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Regulatory Compliance – ENS Organizational Registry
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Regulatory Compliance

The Problem

As DAOs adopt legal wrappers — such as Wyoming's Decentralised Unincorporated Nonprofit Association (DUNA) — they take on regulatory obligations that exist in tension with how on-chain organisations typically operate. A DUNA, for example, may need to publish its registered agent, principal office address, officers, and registration numbers. Other jurisdictions impose similar disclosure requirements on foundations, cooperatives, and other DAO-adjacent legal structures.

Today these details live in off-chain registries, government databases, and legal documents that are difficult to discover and impossible to verify against the organisation's on-chain identity. There is no way to look at a DAO's ENS name and determine whether it has a legal entity, who its officers are, or where it is registered. Worse, there is no way to verify that a statement or transaction was authorised by someone who actually holds a named role in the organisation's legal structure.

Proposed Solution

An organisation can represent its legal structure as subnodes under its ENS name. Officers, registration details, and office addresses are published as on-chain metadata — making the organisation's corporate structure discoverable from the same place as its treasury addresses and smart contracts.

supercooldao.eth
  ├── class              = "Org"
  ├── description        = "A Wyoming DUNA"
  │
  ├── ceo.supercooldao.eth
  │     └── class        = "Officer"
  │     └── full-name    = "Alice Johnson"
  │     └── title        = "Chief Executive Officer"
  │
  ├── secretary.supercooldao.eth
  │     └── class        = "Officer"
  │     └── full-name    = "Bob Chen"
  │     └── title        = "Secretary"
  │
  └── registered-agent.supercooldao.eth
        └── class        = "Officer"
        └── full-name    = "Wyoming Registered Agents LLC"
        └── title        = "Registered Agent"

Each officer subnode resolves to an Ethereum address controlled by that individual. The organisation's ENS name — controlled by the DAO's governance process — is the authority asserting who holds each role.

On-Chain Verification of Authority

This structure has a powerful consequence: the address assigned to an officer subnode can sign messages, and those signatures can be traced back to a named role in the organisation's legal structure.

If the address behind ceo.mydao.eth signs an on-chain statement, anyone can verify that the signer is the person the organisation has designated as its CEO. This creates a chain of attribution — from signature, to address, to subnode, to the organisation's ENS name — that is entirely on-chain and permissionlessly verifiable.

This is relevant anywhere official authority matters: signing governance proposals, authorising treasury disbursements, issuing public statements, or executing legal agreements on-chain. The subnode structure turns an ENS name into something closer to a corporate seal — a verifiable assertion of who is authorised to act on behalf of the entity.

Discoverability

Regulatory disclosures are only useful if people can find them. Because the officer and registration subnodes are standard ENS records, they are discoverable using the same pattern as any other subnode:

  1. Resolve the organisation's ENS name to find its subnodes.
  2. For each subnode, read the class record to identify officers, registered agents, or other roles.
  3. Read full-name and title for a human-readable summary of the corporate structure.
  4. Resolve the subnode's address to find the Ethereum address associated with each role.

Governance dashboards, compliance tools, and legal registries could index this information automatically — providing a live view of an organisation's disclosed structure without relying on off-chain filings.

🚧 Open Questions 🚧

The Person schema currently supports class, full-name, and title. For full regulatory compliance, organisations may also need to publish details like jurisdiction of incorporation, registration numbers, office addresses, and filing dates. Whether these belong as additional fields on the organisation's root node, as dedicated subnodes, or as a new schema is an open question for the community.

There is also the question of privacy. Not all officer details are appropriate to publish on-chain. Some jurisdictions require public disclosure of certain roles but not others. How to balance regulatory transparency with individual privacy — and whether mechanisms like selective disclosure or encrypted records have a role — remains to be explored.

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