A Comparative Analysis of MiCA Regulatory Requirements for OTH, EMT, and ART White Papers
The MiCA Crypto Alliance has released a new report offering a structured comparison of MiCA’s white paper requirements for other tokens (OTH), e-money tokens (EMT), and asset-referenced tokens (ART). This is the first time these indicators have been mapped side by side in a clear, visual format.
The analysis highlights both overlaps and divergences, while also pointing to structural inconsistencies that make compliance more complex than necessary. Many disclosure requirements appear across token types, but they are labelled differently, placed in separate sections, or omitted without clear justification. This creates unnecessary friction for issuers, complicates legal reviews, and introduces ambiguity for regulators.
Key findings include:
- Contact details are required for OTH and EMT, but not for ART
- Redemption rights appear in ART and EMT, but formatting varies
- Section numbers and labels shift between token categories
- ARTs carry the heaviest disclosure load, but lack clarity in areas such as governance and reserves
The report concludes that MiCA sets a valuable foundation, but its application still leaves room for improvement. Better templates, clearer formatting, and more consistent requirements would reduce costs, improve usability, and strengthen regulatory outcomes.
This work is intended to support token issuers, CASPs, compliance teams, and regulators alike by bridging the gap between policy design and real-world implementation.
