Eastern Cardano Council - Response to HLabs Public Response on GA95 (Pebble + Gerolamo - HLabs 2026 Budget)

The Eastern Cardano Council has reviewed the public response published by the Harmonic Labs team (Response To Eastern Cardano Council’s NO Vote on Constitutionality - HackMD) regarding our Unconstitutional finding on GA95. Our vote stands.

On the substance: Article II, Section 7(4)

The Constitution is unambiguous. Treasury withdrawal governance actions must include an explicit allocation of ADA to cover the cost of periodic independent audits and the implementation of oversight metrics. HLabs’ budget consists entirely of personnel costs and a contingency buffer. There is no audit line of any kind. Their own constitutionality checklist addresses Sections 7.1, 7.2, 7.5, 7.6, and the treasury guardrails — but Section 7(4) does not appear at all. We did not overlook the requirement. It was overlooked in the proposal.

On the administrator and the independent auditor

Section 7 contains two distinct requirements. Section 7(4) requires an allocation for periodic independent audits and oversight metrics. Section 7(5) requires designated administrators to monitor fund usage and ensure deliverables. These are not the same function. The word “independent” in Section 7(4) means the auditor must be independent of the process being audited which means independent of the administrator.

HLabs’ own constitutionality checklist designates their oversight board as their administrator under Section 7(5). Having made that designation in their own proposal, they cannot use the same body to satisfy Section 7(4). To accept that argument would render Section 7(4) entirely redundant as any proposal with an administrator would automatically satisfy it, which cannot have been the intent of two separate provisions in two separate paragraphs.

On the Dingo comparison

The Dingo proposal explicitly addressed Section 7(4) in its constitutionality checklist, citing the provision directly:

“An independent audit of all transactions funded from the Cardano treasury shall be possible. Assessment: COMPLIANT. Public transaction journal with full provenance: hashes, amounts, signers, justifications. SundaeSwap contracts enforce fund flows on-chain. Anyone can verify. Quarterly financials published with category-level detail.”

HLabs contains nothing on this point, no checklist entry, no budget line, no narrative commitment. Each governance action is assessed on its own merits and on its actual contents. These are not comparable situations.

A governance action is, functionally, like a contract made with the Cardano community. What is not written in it is not promised, and what is not promised cannot be enforced. We recognise that HLabs has significant community support and the ECC is aware of the value their work provides to the ecosystem. Neither of these considerations is relevant to a constitutional review. Our role is to assess whether a governance action as written meets the requirements of the Cardano Constitution.

On the call for constitutional clarification

HLabs argues Section 7(4) is “not a rigid formality, but a purpose-driven rule” that does not require a separate budget line. The word “shall” is mandatory. The requirement for an allocation of ada is stated plainly. We do not find this provision ambiguous.

The CC’s role is also plainly stated. Article III, Section 1(4) limits the CC to voting on the constitutionality of governance actions. We do not have the authority to issue normative clarifications or binding interpretations. If the community believes clarification is needed, Article IV, Section 1 provides the correct mechanism: a constitutional amendment via on-chain governance action supported by at least 65% of active voting stake. An Info action could also test community consensus first. These are the legitimate pathways.

Path forward

The requirement in Article II, Section 7(4) is not onerous. A revised governance action that includes an explicit allocation for periodic independent audits and oversight metrics would address the deficiency we identified. We welcome a future proposal that meets the constitutional standard in full.

2 Likes

Appreciate the detailed response for feedback here, thank you. I am a little confused, apologize if this seems obvious but can you help me understand…

This stood out to me. I would like to hear how the 2025 Intersect Administered proposals met this requirement? I led a small team to independently assess the process and provide feedback. During that time, I did not see this in the Evidence Submissions. The only proposal that did was the one that had an explicit track to audit was for Input Output, who had independent audits each month of ~478K ADA to audit several outputs from their other 2025 treasury funded proposals.

If it’s not in the project milestones and as you said, the Administrator cannot also be the auditor, what was the deciding criteria for you last year or did I miss something (if so please help me understand).

Christina

Hi Christina

Thanks for your follow up on this topic. We did express some concern over the language used in the Intersect led treasury withdrawals from last year, which all used the same wording for this requirement.

Our vote rationales (which can be read in full on our GitHub) stated the following:

Additionally; ARTICLE IV, Section 4 states “Any governance action requesting ada from the Cardano Blockchain treasury shall require an allocation of ada as a part of such funding request to cover the cost of periodic independent audits and the implementation of oversight metrics as to the use of such ada. Contractual obligations governing the use of ada received from the Cardano Blockchain treasury pursuant to a Cardano Blockchain ecosystem budget shall include dispute resolution provisions.”

This governance action specifies the following:

"Acceptance of the above work is expected to be supported by a 3rd Party Assurer, who will be responsible for reviewing and signing off the work completed at each project milestone against the corresponding milestone deliverables detailed within the Legal Contract. This work is funded from a portion of this treasury withdrawal.”

​​While there were some concerns that simply stating “is expected to be supported by” is not definitive enough and that “This work is funded from a portion of this treasury withdrawal.” does not specify how much ada is allocated, we determined that this does still fulfil the requirement in this section.

Please let us know if this sufficiently answers your question.

Thank you for sharing, basically you felt it was technically correct if not as specific as one might hope.

This prompted me to look at the milestone submissions for the Intersect Administered proposals which I think your consortium should also take a look at. I do not feel these met the technically correctness you approved.

One projects acceptance form shows an announcement with a github link for the third party assurer comments and the signature fields are blank while another used a link to a twitter account post from the maintainer. Two projects have CEO’s who swapped being the third party assurer for each other which I think taints the whole unbiased aspect of the job. One project did a wonderful job, there’s proof of review with the third party who signed the form. One project in five met the criteria, because that’s as far as I looked.