MiCA Compliance in Practice: Article 92, Trade Surveillance, White Papers, and ESG Disclosures
The MiCA Crypto Alliance partnered with Atoma Studio to host a dedicated webinar on how crypto asset service providers can operationalise MiCA Article 92. With MiCA now in force and a growing number of licences already issued across the EU, firms are turning their attention to ensuring their surveillance, documentation and sustainability systems meet regulatory standards.
Understanding Article 92 and Market Abuse Obligations
Atoma Studio opened the session with an overview of what Article 92 requires from CASPs. The regulation places clear responsibility on firms to detect, flag, and document potential market abuse. This includes behaviours such as wash trading, spoofing, pump and dump schemes, front running, and the dissemination of misleading information.
A central message from Atoma was that regulators expect surveillance processes to be real time, auditable, and accompanied by clear escalation workflows. Many CASPs have historically relied on fragmented or in house systems, which are difficult to scale and maintain. Atoma presented its purpose-built, plug-and-play solution, designed to simplify trade surveillance and reduce false positives.
A practical example came from its collaboration with Safello. The firm integrated Atoma during its MiCA licensing process and recently received regulatory approval. The case illustrates that a system alone is insufficient. Effective governance, clear internal responsibilities, and risk-based rules are as important as the technical solution itself.
Documentation and ESG Disclosures under MiCA
The second pillar of MiCA focuses on documentation and sustainability disclosures. The MiCA Crypto Alliance supports both CASPs and issuers with MiCA-compliant white papers, issuer liability requirements under Article 15, ESG indicators, and XBRL/iXBRL rendering, which ESMA has stated will be mandatory starting from 23 December 2025.
Every token admitted to trading must be accompanied by a standardised white paper covering governance, technology, risk factors, and sustainability metrics. CASPs must review this documentation when listing assets, even if they are not the issuer. ESG indicators are now embedded within the white paper, and a defined calculation methodology is required. The Alliance uses its own established methodology, which underpins its ESG datasets and provides a consistent approach across mandatory, supplementary, and optional indicators.
The Alliance delivers these documentation services at scale, having supported more than 50 MiCA white papers and ESG disclosures. Its ESG dataset now spans more than 1,200 assets, providing consistent and up-to-date indicators across mandatory, supplementary, and optional categories.
Beyond direct support, the Alliance contributes to wider industry coordination. This includes formal input to ESMA on XBRL implementation and a standardisation initiative for liquid staking tokens. Participants were invited to join the working group as it enters its final stages.
Looking Ahead
MiCA introduces a new level of regulatory clarity for crypto markets, and firms that invest early in surveillance, documentation, and sustainability processes will be well positioned for CASP authorisation from their national regulators. The MiCA Crypto Alliance will continue to work with partners across Europe to support compliance, share best practices, and help raise standards across the industry.
If you would like to learn more about Atoma Studio’s trade surveillance system or the Alliance’s work on MiCA disclosures, our teams welcome further conversations.
Watch the recording of the webinar: https://youtu.be/oZGS9BPclFo
