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Key Requirements for Crypto-Asset White Papers

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by Ekaterina Anthony

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by Viktor Solomon

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Under MiCA, any issuer offering non-asset-referenced tokens or utility tokens must provide clear and comprehensive information in their white papers, covering aspects such as issuer identity, project goals, technology, and risks. This ensures that investors have the details they need to make informed decisions. The disclosures must include:

  • Information about the Issuer: Name, legal details, management structure, and business activities.
  • Project Information: Overview of the project’s purpose, past achievements, milestones, and use of funds.
  • Token Details: Type of token, its utility, and any additional rights or obligations.
  • Risks: Description of risks associated with the technology, issuer, and project implementation.

This checklist should be placed at the start of every white paper, followed by detailed explanations in the main sections.

Links to Key Regulations

Here are direct links to the official EU regulations and directives mentioned in MiCA:

Major EU Regulators Overseeing MiCA Compliance

The implementation of MiCA is supported by several major European regulatory bodies, which oversee different aspects of financial and digital asset markets:

  • European Securities and Markets Authority (ESMA): Oversees securities markets, including crypto-assets when offered to the public or traded on a platform.
  • European Banking Authority (EBA): Supervises financial institutions, providing guidance for crypto-asset service providers regarding anti-money laundering (AML) and consumer protection.
  • European Central Bank (ECB): Monitors the impact of crypto-assets on financial stability and payment systems within the EU.

MiCA White Paper Compliance Checklist

Below is a detailed checklist to help ensure your white paper meets all MiCA requirements. Each item in this table represents a disclosure that must be included to comply with MiCA, ensuring clarity and transparency for investors.

Section Example Detail/Description Included in White Paper? (Yes/No)
Information about the Offeror/Issuer
Name of the issuer XYZ Crypto Ltd.
Legal form and registered address Private Limited Company, 123 Blockchain Rd, EU
Date of registration Registered on 01/01/2022
Legal Entity Identifier (LEI) or other identifier LEI: 1234567890ABCDEFG
Details of the parent company (if applicable) Parent: ABC Fintech Holdings
Identities of the management body members CEO: John Doe; CTO: Jane Smith
Business activities of the issuer or parent company (if applicable) Software Development, Blockchain Services
Information about the Project
Name of the project and crypto-assets XYZ Token Project
Description of the project A platform for decentralized digital identity verification
Key personnel and advisors involved Lead Developer: Alex Johnson; Advisor: Dr. Maria Gomez
Planned milestones Beta launch in Q1 2025, full release Q3 2025
Past achievements Alpha version deployed with 1,000 users
Resource allocation 70% for platform development, 20% for marketing, 10% for legal/compliance
Use of funds raised To enhance the development and scaling of XYZ Token platform
Offer to the Public
Clarification if it's an offer or admission to trading Offer to the public on EU exchanges
Reasons for the offer Raise funds for further R&D and market expansion
Fundraising targets EUR 5 million target
Pricing and subscription details EUR 0.10 per token, minimum purchase 100 tokens
Targeted investor profiles Retail and accredited investors
Distribution of tokens Initial allocation: 50% to public, 20% to team, 30% for reserves
Crypto-Asset Characteristics
Type and functionality of the crypto-asset Utility token used for accessing identity verification tools
Classification data (utility, governance, etc.) Utility token
Planned future functionalities Voting rights for token holders in platform decisions by 2026
Rights and Obligations
Rights and obligations of token holders Access to XYZ services, potential voting rights
Conditions for exercising rights Token holders must hold at least 500 tokens to vote
Modifications to rights The company reserves the right to amend token use cases with prior notice
Future public offers Future fundraising events anticipated in 2026
Transferability restrictions Tokens non-transferable for the first 6 months post-purchase
Redemption or burn mechanisms 5% of tokens to be burned annually to reduce supply
Underlying Technology
Details of the distributed ledger or blockchain technology used Built on Ethereum blockchain
Consensus mechanism Proof of Stake (PoS)
Transaction validation incentives Validators rewarded in XYZ tokens
Technical audits conducted Audited by SecureSmart Blockchain Auditors in 2023
Risk Factors
Technology-related risks Risk of smart contract bugs or vulnerabilities
Issuer-related risks Risk of insufficient funds to complete project
Offer or admission risks Regulatory changes impacting token utility
Project implementation risks Risk of delayed roadmap milestones

For compliance with MiCA standards and to further enhance transparency, it is recommended that the white paper also be made machine-readable. This means structuring the document in a format that can be easily processed by computers, such as XML, JSON, or another structured data format. A machine-readable format allows regulatory bodies, data analysts, and investors to quickly access and verify information, facilitating automated compliance checks and streamlining data collection.

By following this checklist, crypto-asset issuers can enhance their transparency and compliance, reinforcing the trust of their investors while aligning with MiCA’s goals of fostering a robust and regulated European crypto market.

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