conversation. The pattern to date is that growing headcount continues while every metric the team itself calls north-star is contracting. Hiding behind a budget is not the same as managing to outcomes.

On pivots

Pivoting based on user research is how product development works at a pre-PMF seed-stage startup with $1M of capital and twelve months of runway. It is not how product development works on a product consuming $3.1M per year that is three opposite reversals into its lifetime.

The Gnosis App has pivoted three times to three opposite strategies in nine months, each justified by new user research, each contradicted by the next round of research. The “crypto neobank space is crowded” rationale used to justify the Q1 reversal was equally true in Q3 and Q4 when the team chose that strategy. Either the market analysis is not rigorous enough to drive strategy, or it is being used as ex-post justification for decisions being made on other grounds. A rigorous framework pivots when there is evidence the current path will not work and evidence a new path will. Three opposite pivots in nine months suggests evidence that none of the paths are working, which is a different problem requiring a different response.

At 1,000 DAU after three pivots on the same team, the learning is not “we need a fourth strategy.” It is “this team, at this budget, has not found PMF on this product.” Those are different problems. One gets solved by pivot number four. The other gets solved by restructuring the bet.

On the framing this keeps returning to

GIP-128 did not fund a venture portfolio. It funded named products with named budgets: $8M for Gnosis Pay, $3.1M for the App, $2.9M for Business, $1.5M for Circles. The “three startups” framing invoked in the AMA, and echoed in parts of your response, is a post-hoc reframing that extracts venture-style latitude from a mandate that was pitched and approved as a product operating budget.

The DAO is not an early-stage LP. It is funding growth on products that were represented to it as operational. Gnosis Chain and Gnosis Pay are the two with demonstrated PMF. The mandate on both is to scale them. Gnosis Pay active users down 20.7% QoQ during an active cashback programme is not scaling, it is churning. The App, Circles, and Business do not have PMF and continuing to fund them at pre-PMF burn rates under the label of a product operating budget is a category error.

If these products are not growing, either the capital is being allocated wrong, or the execution is wrong, or both. Both problems have solutions. Continuing at the current burn rate while describing contraction as growth, removing disclosures, and framing buybacks as beneath a long-term strategy is not one of them.

On NAV and “current conviction”

NAV is a measure of assets, not conviction. The discount to NAV is the market’s signal about strategy. A widening discount across three quarters of $22.5M deployed, with every user-facing metric contracting, is the market doing its job and giving Gnosis Ltd direct feedback on capital performance.

Dismissing that signal as short-termism, while the team’s own stated north star (“user growth”) is declining on every product the DAO funds, inverts cause and effect. The conviction problem is not that the market is wrong about value. It is that the operating plan is not generating it.

[citrullin]

@Wismerhill

Total revenue across all products in that period is likely under $400K.

It’s a concerning fact when one of the delegates has no access to the internal books of the Ltd. that were supposed to be in service of the DAO.

[citrullin]

Excellent analysis. It’s worst than I actually expected. The time for questions is clearly over.
The bleeding of the DAO has to stop immediately. This is not a sustainable path.

Personally, I would demand Gnosis Ltd. to have a plan what services they want to cut back on.
Giving them until End of May to come up with a reasonable path to cut the fat.
Otherwise making clear this will result in not even a further discussion about funding from the DAO.
Making Gnosis Ltd. obsolete as a company and service provider as of 1st of June 2026.

[citrullin]

@ernst

Incomplete reports reflect timing, not intent.

Either way, you are not putting the DAO first. Making the intent irrelevant.

The result:
Self-interest in preserving the Ltd. is prioritized in practise over the DAOs concern.

@ernst

Some data points in the latest report weren’t ready at publication and will be added within the next 2 weeks, as has been done in prior updates.

We are far beyond the trust me bro approach here. If the data are incomplete at set date when it is supposed to be publish. You publish it with a note expressing why the data are incomplete. What you are working on to make them complete and when you publish them. Your behaviour in action towards the DAO have shown over and over again, you prioritize self-interest within the Ltd. over DAOs interest. It doesn’t matter how you personally feel about the decisions the DAO makes. It’s not your place to be a moral authority over the DAO. You are a mere service provider for the DAO. Act as such, be accountable or see yourself losing the very thing you started.

[Kenk]

Financial data and a full overview PDF have been added, completing the report. We’ve noted that metrics could be more community-accessible, and work is underway on a unified view with a QvQ breakdown to support future reporting. This will be shared in the comments when ready, ahead of the next quarterly report.