Under MiCA, most public token offerings or exchange listings require a mandatory disclosure document called a crypto-asset white paper. It’s not marketing and not optional — it’s a legally prescribed document with strict content, liability, and formatting rules. Think of it as a regulated prospectus-lite for crypto.
Under MiCA, most public token offerings or exchange listings require a mandatory disclosure document called a crypto-asset white paper.
It’s not marketing and not optional — it’s a legally prescribed document with strict content, liability, and formatting rules.
Think of it as a regulated prospectus-lite for crypto.
Below is the standard structure, followed by what regulators expect in practice.
Purpose: Identify who is responsible and legally liable.
Must include:
Example
“XYZ Labs Limited, an Irish private company limited by shares, accepts full responsibility for the accuracy of this white paper.”
Purpose: Transparency on who’s behind the token.
Must include:
Example
Purpose: Explain why the token exists.
Must include:
Example
“The token enables access to decentralised storage services within the XYZ Network and is required to pay for transaction fees.”
No vague “future ecosystem” language — no fluff!.
Purpose: Define exactly what the token is — legally and technically.
Must include:
Example
“The token does not confer ownership, voting rights, or profit participation.”
If you don’t say this clearly, regulators may assume it does.
Purpose: Prevent misleading supply or value expectations.
Must include:
Example Table
Any discretion to change supply must be disclosed explicitly.
Purpose: Investor/user protection.
Must include:
MiCA rule:
Retail purchasers usually have a 14-day withdrawal right, unless an exemption applies.
Purpose: Operational transparency and risk assessment.
Must include:
Example
“Smart contracts have been audited by ABC Security Ltd; no critical vulnerabilities identified.”
If there is no audit? You must say so.
Purpose: Consumer protection.
Must include:
MiCA expectation
Example:
“If the XYZ protocol fails to reach minimum network adoption, the token may have no functional utility.”
Purpose: ESG transparency.
Must include:
Especially relevant for proof-of-work chains.
Purpose: Consumer rights.
Must include:
Purpose: Prevent regulatory arbitrage.
Must include:
MiCA requires specific wording, including:
Token:
TypeProcessUtility / other crypto-assets Notification to Central Bank of Ireland
Asset-Referenced Tokens (ARTs) Prior approval required
E-Money Tokens (EMTs) Issuer must be authorised
The white paper must be published before offering or listing.
Overview: A MiCA white paper must:
Under MiCA, most public token offerings or exchange listings require a mandatory disclosure document called a crypto-asset white paper. It’s not marketing and not optional — it’s a legally prescribed document with strict content, liability, and formatting rules. Think of it as a regulated prospectus-lite for crypto.
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