MiCA makes crypto white papers formal filings with LEI and DTI

The EU’s Markets in Crypto-Assets regulation requires crypto white papers to be filed as formal legal disclosures with mandatory identifiers, a machine-readable format and a named person or entity carrying legal liability. Regulators treat these documents as disclosure instruments comparable to securities prospectuses rather than promotional material.

The European Securities and Markets Authority published the taxonomy that defines the required structure on August 5, 2025. Machine-readable rules have been in force since December 23, 2025. Commission Implementing Regulation (EU) 2024/2984 and related delegated rules require white papers to be prepared in a structured digital format so national competent authorities can run identical automated checks on each submission across the EU. A filing that fails an automated error check does not proceed to human review.

MiCA regulation divides crypto assets into three categories, each with its own white paper template: Other crypto-assets (OTHR), Asset-Referenced Tokens (ART) and Electronic Money Tokens (EMT). For OTHR tokens, the obligation to prepare and submit the white paper generally falls on the offeror or the person seeking admission to trading, roles that can be separate from the original issuer and can be based outside the EU. ARTs and EMTs require an authorized EU issuer or institution and carry stricter authorization and liability conditions.

Two identifiers must exist before preparation begins. The filer must hold a valid Legal Entity Identifier (LEI, ISO 17442) that identifies the legal entity. The crypto asset must have a Digital Token Identifier (DTI, ISO 24165) registered in the DTIF database. If a DTI does not yet exist for a new token, a requester-often the CASP if the trading platform is filing-must obtain the DTI before submission. Files without valid LEI and DTI entries will fail automated validation.

Automated validation checks are extensive. ESMA’s taxonomy enforces 257 existence checks to confirm required fields are present and 223 value checks to verify field content. Each language version of a white paper must be submitted as its own separately structured file, and every translated version must match the original at the field level. Sustainability disclosures must use fixed units: energy in kilowatt-hours (kWh) and carbon in tonnes of CO2 (tCO2); using other units or omitting these fields triggers validation failures.

A crypto-asset service provider (CASP) operating a trading platform can agree to prepare and publish a white paper and assume responsibility for technical preparation. MiCA specifies that legal exposure cannot be fully outsourced. For OTHR filings, the person seeking admission to trading remains legally accountable if they supply incomplete, unclear or misleading information to the CASP. For ARTs and EMTs, civil liability extends to the issuer and members of its administrative, management or supervisory bodies, and contractual attempts to limit that liability are void.

A LegalBison study conducted in April 2026 and the implementing rules describe the white paper as the procedural entry gate for offering crypto assets in the EU and state that compliance requires both machine-enforced technical standards and legal disclosure duties.