Have We Overregulated? Reflections on MiCA Implementation from DAF3

Frequently Asked Questions
A MiCA white paper is not the same as a project whitepaper.
A traditional crypto whitepaper may explain a protocol, tokenomics, roadmap or community vision. A MiCA white paper is a regulatory disclosure document. It must follow prescribed content requirements and, depending on the category of token, cover information on the issuer, offeror or person seeking admission to trading, the project, the offer or admission, the crypto-asset, rights and obligations, underlying technology, risks, and adverse impacts on climate and the environment. MiCA’s rulebook lists separate content provisions for OTH tokens, ARTs and EMTs: Article 6, Article 19 and Article 51 respectively.
There are also technical format requirements. Commission Implementing Regulation (EU) 2024/2984 and Commission Delegated Regulation (EU) 2025/422 lay down standard forms, formats and templates for crypto-asset white papers, and explains that the white paper framework is intended to make white papers available in machine-readable format. The implementing regulation also requires crypto-asset white papers to be drawn up in XHTML format with Inline XBRL tagging of the relevant fields.
This means a MiCA white paper project usually has four workstreams: legal classification, regulatory drafting, technical and sustainability data collection, and XHTML/iXBRL production.