MiCAR Crypto Asset Types
Summary of each of the three crypto asset types under MiCAR
Introduction
MiCAR (Regulation (EU) 2023/1114) establishes a harmonized EU framework for crypto-assets, including EMTs, ARTs, and all other crypto-assets, with mandatory machine-readable white papers in Inline XBRL (iXBRL). These disclosures support investor protection, comparability, and supervisory oversight.
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Disclaimer
Crypto-asset regulations, including MiCAR (Regulation (EU) 2023/1114) and its Implementing Technical Standards (ITS), are highly fluid and are expected to evolve rapidly. Updates to MiCAR or related legislation may occur frequently, potentially creating inconsistencies between this guide, the ITS, and the official texts. We do not provide legal analysis or advice on regulation or any amendments or interpretations thereunder. Always consult qualified legal counsel for your specific circumstances.
E-Money Tokens (EMT) - Table 4
EMTs are crypto-assets designed to function as digital equivalents of electronic money, maintaining a stable value tied to a single official currency. Under Article 3(5) of MiCAR, an EMT:
qualifies as electronic money under Directive 2009/110/EC,
represents a claim on the issuer,
is issued and redeemed at par value,
provides holders with an unconditional redemption right in fiat.
Key features include:
No interest or remuneration (Article 50)
Full reserve backing in the reference currency, with segregation and strict liquidity requirements (Article 54)
Permanent par-value redemption right (Article 55)
Issuance restricted to credit institutions or electronic money institutions (Article 48)
Prudential and governance requirements including own funds (minimum €350,000 or 2% of reserve assets; Article 35)
Significant EMTs are supervised directly by the EBA under Articles 56–57.
Machine-Readable White Paper Requirements for EMTs
EMT white papers follow Article 51 and the ITS Table 4 template, requiring:
Fair, clear, non-misleading disclosures
Mandatory warnings, management statements, and summary
Issuer identity, authorization status, governance, and third-party involvement
EMT characteristics, stabilization mechanism, redemption conditions
Technology, DLT, audit outcomes
Detailed reserve composition
Risk disclosures and sustainability indicators
Machine-readable requirements (ITS):
Format: Single XHTML document with Inline XBRL 1.1
Identifiers: LEI for issuers/CASPs, DTI for tokens, ISIN for reserve assets, MIC for trading platforms
Validation: ESMA taxonomy including all Table 4 elements
Publication: On issuer website (from 23 Dec 2025) with archived versions
Asset-Referenced Tokens (ART) - Table 3
ARTs are stablecoins referencing a basket of assets, excluding those referencing a single fiat currency (which are EMTs). Under Article 3(4), an ART:
is used as a means of exchange,
aims at stability through a reserve basket,
is not electronic money and not a money-market fund.
Key features:
Full reserve backing in diversified, low-risk assets (Article 36)
No interest or remuneration (Article 40)
On-demand redemption rights (Article 39)
Issuance authorization under Article 16
Own funds and governance requirements (Articles 34–35)
Enhanced EBA supervision for significant ARTs (Articles 43, 46–47)
Quarterly reporting obligations to home authorities (Article 22)
Machine-Readable White Paper Requirements for ARTs
ART white papers follow Article 19 and the ITS Table 3 template, requiring:
Statement of compliance, warnings, and summary
Issuer identification, governance, registration, and authorization
Stabilization mechanism, reserve policies, custody arrangements
Technology, DLT usage, audits
Risks including reserve volatility, de-pegging, and governance risks
Sustainability indicators
Machine-readable structure:
Format: XHTML + Inline XBRL 1.1
Table 3 fields: issuer details, token characteristics, stabilization, reserves, offer conditions, sustainability
Identifiers: LEI, DTI, MIC
Validation: ESMA taxonomy for Table 3 fields
Publication: Open website access (from 23 Dec 2025)
Other Crypto-Assets (OCA) - Table 2
OCAs are any crypto-assets not classified as EMTs or ARTs. This includes utility tokens, NFTs (unless they qualify as fungible), and other digital assets without stabilization mechanisms.
Under Article 3(1)(2), OCAs are digital representations of value or rights transferable via DLT, excluding financial instruments, deposits, and funds (per Article 2(4)).
Key features:
No reserve or redemption obligations
White paper required for public offers or trading admissions (Articles 4–6, 8–9) unless exempted
Exemptions include small offers (<€1 million), offers to <150 persons, free distributions, or limited networks (Article 4)
Custody safeguards for fiat or crypto received from purchasers (Article 10)
14-day withdrawal right for retail investors (Article 13)
Environmental impact disclosures (Article 66(5))
Machine-Readable White Paper Requirements for OCAs
OCA white papers follow Articles 6 & 8 and the ITS Table 2 template, requiring:
Disclaimer (no approval by authorities)
Management statement
Non-technical summary
Offeror/issuer information
Project description, token functionality, technology, audits
Rights, obligations, risks
Sustainability indicators
Machine-readable structure includes:
Format: XHTML + Inline XBRL 1.1
Table 2 fields: offeror/issuer identity, utility, offer terms, DLT details, risks, sustainability
Identifiers: LEI, DTI, MIC
Validation: ESMA taxonomy for Table 2
Publication: Public website access from 23 Dec 2025
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