MiCA whitepaper requirements: Article 6 and Annex I

The Annex I content: Parts A to I

Article 6(1) lists the content headings (a) to (j); headings (a) to (i) map to the lettered Annex I Parts, and heading (j) is the environmental disclosure. Parts B and C are conditional — B applies only where the issuer differs from the offeror, C only where a trading-platform operator drafts the whitepaper.

1. A. The offeror or person seeking admission to trading

   Art. 6(1)(a), Annex I Part A

   Name, legal form, registered address and head office, date of registration, Legal Entity Identifier, contact details with a stated response-time period, parent company where applicable, the management body, the business activity, and a fair review of the financial condition over the past three years.

2. B. The issuer, if different from the offeror

   Art. 6(1)(b), Annex I Part B

   A lighter identity block — name, legal form, address, registration date, LEI, parent company, management body and business activity — rendered only where the issuer is not the offeror or admission-seeker.

3. C. The operator of the trading platform, where it drafts

   Art. 6(1)(c), Annex I Part C

   The operator's identity block plus the reason it drew up the whitepaper — rendered only on the operator-drafting path.

4. D. The crypto-asset project

   Art. 6(1)(d), Annex I Part D

   Project and token name, ticker, a brief description, the persons involved in implementation, past and future milestones, and the planned use of funds collected. Where utility tokens are involved, the key features of the goods or services to be developed.

5. E. The offer to the public or admission to trading

   Art. 6(1)(e), Annex I Part E

   Whether it is an offer or an admission, the reasons for it, the amount targeted and any subscription goals, the issue price, the number of tokens, the targeted holders, the reimbursement notice and refund mechanism, the offer phases, the subscription period, safeguarding arrangements (Art. 10), payment methods, the right of withdrawal (Art. 13), the transfer schedule, technical requirements, any placing CASP, the trading platform, expenses, conflicts of interest and the applicable law.

6. F. The crypto-asset

   Art. 6(1)(f), Annex I Part F

   The type of crypto-asset and a description of its characteristics — including the data needed to classify the whitepaper in the ESMA register — and its functionality, including planned functionalities.

7. G. Rights and obligations attached to the crypto-asset

   Art. 6(1)(g), Annex I Part G

   The rights and obligations of the holder and how to exercise them; conditions for modifying them; future offers and tokens retained by the issuer; for utility tokens, the quality and quantity of goods or services and how they are redeemed; transferability restrictions; supply-adjustment protocols; protection and compensation schemes; and the applicable law.

8. H. The underlying technology

   Art. 6(1)(h), Annex I Part H

   The technology, DLT, protocols and standards used; the consensus mechanism (which feeds the sustainability disclosure); incentive mechanisms and fees; a detailed description of the DLT where operated by or for the issuer; and the outcome of any technology audit.

9. I. The risks

   Art. 6(1)(i), Annex I Part I

   Risks associated with the offer or admission, the issuer if different, the crypto-asset, project implementation, and the technology used together with any mitigation measures.

10. Sustainability (environmental) disclosure

    Art. 6(1)(j), Del. Reg (EU) 2025/422

    The principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism. Total annual electricity consumption is always mandatory; a supplementary set of indicators is triggered above 500,000 kWh per year (Del. Reg (EU) 2025/422). This is an Article 6(1)(j) content item, not a lettered Annex I Part — Annex I ends at Part I.

The mandatory statements (Article 6(3)-(7))

Article 6 requires fixed statutory statements in a set order. These are prescribed legal copy — the exact wording is lifted from the Official Journal and is not editable content.

• No-approval / sole-responsibility statement

  Art. 6(3)

  A clear and prominent statement on the first page that no competent authority has approved the whitepaper and that the offeror (or admission-seeker, or operator) is solely responsible for its content.

• No future-value assertions

  Art. 6(4)

  The whitepaper must contain no assertions about the future value of the crypto-asset, other than the Article 6(5) statement.

• Clear and unambiguous risk statement

  Art. 6(5)(a)-(f)

  A six-limb statement that the crypto-asset may lose value, may not be transferable, may not be liquid, that a utility token may not be exchangeable for the promised good or service, and that it is covered by neither investor-compensation nor deposit-guarantee schemes.

• Management-body statement

  Art. 6(6)

  A statement from the management body, inserted after the no-approval statement, confirming Title II compliance and that the information is fair, clear and not misleading with no material omission.

• Summary warning

  Art. 6(7)(a)-(d)

  A four-limb warning in the summary: read it as an introduction, decide on the whole whitepaper, the offer is not a financial-instrument solicitation, and the whitepaper is not a prospectus under Regulation (EU) 2017/1129.

Notification, not approval

The 'other' crypto-asset regime is notify-and-publish. There is no positive clearance, but supervision and strict liability remain.

• 20 working days before publication

  Art. 8

  Notify the whitepaper and marketing communications to the home Member State's competent authority at least 20 working days before publication, with the list of host Member States and the intended publication date.

• No approval, but reactive powers

  Art. 8, Art. 109

  The authority does not approve the whitepaper. It retains power to require amendments, suspend or prohibit the offer where MiCA is breached, and notified whitepapers are entered in the public ESMA register.

• Publish and keep accessible

  Art. 9

  Publish on the offeror's, admission-seeker's or operator's website before the offer or admission begins, and keep it accessible while the crypto-assets are held by the public.

Tokenpaper turns a qualifying offer into a filing-ready whitepaper — guided Annex I intake, the mandatory statements, and validated Inline XBRL. Software, not legal advice; the issuer stays liable under Article 15. See Tokenpaper.

Frequently asked questions