MiCA Crypto-Asset White Paper Services

Only crypto-asset white papers for asset-referenced tokens (ARTs) require formal approval from the competent authority. For e-money tokens (EMTs) and other crypto-assets, the white paper must be submitted to the relevant regulator before publication, but prior approval is not required.

Under MiCA/MiCAR, offerors of crypto-assets and persons seeking admission to trading must publish a MiCA/MiCAR white paper before offering crypto-assets to the public or applying for a trading venue listing.

For ARTs and EMTs, only the issuer of the respective crypto-asset is responsible for the white paper.

For other crypto-assets (not ARTs or EMTs), operators of a trading platform must also publish a white paper if the crypto-asset is admitted to trading on the initiative of the platform operator and no white paper for the crypto-asset yet exists.

According to Article 4(7) and Article 5(4) MiCA/MiCAR, an offeror or a person seeking admission to trading can only use an existing white paper if they obtain explicit written consent from the entity responsible for the original white paper.

Yes, under Article 4(2) MiCA/MiCAR, certain crypto-assets can be offered to the public without a white paper in the following cases:

• The offer is made to fewer than 150 persons per EU member state, provided that the offeror acts on their own account.
• The total value of the offer across the entire EU does not exceed €1 million within a 12-month period.
• The offer is made exclusively to qualified investors, meaning professional clients as defined under Annex II, Section I, MiFID II.

Additionally, utility tokens that provide access to already existing goods or services are exempt from the white paper requirement under MiCA/MiCAR.

Crypto-asset exchange platforms qualify as Crypto-Asset Service Providers (CASPs) under MiCA/MiCAR. A trading platform operator must only publish a white paper if a crypto-asset is admitted to trading on its own initiative and no existing white paper is available.

If a white paper already exists, the platform is not required to draft a new one. Instead, under Article 66(3) MiCA/MiCAR, the platform must ensure that hyperlinks to all available white papers are provided for public reference.

Exchange platforms can verify the existence of a white paper through the ESMA register (Article 109 MiCA/MiCAR) before listing a crypto-asset.

A MiCA/MiCAR-compliant white paper must provide clear and transparent information about the issuer, the crypto-asset, and the risks involved. It should include:

• Issuer and Offer Details – Information on the entity issuing or offering the crypto-asset.
• Crypto-Asset Description – Features, functionalities, and rights attached to the asset.
• Project and Offering Terms – The purpose of the project and key details of the token sale or trading application.
• Technology Overview – Explanation of the blockchain and consensus mechanism.
• Risk Factors – Financial, legal, and operational risks for investors.
• Environmental Impact (if applicable) – Information on climate-related impacts if already available from the blockchain.

Non-compliance with MiCA/MiCAR’s white paper requirements can lead to regulatory fines, trading restrictions, and potential legal claims from investors. Authorities may take enforcement actions, and failing to meet transparency requirements can damage your reputation, making it harder to attract investors and operate in the market.

To launch a crypto token in the EU, you must comply with the Markets in Crypto-Assets Regulation (MiCA/MiCAR). Whether it’s a utility token, governance token, or memecoin, a MiCA/MiCAR-compliant crypto-asset white paper is typically required before offering the token to the public or listing it on an exchange. Token launch strategies must align with MiCA/MiCAR compliance obligations from day one.

MiCA/MiCAR outlines specific white paper requirements for any crypto-asset offering to the public or listing on an EU exchange. A TGE or ICO usually must include a white paper disclosing the issuer’s identity, token functionality, offering terms, technology stack, and potential risks. This is essential to ensure MiCA/MiCAR compliance for token launch projects across Europe.

Utility tokens are legal in the EU, but they may still fall under MiCA/MiCAR depending on how they are offered or used. MiCA/MiCAR distinguishes between utility tokens that merely grant access to existing services and those used in broader ecosystems. To assess legality under EU crypto regulations 2025, a classification under MiCA/MiCAR crypto asset rules is essential.

Yes, if your ICO targets EU investors or exchanges, a white paper that meets all MiCA/MiCAR white paper requirements is mandatory unless your project qualifies for a narrow exemption. Token ICOs without a compliant white paper risk regulatory sanctions, investor claims, and exchange listing bans.

Can I list my token on an exchange EU without MiCA/MiCAR compliance?

Major EU exchanges in the EU require listed tokens to be compliant with MiCA/MiCAR. This includes ensuring a valid white paper has been filed or is publicly available. Without it, crypto exchanges may refuse to list your token or require remedial compliance steps.

MiCA/MiCAR compliance for token launch projects involves a step-by-step legal process: determining if a white paper is required, preparing the white paper with all disclosures, notifying regulators, and verifying crypto-asset classification. This applies to governance tokens, ICOs, and utility token launches alike

The MiCA/MiCAR white paper must be submitted to the competent national authority in the EU member state of the issuer or offeror. It also needs to be made publicly available, usually on the issuer’s website, before the crypto token sale begins.

Starting in 2025, with MiCA/MiCAR fully in force, crypto projects planning a token generation event must comply with EU crypto regulations. This includes publishing a white paper, following disclosure requirements, and avoiding misleading information—especially when offering utility or governance tokens to EU retail investors.

MiCA/MiCAR divides crypto-assets into categories: asset-referenced tokens (ARTs), e-money tokens (EMTs), and other crypto-assets like utility and governance tokens. Proper classification is crucial for determining which rules and disclosures apply to your ICO, TGE, or token sale.