Can MiCA ESG Disclosures Be Network-Level?
MiCA sustainability disclosures raise a simple but important question for the market:
If a token is built on an existing blockchain, can it comply by reporting only network-level environmental data?
For example, should a white paper disclose the environmental footprint of a token itself, or that of the underlying network it relies on?
At first glance, the regulatory wording may seem to support a network-level approach. Both MiCA and CDR 2025/422 refer to sustainability indicators “of the consensus mechanism”.
This has led some market participants to assume that reporting at the blockchain level may be sufficient.
The problem with that interpretation
If this were correct, all tokens built on the same network would disclose identical environmental metrics.
This would mean that:
- tokens with very different levels of activity
- tokens relying on different scaling layers
- tokens with different operational footprints
would all report the same sustainability data.
This raises an obvious question: Is this really what the regulation intends?
The key takeaway
A closer reading of MiCA and CDR 2025/422 suggests otherwise.
Sustainability disclosures must ultimately be asset-level.
While environmental impacts originate from the consensus mechanism, the disclosure obligation applies to each crypto-asset.
This distinction is critical for ensuring that disclosures remain meaningful, comparable, and aligned with the intent of the regulation.
Why this matters
Getting this wrong is not just a technical issue.
A purely literal interpretation can lead to disclosures that are formally compliant but fail to reflect the actual environmental footprint of the crypto-asset.
This creates:
- comparability issues
- misleading disclosures
- potential regulatory risk
Read the full analysis
The MiCA Crypto Alliance has published a detailed report examining this issue, including:
- interpretation of MiCA and CDR 2025/422
- analysis of Recitals 1 and 8
- practical implications for white papers and CASPs
- a structured approach to asset-level attribution
Download the report: Blockchain-Level vs Asset-Level ESG Disclosures Under MiCA
Request ESG Support
The MiCA Crypto Alliance prepares ESG datasheets fully aligned with Articles 6, 19, 51 and 66(5) of Regulation (EU) 2023/1114 and CDR 2025/422.
Datasheets are available as standalone deliverables or as part of a full white paper package, and may also be used to support sustainability disclosures published by crypto-asset service providers.
If you require support with MiCA sustainability disclosures, request your ESG datasheet via this form.
