RSA 301-B › Registry Requirements

Registry Requirements

How to Register a DAO in New Hampshire

0 of 11 assessed · 0 passing · 0 failing

Overview

RSA 301-B:15 establishes eleven listing requirements that every DAO must satisfy in order to be placed on the New Hampshire DAO registry. These requirements cover the DAO’s technical infrastructure, governance and transparency mechanisms, and decentralization structure.

Critically, these requirements must be satisfied both at the time of application and “at all times” afterward. New Hampshire is the only state with ongoing compliance obligations for registered DAOs. The registry administrator — currently the University of New Hampshire Interoperability Laboratory (UNH-IOL) — monitors compliance on an ongoing basis.

Use the interactive checklist below to assess your DAO against each requirement. Your selections are saved locally and persist between sessions.

The 11 Requirements

Technical Infrastructure (a–e)

These requirements establish what the DAO’s technology must provide: a permissionless deployment, public visibility, open-source code, quality assurance, and a user-facing interface.

(a) Permissionless Blockchain
NH UT

RSA 301-B:15(I)(a)

“The DAO shall be deployed on a permissionless blockchain.”

What This Means

Your DAO’s smart contracts must run on a public blockchain where anyone can validate transactions. Private or permissioned chains do not qualify.

How to Demonstrate

Identify the blockchain (e.g., Ethereum, Solana, Avalanche) and confirm it meets the § 301-B:5(XXX) definition of a permissionless blockchain.

Cross-reference: § 301-B:5(XXX) (definition of “permissionless blockchain”)

(b) Public Address
NH UT

RSA 301-B:15(I)(b)

“The DAO shall provide a unique public address by which any person can review and monitor the DAO’s activities.”

What This Means

The DAO must have a verifiable on-chain identity — a contract address or equivalent — that anyone can inspect.

How to Demonstrate

Provide the smart contract address(es) deployed on the permissionless blockchain.

Cross-reference: § 301-B:5(XXXIII) (definition of “public address”)

(c) Open-Source Code
NH UT

RSA 301-B:15(I)(c)

“The software code establishing and maintaining the DAO shall be in open-source format in a public forum to allow anyone to review it.”

What This Means

The DAO’s smart contract source code must be publicly available under an open-source license as defined by the Open Source Initiative.

How to Demonstrate

Publish verified source code to a public repository (e.g., GitHub) or verify contract source on a block explorer (e.g., Etherscan).

Cross-reference: § 301-B:5(XXVIII) (definition of “open-source”)

(d) Quality Assurance Testing
NH UT

RSA 301-B:15(I)(d)

“The software code establishing and maintaining the DAO shall have undergone quality assurance testing.”

What This Means

The code must have been security-reviewed according to industry standards. The registry administrator may develop its own testing standards.

How to Demonstrate

Obtain and publish a third-party security audit report. The registry administrator (UNH-IOL) may specify additional standards per § 301-B:5(XL).

Commission note. The April 18–19, 2026 Design Sprint at UNH-IOL is developing the registry’s QA testing standards.

Cross-reference: § 301-B:5(XL) (definition of “quality assurance testing”)

(e) Graphical User Interface
NH UT

RSA 301-B:15(I)(e)

“There shall be at least one GUI by which any person can read the value of the key variables of the DAO’s smart contracts and monitor all transactions originating from, or addressed to, any of the DAO’s smart contracts.”

What This Means

There must be a web interface or app where anyone — not just developers — can inspect the DAO’s on-chain state and transactions.

How to Demonstrate

Provide a URL to a publicly accessible interface displaying smart contract state. Block explorers alone may not satisfy this if they do not show “key variables.”

Cross-reference: § 301-B:5(XVI) (definition of “GUI”)

Governance & Transparency (f–i)

These requirements address how the DAO governs itself, communicates with the public, and resolves disputes — both internally and with third parties.

(f) Public Bylaws
NH UT WY TN

RSA 301-B:15(I)(f)

“The DAO shall have bylaws that satisfy the RSA 301-B:16 and may be publicly accessed using a GUI or public forum.”

What This Means

The DAO must have written governance rules that are (1) publicly accessible, (2) written in plain language a layperson can understand, (3) accurately reflecting the smart contract rules, and (4) providing material disclosures. Where bylaws and smart contract code conflict, the code governs.

How to Demonstrate

Publish bylaws at a public URL or on-chain. Ensure they satisfy all five subsections of § 301-B:16.

Cross-reference: § 301-B:16 (full bylaws requirements)

(g) Public Communications
NH UT

RSA 301-B:15(I)(g)

“The DAO shall refer to or provide a communications mechanism accessible by the public that allows a layperson to contact the DAO, and all participants and administrators of the DAO shall be able to access the contents of this mechanism.”

What This Means

There must be a way for anyone — including non-members — to contact the DAO, and all participants and administrators must be able to see those communications.

How to Demonstrate

Provide a public forum, email address, or contact mechanism. All DAO members must have access to its contents.

(h) Internal Dispute Resolution
NH UT

RSA 301-B:15(I)(h)

“The DAO shall refer to or provide a dispute resolution mechanism to resolve any disputes among the DAO’s participants and administrators.”

What This Means

The DAO must have a mechanism (on-chain arbitration, mediation, or similar) for resolving disputes between members and administrators. Awards are treated as international arbitral awards.

How to Demonstrate

Specify the dispute resolution mechanism in the bylaws or smart contracts. May use an on-chain arbitration protocol (e.g., Kleros, Aragon Court).

Cross-reference: § 301-B:5(XIII) (definition of “dispute resolution mechanism”)

(i) Third-Party Dispute Resolution
NH

RSA 301-B:15(I)(i)

“The DAO shall refer to or provide a dispute resolution mechanism to resolve any disputes with third parties that, by their nature, are capable of being settled by alternative dispute resolution.”

What This Means

The DAO must also have a mechanism for resolving disputes with people outside the DAO — customers, vendors, counterparties — where ADR is feasible.

How to Demonstrate

Specify a third-party dispute resolution mechanism in the bylaws. This is separate from requirement (h).

Unique to New Hampshire. This dual dispute-resolution requirement (internal + external) is unique to New Hampshire. No other state DAO statute requires a mechanism for resolving disputes with third parties.

Cross-reference: § 301-B:5(XIII) (definition of “dispute resolution mechanism”)

Decentralization (j–k)

The hardest requirements — ongoing structural tests that the DAO must satisfy continuously, not just at registration.

(j) Decentralized Network (Ongoing)
NH UT

RSA 301-B:15(I)(j)

“The DAO shall be a decentralized network at all times.”

What This Means

The DAO must continuously satisfy the three-prong test in § 301-B:5(IX): no unilateral control (12-month lookback), no 20%+ ownership or voting concentration (12-month lookback), and no material code changes by insiders without governance approval (3-month lookback).

How to Demonstrate

Publish token distribution data, validator/node distribution, and governance participation metrics sufficient for ongoing monitoring per § 301-B:15(III). See the interactive calculator and mathematical analysis.

The strictest requirement. This is the requirement that makes NH’s framework uniquely strict. Utah requires decentralization at formation only. NH requires it “at all times.” See Measuring Decentralization for the mathematical tools.

Cross-reference: § 301-B:5(IX) (three-prong definition); decentralization.html (full analysis)

(k) Decentralized Governance (Ongoing)
NH UT

RSA 301-B:15(I)(k)

“The DAO shall have a decentralized governance system at all times.”

What This Means

The governance mechanism must permit genuine consensus without any person or group having unilateral control over rules or outcomes. This must hold continuously, not just at registration.

How to Demonstrate

Document the governance mechanism. Show that no person or coordinated group can unilaterally alter consensus rules or determine outcomes.

Cross-reference: § 301-B:5(X) (definition of “decentralized governance system”); decentralization.html (full analysis)

Considering other jurisdictions? See How State DAO Statutes Compare for a side-by-side analysis of requirements across New Hampshire, Wyoming, Utah, Tennessee, and Vermont.

The “At All Times” Problem

Section 301-B:15(III) mandates that DAOs publish monitoring data sufficient for the registry administrator to verify ongoing compliance. This means the eleven requirements above are not one-time gates: they create a continuous compliance obligation. A DAO that passes all eleven requirements on Monday can fail on Tuesday if its token distribution shifts or its governance mechanisms change.

The rolling lookback windows compound this challenge. The decentralization test in § 301-B:5(IX) uses a 12-month lookback for ownership and control prongs and a 3-month lookback for the source code prong. Compliance is therefore a moving window: a large token sale, a delegation event, or a single code commit by an affiliated person can change the result. The Commission discussed monitoring challenges at its December 10, 2025 meeting, recognizing that the registry administrator will need both automated on-chain monitoring and manual off-chain investigation capabilities.

The Nakamoto coefficient and Gini coefficient provide the operational tools for this ongoing assessment. A DAO that monitors its own metrics proactively — and publishes them transparently — is better positioned than one that waits for the registry administrator to identify a problem. See Measuring Decentralization for the interactive calculator and mathematical framework.

Registration Process

The path from formation to registry listing involves the following steps:

  1. Authorized person delivers notice to the Secretary of State (§ 301-B:12).
  2. Notice must include the DAO name (per § 301-B:13 naming requirements) and a registered agent (per § 301-B:9).
  3. Pay the $100 filing fee (§ 301-B:12(III)).
  4. Secretary of State verifies name availability and completeness of the filing.
  5. Secretary issues a Legal Entity Identifier (LEI) number.
  6. Registry administrator lists the DAO on the blockchain-based registry (§ 301-B:14).

Stablecoin payments accepted. The Secretary of State’s office has announced it will accept stablecoin payments (USDC or Tether) for registration fees — New Hampshire’s first acceptance of digital assets at the state level.

Resources and Further Reading

This page is part of the NH DAO Law Explorer project, which provides open, interactive tools for understanding DAO legislation across jurisdictions.

Primary Sources

Related Projects

Maintained by Seth C. Oranburg, Professor of Law, UNH Franklin Pierce School of Law. Statutory text is public law. Educational analysis and display tool © 2026 Seth C. Oranburg. MIT License.