Which MiCA Obligations Apply to Your Service? A Reference for CASPs
Under MiCA, the obligations a crypto-asset service provider carries are not uniform across the board. They depend on the specific service being provided. A custody provider, an exchange, and a portfolio manager each sit in a different position when it comes to sustainability disclosures, white paper link obligations, and whether the white paper requirement is triggered at all.
This is one of the more common sources of confusion in practice. Firms hold authorisation for several services at once, and the documentation and disclosure duties attached to each are easy to conflate. The table below sets out, service by service, how three distinct obligations apply.
The three obligations
The framework distinguishes three separate questions, and a single service can answer them differently.
- Sustainability indicators, Article 66(5). The obligation to disclose climate and environmental information on the crypto-assets a provider deals in. This applies across every CASP service. Whatever the licence, the sustainability disclosure duty is present.
- White paper links, Article 66(3). The duty to provide a link to the relevant white paper for each crypto-asset the provider handles. How this applies depends on whether a white paper exists for the asset, and the obligation differs across services accordingly.
- The white paper requirement itself, Articles 4 and 5. Whether the activity triggers the obligation to draw up a white paper in the first place. For most services this turns on whether the CASP has a trading platform licence or whether the crypto-asset service, if not the offering of a trading platform, constitutes an offer to the public, which is a case-by-case assessment.
How the obligations apply, by service
The table maps all ten CASP services against the three obligations. It reflects the Alliance's structured reading of the relevant MiCA provisions and the European Commission's clarifications in ESMA Q&As 2654 and 2404. Several entries turn on case-by-case tests, noted in the table.
A few patterns are worth drawing out.
- Sustainability disclosure is universal. Every service carries the Article 66(5) climate-data obligation. There is no CASP activity that escapes it, which makes standardised, comparable environmental data a baseline requirement rather than a niche concern.
- White paper link duties cluster around the client-facing trading services. According to Article 66(3), services that involve presenting or transacting specific assets to clients, exchange for funds, exchange for crypto, advice, and portfolio management, carry the link obligation where a white paper exists. Services that are more operational or custodial in nature do not attach the same duty in the same way.
- The white paper requirement is rarely triggered by the service itself. For most services, the white paper obligation only arises where the activity constitutes an offer to the public, which is assessed case by case, as specified by ESMA Q&A 2404. Custody, advice, portfolio management, and transfer services are unlikely to constitute an offer on their own, but services of exchange and reception, transmission or execution of orders may constitute them. The one special case is placing: there is no obligation on the CASP as such, but in practice the CASP will have to require a white paper from the offeror, as placing is a service of marketing for another’s offer.
- Where a white paper does not exist, link obligations fall away for most services. This was clarified by ESMA Q&A 2654. Only operating a trading platform retains a clear duty in that scenario, consistent with the platform's gatekeeping role in admission to trading.
Two qualifications that matter
The white paper requirement applies for admission to trading unless consent is secured to use somebody else's white paper, and for an offer to the public unless a subsequent offeror secures consent from a previous offeror. In other words, consent is required for white paper reuse, and not for the publication of a link. This distinction is frequently missed, and it changes the documentation a provider needs to hold.
Where the Alliance fits
The Alliance provides each of the services mapped in this table, and works with CASPs to determine precisely which obligations attach to their specific licence profile. Classification analysis, white paper preparation and review, sustainability data under Commission Delegated Regulation (EU) 2025/422, and iXBRL conversion are all part of that work. The aim is straightforward: helping providers hold the right documentation for the services they actually run, rather than the documentation they assume they need.
If you are working through which obligations apply to your authorisation, the Alliance can help map it.
