One Year of Building MiCA Compliance Infrastructure for Europe’s Crypto Market
Over the past year, the MiCA Crypto Alliance, an Exponential Science initiative, has evolved from an early-stage effort into an operational pillar of MiCA compliance in Europe. What began with a small team and limited public presence has grown into a multidisciplinary organisation delivering MiCA-compliant white papers, sustainability and ESG data, public infrastructure, and regulatory engagement at scale.
This recap highlights the work delivered across white paper preparation, sustainability reporting, structured data, policy engagement, and ecosystem coordination over the past twelve months. It reflects what the Alliance built, the implementation challenges it addressed, and the role it now plays in supporting MiCA’s application across the European crypto market.
Delivering MiCA Compliance in Practice
At the start of the year, the Alliance’s work centred on building a network of technical, legal, and sustainability experts and supporting early educational efforts around the upcoming MiCA requirements. This phase focused on clarifying regulatory expectations, developing shared understanding across stakeholders, and laying the groundwork for sustainability reporting and white paper preparation under MiCA.
Over the course of the year, this developed into a structured MiCA compliance capability. The Alliance moved from having a small number of draft documents to delivering regulator-facing white papers that support regulatory submission, exchange listings, and ongoing disclosure obligations under MiCA.
This involved establishing consistent production and review frameworks and applying them across MiCA white papers covering multiple crypto-asset categories, including e-money tokens (EMTs), asset-referenced tokens (ARTs), and crypto-assets other than asset-referenced tokens and e-money tokens (OTHR). White papers prepared through this process supported continued market access through regulatory review and submission by issuers and service providers.
By the end of the year, the Alliance had supported the writing of more than 58 MiCA-compliant white papers and developed a suite of standardised disclosure templates used across multiple ecosystems.
A key milestone was the update and enhancement of MiCA white papers for Circle’s USDC and EURC. This work introduced best-in-class mandatory and supplementary sustainability disclosures, aligned with the final MiCA technical standards, and deployed the Alliance’s leading XBRL and iXBRL formatting standards for structured, machine-readable reporting. Through this process, Circle became among the first global stablecoin issuers to completely meet MiCA requirements, setting a clear benchmark for the market.
The publication of the HBAR MiCA white paper also marked an important milestone for the Hedera ecosystem. The MiCA Crypto Alliance independently authored and published the official MiCA white paper for HBAR, providing a detailed, regulator-facing disclosure for a Layer-1 network under MiCA and positioning Hedera as the leading Layer-1 in regulatory compliance in Europe.
This delivery work was supported by comparative and diagnostic analysis of MiCA disclosure practices across the market. Over the year, the Alliance examined how white paper requirements differ across crypto-asset categories, assessed the quality and consistency of stablecoin disclosures by major issuers, and analysed both the sequencing of MiCA obligations and the gap between public claims of readiness and the actual standard of documentation delivered in practice.
Together, this work provided concrete benchmarks for issuers and service providers, informed internal delivery standards, and helped distinguish formal compliance from genuinely regulator-ready disclosure.
MiCA Sustainability and ESG Disclosure Frameworks
The Alliance built a dedicated sustainability and ESG data capability aligned with MiCA’s sustainability indicator requirements, supported by a published technical standard setting out the methodologies used to calculate indicators under the applicable implementing and delegated rules.
As part of this work, the Alliance assembled the largest MiCA-aligned sustainability dataset currently used for crypto-asset disclosures, covering more than 1,200 crypto-assets.The dataset spans energy consumption and greenhouse gas emissions, as well as wider environment-related indicators, including water, waste, natural resources, land use, and intensity measures. No other provider currently offers sustainability coverage at this level of breadth, depth, and regulatory alignment for MiCA disclosures.
The methodologies developed by the Alliance support standardised, comparable sustainability reporting across fundamentally different crypto-asset designs, including Layer-1s, Layer-2s, and assets that are not yet minted or launched. This enables sustainability disclosures to be prepared consistently across the full range of crypto-assets subject to MiCA.
The Alliance also developed industry-leading Bitcoin energy and emissions models, published scenario-based analysis of Bitcoin’s carbon footprint to 2030, and released Bitcoin ESG data sheets illustrating how MiCA-aligned sustainability indicators apply to proof-of-work systems. The Alliance is the only sustainability data provider currently measuring and disclosing renewable energy usage, off-grid mining, and methane-mitigation activity for Bitcoin within a MiCA-aligned framework, using methodologies aligned to academic standards such as the Cambridge Centre for Alternative Finance (CCAF). This work has been independently validated and cited externally, reinforcing the Alliance’s position as the reference provider for Bitcoin sustainability disclosures under MiCA.
The Alliance has also committed to maintaining and updating this work on an ongoing basis, including regular updates to Bitcoin mining metrics as underlying data and market conditions evolve.
Beyond asset-level disclosures, the Alliance also published policy-relevant sustainability research addressing systemic and methodological challenges in crypto-asset sustainability assessment. This included analysis of the environmental impact of ASIC-resistant consensus designs and research on the unintended carbon consequences of Bitcoin mining bans, demonstrating how design choices and poorly calibrated policy interventions can increase energy intensity or shift emissions rather than reduce them.
Together, these publications reinforced the Alliance’s position that MiCA sustainability indicators must be applied with technical accuracy and contextual understanding, ensuring they promote best practices in disclosure rather than mischaracterise network behaviour or produce misleading comparisons.
As a result, the Alliance’s sustainability data has been used directly in MiCA white papers and ecosystem disclosures and has informed regulatory dialogue on how sustainability indicators should be applied in practice. This included the Alliance’s formal contribution to the European Commission’s MESMERICE study, where it provided detailed methodological input to ensure that sustainability metrics under MiCA are technically accurate, proportionate, and fit for purpose—supporting best practices in disclosure rather than mischaracterising or disproportionately penalising crypto-asset networks.
Structured Reporting and iXBRL Rendering
As MiCA’s structured reporting requirements began to take shape, the Alliance assumed a leading role in the practical implementation of XBRL for crypto-asset disclosures, combining regulatory analysis, technical execution, and live delivery under MiCA timelines.
In September 2025, it was invited by ESMA to provide technical feedback on the MiCA XBRL implementation package, including the taxonomy and the conversion tooling made available to preparers. The Alliance’s feedback, published separately, reflected early hands-on analysis of how MiCA’s structured reporting requirements would operate in practice.
Building on this engagement, the Alliance developed operational capability to prepare MiCA white papers in inline XBRL (iXBRL), aligned with Commission Implementing Regulation (EU) 2024/2984 and ESMA’s published taxonomy. This work focused on ensuring that machine-readable disclosures are prepared consistently with the underlying legal requirements and remain aligned with the human-readable content of each white paper.
The Alliance also hosted a dedicated webinar on preparing HTML and iXBRL white papers, using real implementation experience to define and promote best practices. The session was not limited to explaining regulatory requirements. It was designed to help issuers, service providers, and regulators understand the practical difference between meeting the bare minimum and producing high-quality disclosures in practice.
In particular, the webinar contrasted simple, static files that technically satisfy format requirements but remain difficult to process, with properly structured, interactive iXBRL documents that are easier for regulators to analyse and more usable for readers. Drawing on live examples, it demonstrated how disciplined tagging, alignment between human-readable and machine-readable content, and integrated sustainability disclosures materially affect review efficiency, supervisory clarity, and the overall quality of MiCA submissions. This positioned structured reporting not as a box-ticking exercise, but as a core regulatory reporting discipline under MiCA.
By year-end, the Alliance was delivering iXBRL-formatted MiCA white papers in practice and supporting issuers, CASPs, and exchanges as MiCA moves into a stricter phase of operational application. To date, the Alliance has converted and delivered 14 MiCA white papers in inline XBRL, demonstrating live operational capability.
This capability was further demonstrated through the delivery of multiple iXBRL white papers under tight regulatory timelines, including a batch of crypto-asset white papers within the Chiliz ecosystem. The work involved processing multiple documents in parallel and delivering regulator-ready, machine-readable disclosures under significant time constraints, demonstrating the Alliance’s ability to scale iXBRL delivery as MiCA requirements take effect.
Market Infrastructure: The MiCA White Paper Tracker
As part of its work to support MiCA implementation, the Alliance developed and maintains the MiCA White Paper Tracker, a public registry designed to improve transparency and comparability of crypto-asset disclosures across the European market.
The Tracker, now in its second major version, is a continuously updated database covering more than 700 publicly available MiCA white papers. It analyses disclosure quality and compliance readiness using a transparent scoring methodology aligned with MiCA’s white paper requirements under Titles II, III, and IV, with approximately 250 documents scored to date.
Building on information published through the ESMA registry, the Tracker intentionally expands the available dataset. It includes white papers that have been published but not yet submitted to a national competent authority, preserves full version histories where documents are updated or replaced, and retains records of white papers that have been removed from ESMA’s published datasets. Locally stored copies of documents ensure continuity and comparability over time, rather than relying on external links that may change or disappear.
The Tracker also provides significantly improved navigation and filtering, enabling users to explore disclosures by asset type, author, submission status, and document version. Together, these features offer a more complete and practical view of how MiCA white paper requirements are being implemented in practice and how disclosure quality is evolving across the market.
By making this information accessible and comparable, the MiCA White Paper Tracker has become a key reference for issuers, service providers, exchanges, and policymakers seeking to understand MiCA readiness and disclosure standards across the crypto-asset ecosystem.
Policy Engagement and Regulatory Dialogue
The Alliance has played an active role in MiCA-related policy discussions, combining thought leadership with direct engagement across EU, UK, and international regulatory processes. This included sustained participation in public and industry discussions, with 18 in-person speaking engagements, 6 webinars, and 5 podcasts spanning regulatory, academic, and technical audiences.
At EU level, the Alliance participated in policy and expert discussions related to MiCA implementation. This included participation in European Commission roundtables, engagement through the DARTE roundtable series, and the submission of a formal response to the MESMERICE study led by Trinomics on behalf of the European Commission. These forums provided opportunities to engage with regulators, legal experts, and market participants on emerging implementation questions as MiCA moved from legislative design into application.
This policy engagement was reinforced through the Alliance’s contributions to the DARTE Roundtable Series, organized by BlackVogel and siedler legal, whose published reports consolidate expert discussion into implementation-focused analysis. As a core contributor to multiple roundtables, the Alliance helped shape published outputs addressing MiCA implementation challenges, market integrity considerations, the classification of liquid staking arrangements, and legal uncertainty in the application of Title II MiCAR.
In parallel, the Alliance engaged extensively with UK regulators as the UK develops its post-MiCA framework. Together with the UK Centre for Blockchain Technologies (UK CBT), it submitted joint responses to the Financial Conduct Authority’s Discussion Paper DP25/1 and Consultation Paper CP25/25, addressing decentralisation, governance and conduct standards, operational resilience, and ESG requirements for crypto-asset firms, while emphasising the importance of interoperability with MiCA to avoid regulatory fragmentation.
At national level, the Alliance supported MiCA compliance through the drafting, review, updating, and notification of white papers to National Competent Authorities (NCAs). This included notifications and submissions involving multiple jurisdictions, including the Financial Markets Authority (AFM), the Federal Financial Supervisory Authority (BaFin), the Central Bank of Ireland (CBI), and the Malta Financial Services Authority (MFSA), among others. Where applicable, white papers prepared with the Alliance’s support were successfully accepted by regulators as part of MiCA notification processes.
The Alliance also met with supervisory authorities, including the European Securities and Markets Authority (ESMA), the Austrian Financial Market Authority (FMA), and the Swedish Financial Supervisory Authority.
In addition, the Alliance played an active role through Blockchain for Europe, acting as co-chair of the non-financial working group and as an active participant in the MiCA working group.
Taken together, this body of work reflects a progression from participation in policy dialogue to recognised thought leadership on MiCA implementation. The Alliance’s engagement increasingly focused on concrete supervisory and implementation challenges, reinforcing its role as a constructive and technically grounded interlocutor in evolving regulatory practice.
Building a Network and Coordinating Implementation
The Alliance has established a durable network of organisations operating across the MiCA-regulated digital assets ecosystem. It supported approximately 70 direct and indirect clients and worked with around 40 members and partners, spanning protocol ecosystems, token issuers and offerors, CASPs, exchanges, and law firms.
The Alliance has become a partner of choice for major Layer-1 networks, such as Cardano Foundation, DFINITY Foundation (Internet Computer), Xinfin (XDC Network), Hedera, Aptos, and the XRP Ledger (XRPL) ecosystem.
It also works closely with vertically integrated blockchain ecosystems, including Chiliz and Cronos Labs, where MiCA implementation spans protocol infrastructure, native assets, and multiple application-level tokens.
At the market access layer, the Alliance also works closely with exchanges and CASPs, including YouHodler, SaucerSwap, Ahora Crypto, and One Trading, supporting white paper preparation, sustainability disclosures, and structured reporting.
Legal partnerships form a critical pillar of this network. The Alliance works closely with law firms across multiple jurisdictions, including Lexify, WH Partners, Asensi Abogados, and DLA Piper, with additional firms expected to join in 2026. These partnerships are essential to MiCA implementation in practice: law firms act as multipliers, embedding the Alliance’s technical, sustainability, and reporting standards into client engagements across multiple issuers and service providers. They also contribute local regulatory insight, helping ensure consistency and credibility across jurisdictions while reducing duplication of effort for market participants.
Building on this network, the Alliance launched targeted initiatives to address shared implementation challenges under MiCA.
One such initiative is the taxonomy project on decentralised assets and liquid staking tokens (LSTs). The project addresses ongoing uncertainty around the classification of decentralised assets under MiCA, particularly where assets lack a central issuer, generate yield, or do not fit cleanly within existing categories. By combining academic research with industry review, it aims to deliver a structured, submission-ready taxonomy framework to support more consistent regulatory interpretation across Member States.
In parallel, the Alliance launched the Future of Banking and Digital Assets initiative, examining how European banks are preparing for MiCA and related sustainability obligations. Through surveys, interviews, and closed-door roundtables with institutions and regulators, the initiative explores licensing strategies, governance, white paper obligations, and the integration of digital assets into CSRD and ESG reporting frameworks, generating evidence-based insights to support regulatory dialogue and emerging industry standards.
The Alliance also introduced an Ambassador Programme to support informed, local-level engagement with MiCA across European cities. The programme enables trusted professionals to convene practitioners, legal experts, and market participants locally, organise structured events aligned with the Alliance’s mission, and surface jurisdiction-specific implementation questions, connecting central policy work with local market realities across Europe.
Together, these initiatives illustrate how the Alliance functions as a platform for coordination and shared problem-solving under MiCA. By combining research, industry participation, and structured engagement formats, the Alliance supports more consistent interpretation of regulatory requirements and helps translate MiCA’s legal framework into operational practice.
Looking Ahead
Over the past year, the MiCA Crypto Alliance moved from early research and exploratory work to operating at the centre of MiCA implementation in practice. Across white paper preparation, sustainability data, structured reporting, policy engagement, and ecosystem coordination, the Alliance focused on turning regulatory requirements into usable standards, processes, and tools.
As MiCA continues to phase in through 2026, the Alliance enters its next phase with proven delivery capability, an established network of market participants and regulators, and infrastructure designed to support scale and consistency. The work completed over the past twelve months provides a practical foundation for the next phase of Europe’s regulated crypto market.
