Authorize LDO Accumulation Program for up to 10,000 stETH

TL;DR

The proposal seeks to authorize the Lido Growth Committee to execute a one-time LDO accumulation program using up to 10,000 stETH from the Lido DAO Treasury.

Execution will be facilitated by the Lido Ecosystem Foundation and carried out by the Growth Committee, with discretion over execution timing and venues within predefined constraints, provided current market conditions prevail. Execution will be conducted in 1,000 stETH batches obtained from the Treasury via Easy Track, with predefined price caps, ≤3% slippage limit, and full DAO oversight across tranches.

All acquired LDO tokens will be transferred to the Treasury, with detailed reports to be published on the Research Forum by the Growth Committee upon completion of each batch.

Disclaimer

This proposal is not an addition, specification, or replacement for Liquid Buybacks: NEST execution with LDO/wstETH liquidity proposal. Unlike the proposed one-time initiative, which aims to capitalize on a recent market opportunity, NEST aims to establish a long-term automated solution to acquire LDO based on protocol performance and ETH price, and to improve on-chain liquidity.

This proposal is separate from the 2026 Ecosystem Grant gRequest (EGG) budget and is not covered under its scope.

Motivation

LDO is trading at historically depressed levels relative to ETH. The LDO:ETH ratio currently sits at approximately 0.00015, a 67% discount to the 2024-2025 median of 0.00046. It may be viewed as one of the most significant dislocations between LDO’s market price and its underlying protocol fundamentals in the token’s history.

LDO:ETH ratio, Jan 2024 – present (market data provided by Coingecko)

Critically, this dislocation is not justified by a proportional deterioration in protocol performance:

• Net revenue from staking fees declined by approximately 23% year-over-year in 2025 compared to 2024 (source), while the LDO:ETH ratio fell by ~65% over the same period.
• In 2025, costs improved by 13% year-over-year, while the DAO Rewards rate increased from 4.95% to 6.10% despite a market backdrop (source).
• Lido protocol continues to lead as the dominant liquid staking middleware by TVL, with consistent fee generation and a resilient node operator network (source).

This proposal aims to allocate capital with the intention of balancing potential upside with associated risks while also supporting the protocol’s long-term development.

Program Details

• Budget: up to 10,000 stETH, with execution carried out in batches of 1,000 stETH.
• Execution Timing and Duration:
  • The Growth Committee retains discretion over the execution pace and timing, within the defined parameter limits.
  • The Growth Committee defines the execution window for each batch when proposing the corresponding execution parameters on the Research Forum. Execution may be completed much faster than the specified end of the execution window.
  • The DAO retains the right to terminate the program:
    • through the Easy Track objection process: if any Easy Track motion for stETH batch transfer is objected to, the Growth Committee publishes clarifications and/or updated parameters on the Research Forum and submits a revised Easy Track motion; if the revised motion is also objected to, the program is considered terminated.
    • at any time via a Snapshot vote.
• Execution Strategy and Constraints:
  • Treasury assets may be used only for:
    • transfers to/from Centralized Exchanges or Market Makers,
    • conversion/swaps to execute the mandate,
    • necessary execution costs (e.g., conversion/swap/market maker fees/gas).
  • The Growth Committee may primarily utilize limit orders and Dollar Cost Averaging (DCA), including a Time-Weighted Average Price (TWAP) strategy, to avoid market movements and increased slippage.
  • Trade execution shall consider the Tolerable Slippage Threshold: ≤ 3%, meaning the worst acceptable execution price is 3% below the prevailing market price.
  • LDO acquired under this mandate may not be used for voting in any Snapshot votes or on-chain governance processes while held by the Growth Committee or its execution addresses.
• Execution Mechanisms:
  • The trades may be executed via the following execution addresses:
    • Liquidity Observation Lab multisig,
    • Rewards Share multisig,
    • or a new designated multisig that may be created by the Growth Committee (which would receive Treasury assets from the Liquidity Observation Lab multisig).
  • For the purposes of this proposal, execution addresses may not hold more stETH than required for the very next batch (+5% tolerance for operational reasons). They may, however, hold additional assets for other permitted purposes outside the scope of this proposal.
  • Funds held in these multisigs may be transferred to approved execution venues and counterparties:
    • On-chain venues: CoW Swap, 1inch, Uniswap
    • Off-chain centralized exchanges: Binance, Bybit, OKX, Gate, or Bitget
    • Market makers
• Execution Process:
  1. The Growth Committee publishes the proposed execution parameters for the next execution iteration in the dedicated Research Forum thread, including the batch size, the execution price cap, and the applicable execution window.
  2. Following a minimum notice period of 2 calendar days after publication, the Growth Committee may initiate the corresponding Easy Track motion to draw the funds from the Treasury.
  3. The Easy Track motion is then subject to the standard 3-day objection period, during which tokenholders may object to the motion.
  4. If the motion is not rejected, the batch may be executed.
  5. The Growth Committee executes trades at its discretion, within the parameters and constraints defined in this mandate, including price caps, slippage thresholds, and approved venues and counterparties, utilizing proposed execution strategies.
     • If the execution window expires before all stETH in the approved batch is swapped, or if the Growth Committee deems it reasonable to revise the batch’s initial parameters in response to changing market conditions, it may propose updated execution parameters for the remaining budget in the current batch. Any such adjustment proposal would be published on the Research Forum and subject to a 2-calendar-day objection period before execution.
  6. Before any subsequent batch is initiated, acquired LDO tokens are sent to the Treasury, and the Growth Committee publishes a report on the execution of the previous batch on the Research Forum.
• Reporting:
  • The Growth Committee publishes a report after the sale of each batch and before requesting another batch. Each report includes the total LDO acquired to date, the average execution price (LDO/ETH and LDO/USD), the remaining budget, and confirmation that LDO tokens acquired in the previous batch have been transferred to the Treasury.
  • Upon the end of the program, the Growth Committee publishes a full completion report within 14 calendar days.
  • All reports are to be published on the Research Forum.
• DAO Authority and Oversight:
  • Lido DAO holds ultimate governance authority over this mandate and may modify, pause, or terminate it at any time through a Snapshot vote, and retains the right to recall assets at any point.
  • Lido DAO retains full beneficial ownership of all stETH deployed and all LDO acquired.

Potential Risks / Concerns

• Front-Run Risk

  Publicly detailing the exact timing and size of a large-scale trade exposes this operation to predatory market actors.

  Mitigation: This proposal balances transparency with the discretion required for effective execution. By allowing the Growth Committee a degree of operational flexibility, the trades can be executed without signaling the exact moves to the market, reducing the risk of front-running and other adverse market reactions.

• Smart Contract / Counterparty risk

  The use of various on-chain and off-chain venues introduces potential technical or vendor-related vulnerabilities.

  Mitigation: Execution will be managed by the Growth Committee, which has consistently operated in good standing and, to date, has no precedent of mandate violations. Furthermore, all venues and contracts will undergo rigorous technical due diligence by the Lido Ecosystem Foundation in cooperation with the Lido Labs Foundation, and prior to any capital deployment. Further, the Growth Committee will negotiate terms with vendors to minimize counterparty risk where possible.

• Market Volatility

  Markets are inherently volatile, and the favorable LDO:ETH ratio identified in this proposal may shift during the execution window.

  Mitigation: The Growth Committee is bound by strict price and slippage thresholds defined in this mandate. If market conditions deteriorate beyond these tolerable levels, the program will be halted to prevent execution under unfavorable market conditions.

• Freezing / Blocking Risks

  Venues may freeze, block, or delay withdrawals of Treasury assets due to compliance reviews, regulatory pressure, venue-side operational issues, or asset-specific restrictions. This could temporarily or permanently impair access to assets during the execution process.

  Mitigation: The Growth Committee will distribute execution across multiple venues rather than concentrating assets on a single exchange, reducing single-point-of-failure exposure. Batch sizing further limits the maximum amount at risk at any one time. However, it should be acknowledged that the risk of freezing cannot be fully eliminated, as it ultimately depends on each venue's policies and regulatory environment.

• Regulatory & Tax Compliance

  Large-scale trades can sometimes be misconstrued as market signaling or create tax liabilities.

  Mitigation: All transactions will be conducted at arm’s length and within tight spread tolerances to maintain market integrity. All transactions will be structured in accordance with applicable legal and regulatory requirements in relevant jurisdictions.

Next Steps

A vote "For" indicates agreement with this proposal. If "For" wins:

• The Growth Committee will be granted the proposed mandate to execute the LDO accumulation program in accordance with the parameters outlined in this proposal.
• Following approval, the Growth Committee will initiate execution of the accumulation program. Execution will proceed in 1,000 stETH batches, each tranche subject to Easy Track approval. Parameters for each batch will be publicly disclosed on the Research Forum prior to initiating the corresponding Easy Track motion, and post-execution reporting will be completed prior to initiating the next batch.
• Throughout the program, the Growth Committee will operate within the specified constraints, while the DAO retains full oversight and may pause or terminate the program at any time via Snapshot or Easy Track objection mechanism.
• Upon completion or termination of the program, the Growth Committee will publish a final report within 14 days summarizing program execution outcomes.

A vote "Against" indicates disagreement with this proposal. As the range of potential concerns or remediation options may vary, a vote "Against" entails further discussion to determine what specific actions, if any, should be considered and potentially brought to a subsequent vote.