COTWO ADVISORS PHYSICAL EUROPEAN CARBON ALLOWANCE TRUST

SEC 10-K Item 1C cybersecurity disclosure for a trust managed by a Sponsor. The filing states no cybersecurity incidents or risks have been identified that have materially affected, or are reasonably likely to materially affect, the Trust. Describes NIST-CSF-based cybersecurity program, ISC governance, annual due diligence on service providers (Trustee, Cash Custodian). No breach or incident is disclosed.