- within Technology topic(s)
- in China
- within Energy and Natural Resources, Employment and HR and Real Estate and Construction topic(s)
New format requirements for crypto-asset white papers under the EU Markets in Crypto-Assets Regulation (MiCA) will take effect on 23 December 2025. From that date, crypto-asset white papers will be required to comply with machine-readable format requirements. PDF-only submissions will no longer meet regulatory requirements.
These new obligations arise from Commission Implementing Regulation (EU) 2024/2984, which specifies the format, structure and technical templates applicable to MiCA crypto-asset white papers. This Implementing Regulation mandates the use of eXtensible Business Reporting Language (XBRL), and more specifically, Inline XBRL (iXBRL), for all white papers notified or submitted under MiCA.
What Does "Machine-Readable" Mean
A machine-readable document is one whose content can be automatically processed, extracted, and validated with software systems without manual interpretation.
While various file formats may technically be machine-readable, the Implementing Regulation expressly requires crypto-asset white papers to be drafted in XHTML format using Inline XBRL specifications. Inline XBRL allows the white paper to remain readable as a continuous narrative while embedding structured, machine-readable tags within the text, enabling regulators to identify and process individual data points at a granular level.
What is (and is NOT) Changing
The machine-readability requirement does not change the substantive disclosure obligations under MiCA. Issuers and/or offerors remain subject to the same underlying transparency, risk disclosure and information requirements set out in Titles II, III and IV of MiCA.
What does change is the form and structure of disclosure. The Implementing Regulation introduces binding templates and taxonomy-based fields that must be followed strictly. Responses must align precisely with the prescribed structure and data definitions, including the use of standardised values for certain fields. As a result, the internal consistency and technical structuring of a white paper become legally consequential, even where the substantive content is accurate.
The MiCA White Paper Taxonomy Framework
The MiCA taxonomy incorporates automated validation rules that assess the completeness, consistency and identification data of a white paper. A submission may be flagged or rejected at a technical level notwithstanding substantively accurate disclosures, while conversely passing technical validation does not, in itself, guarantee legal compliance with MiCA.
Practical Implications and Key Takeaways
From 23 December 2025, white papers must be submitted in Inline XBRL (XHTML) format and be linked to a valid Legal Entity Identifier (LEI), which will be subject to automated verification. Disclosures must be reported within their designated taxonomy fields, as mis-tagging or structural misalignment may trigger validation failures regardless of substantive accuracy. While tooling may support the technical preparation of submissions, regulatory responsibility for compliance remains with the issuer.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]
