When MiCA white papers are required, mandatory content, iXBRL format, marketing rules, retail withdrawal rights, and issuer liability.
A white paper is required when offering crypto-assets to the public in the EU or seeking admission to trading on an EU trading platform, unless a specific exemption applies (e.g. offer to fewer than 150 persons per member state, total consideration under 1M euros over 12 months, or qualified investors only).
From 23 December 2025, Commission Implementing Regulation (EU) 2024/2984 requires a single Inline XBRL (iXBRL) XHTML file using the ESMA MiCA taxonomy, not a standalone PDF as the supervisory filing format.
The offeror, person seeking admission to trading, or operator of the trading platform (as applicable) is liable to holders for losses from inaccurate or misleading information in the white paper, subject to MiCA liability provisions.
Yes. Retail holders generally have a withdrawal right within a defined period after the offer, unless the crypto-asset is already admitted to trading on a regulated platform.
No. Confirmed by the European Commission via ESMA Q&A 2671 (21 May 2026). If a crypto-asset is solely admitted to trading on a platform operated by a service provider established outside the Union, and is not otherwise offered to the public in the EU, no white paper obligation arises under Article 4(1). The Article 4(4) override, which neutralises the Art. 4(2)-(3) exemptions when admission to trading is intended, applies only to admission on EU-licensed (MiCA-authorised) platforms. However, listing on a DEX that operates within the EU could itself amount to an offer to the public. Fully decentralised protocols with no intermediary are outside MiCA scope per Recital 22, but whether a platform is truly fully decentralised is assessed case-by-case by the competent authority.
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