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White Paper

Our database helps Crypto Asset Service Providers to find and keep up-to-date white papers in order to fulfill their MiCAR-requirements. Please make sure to read the Info- and FAQ-sections on the bottom of this page before using the data.

If you are an issuer or offeror of crypto-assets, electronic money token or asset-referenced token, please click here.

Info

According to MiCAR Articles 4 and 5, Crypto Asset Service Providers shall not offer a crypto asset or seek admission to trading of a crypto-asset other than an asset-referenced token or e-money token within the European Union unless that person has drawn up a crypto-asset white paper in respect of that crypto-asset in accordance with Article 6 and is keeping it up to date in accordance with Article 12. As per ESMAs public statement “On the provision of certain crypto-asset services in relation to non-MiCA compliant ARTs and EMTs“, dated January 19th 2025, the concept of “offer“ must be understood broadly, including brokers and proprietary traders.

This causes challenges for Crypto Asset Service Providers in situations where no MiCAR-compliant white papers are available, as these will not be able to list assets without white papers from December 30th, 2024 on. As it would also not make sense for every Crypto Asset Service Provider to draft up own white papers (and bear the associated risk of getting sued on faulty/outdated data) Crypto Risk Metrics steps in as a provider if these white papers.

If you are interested in requesting our services, please inquire here.

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FAQ

Do you have a question that is not answered here? Please reach out and we will happy to answer any question you might have.

We are not a trading platform but provide different services in relation to crypto-assets. Do we need white papers, too?

According to the ESMA Statement (ESMA75-223375936-6099), only companies that provide the following services are required to publish white papers:

  • Receipt and transmission of crypto asset orders
  • Execution of crypto asset orders on behalf of clients
  • Exchange of crypto assets for fiat money or other crypto assets

In our opinion, this means that the mere custody of crypto assets would not be affected by the obligation – but all “trading-like” services would be.

We heard that article 143 concerning the grandfathering clause is only applicable to trading platforms. What does that mean of us, if we are a broker, for example?

By referring to Article 143 exclusively in relation to trading platforms, all other crypto asset services are not covered by this article and therefore cannot benefit from the transition period. As a result, white papers are required immediately for all crypto assets.

In our opinion, this wording was an unintended “side effect” of the reference to trading platforms – nevertheless, it appears to correspond to the current legal situation.

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