Legal Structure for a DAO-Based Business in India

Legal Structure for a DAO-Based Business in India

🏛️ Legal Structure for a DAO-Based Business in India 🇮🇳

DAOs are transforming the way we think about organizations. But the big question for Indian founders is: Can we legally operate a DAO-based business in India?

In this article, we'll dive deep into the legal reality, available structures, regulatory challenges, and practical paths to legally operate a DAO-style business within or from India.


🌐 What is a DAO?

A DAO (Decentralized Autonomous Organization) is an internet-native organization governed by smart contracts, blockchain voting, and community consensus — not by traditional boards or management hierarchies.

DAOs aim to eliminate the need for intermediaries by automating decision-making through smart contracts on blockchain platforms like Ethereum, Solana, etc.

✨ Key Characteristics of a DAO:

  • 📜 Code-Defined Governance: Rules are encoded in smart contracts.

  • 🗳️ Token-Based Voting: Decisions are made via token-holder votes.

  • 🌍 Global Participation: Anyone from anywhere can join or contribute.

  • 🔐 Transparent & Immutable: All actions are recorded on-chain.

  • 🤝 Trustless Collaboration: No single person controls the DAO.


As of now, DAOs have no formal legal recognition under Indian law.

  • No clause in the Companies Act, 2013, LLP Act, or Trust Act mentions DAOs.

  • Smart contracts have no enforceable status in Indian courts.

  • There's no clarity on taxation, asset holding, or legal liability for DAO members or token holders.

Despite this, Indian founders are not legally barred from participating in DAOs or even forming one — but they must use alternative legal wrappers to operate in the real world.


Since DAOs can't be registered directly, founders must wrap the DAO in a recognized Indian business structure to interact with banks, employees, vendors, and the government.

Let’s explore the main options:


1️⃣ Private Limited Company (Pvt Ltd)

🔧 Best For: Startups looking to raise VC funds, scale quickly, or handle fiat transactions

  • Registered under Companies Act, 2013

  • Requires two directors and minimum ₹1 lakh capital (practically)

  • Subject to ROC compliance, audits, and taxation

✅ Pros:

  • Legally valid, globally accepted structure

  • Easy to enter into contracts, hire staff, and open bank accounts

  • Preferred by investors, especially VCs

❌ Cons:

  • Centralized structure — contradicts DAO philosophy

  • Cannot embed smart contracts directly into operations

  • Extensive compliance load


2️⃣ Limited Liability Partnership (LLP)

🔧 Best For: Small DAO teams and consulting-based or low-scale Web3 businesses

  • Registered under LLP Act, 2008

  • Requires two partners

  • Flexible agreement allows token distribution clauses

✅ Pros:

  • Less compliance than Pvt Ltd

  • Can be more community-centric in structure

  • Profit-sharing customizable via partnership deed

❌ Cons:

  • Still requires human partners — no true decentralization

  • More difficult to scale or raise institutional capital


3️⃣ Trust / Society / Section 8 Company

🔧 Best For: DAOs focused on public goods, open-source projects, or non-profit goals

  • Useful for community grants, donations, or protocol development

  • Can register under Indian Trusts Act or Societies Registration Act

✅ Pros:

  • Aligns with DAO philosophy of community ownership

  • Easy to justify treasury operations for public benefit

  • Good for protocol development DAOs or open-source tools

❌ Cons:

  • Commercial activity is limited

  • Cannot distribute profits

  • Regulatory monitoring is high


🔁 The Hybrid Approach (Most Practical)

Most Indian founders are now using a hybrid DAO model:

🧠 DAO handles on-chain governance + 🏢 Pvt Ltd or LLP handles off-chain operations


✅ Here's how it works:

LayerFunction
🧱 DAO (on-chain)Manages community votes, grants, treasury (crypto)
🏢 Indian entity (off-chain)Handles payroll, fiat banking, compliance
🌐 Foreign entity (optional)DAO incorporated in a crypto-friendly jurisdiction (e.g., Singapore, UAE, Cayman)

Running a DAO in India is not illegal, but it’s not easy either.

Here are the major legal and regulatory gray areas you must navigate:


🔸 1. Smart Contracts Not Legally Enforceable

  • Indian Contract Act does not currently recognize self-executing code as a binding agreement.

  • If a dispute arises over a DAO vote or action, courts may not accept on-chain records as final proof.

  • India has not defined DAO tokens — are they securities? Commodities? Virtual digital assets?

  • The Income Tax Act (VDA rules) applies a flat 30% tax + 1% TDS on crypto transfers, even for governance tokens.

🔸 3. No Entity Can Be Fully "Decentralized"

  • Indian law requires human owners or partners.

  • You can't register an org where no one is in charge — that’s legally invalid.

🔸 4. FEMA and Cross-Border Issues

  • If DAO treasury receives funds or payments from outside India, FEMA (Foreign Exchange Management Act) applies.

  • Crypto transfers across borders may attract scrutiny from ED, RBI, and SEBI.


🇮🇳 Current Government Outlook

India has taken a cautious stance on crypto and DAOs:

DepartmentPosition
RBIStrongly skeptical of private cryptocurrencies
Finance MinistryImposed VDA tax laws; not outright bans
SEBIWorking on a regulatory framework for digital assets
MeitYExploring blockchain for governance; no DAO laws yet

here is no direct law banning DAOs, but there is also no clear legal path to fully decentralize a business in India.


📘 How Indian Web3 Startups Are Operating DAOs

Here are real-world strategies that Indian DAO projects are using to stay compliant:


✅ 1. Use Foreign Foundation for DAO

  • Register DAO in Singapore, UAE, or Cayman Islands

  • Keep Indian entity as a “tech service provider”

  • Avoid crypto exposure in India directly

✅ 2. Keep DAO Treasury On-Chain

  • No crypto transactions in Indian bank accounts

  • Use stablecoins or crypto for community operations

  • Convert only when required through legal exchanges

  • Indian entity signs an MoU with the DAO (yes, with a multisig or smart contract)

  • Define services, scope, and deliverables clearly

  • Helps auditors and banks during scrutiny


💡 Best Practices for DAO-Based Businesses in India

✅ Action🔍 Why It Matters
Register an Indian entityNeeded for hiring, tax, compliance
Use a compliant crypto exchangeTo manage fiat conversion legally
Maintain clean documentationEspecially around token grants and treasury use
Consult a crypto-knowledgeable CA/LawyerTraditional firms may not get it
Stay updated on VDA taxationRules may evolve soon

📍 Future Outlook: Will India Recognize DAOs?

India is drafting the Digital India Act, which may bring better legal definitions around blockchain, digital assets, and maybe DAOs.

Meanwhile, organizations like:

  • BACC (Blockchain & Crypto Assets Council)

  • IAMAI (Internet & Mobile Association of India)

...are engaging with regulators to help formalize DAO-like models in the country.

✨ India may not fully embrace DAOs yet, but a future-friendly legal framework is possible within the next 2–3 years.


🧾 Conclusion

DAOs are the future — but the present in India requires a workaround.

🧠 You can operate a DAO-style business in India — just don’t expect to do it purely on-chain (yet).

By wrapping your DAO with a Pvt Ltd, LLP, or Trust, and using smart contracts and tokens off-chain, you can stay compliant while exploring Web3 innovation.

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