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LexorCorp Global Order

Guide

Crypto-asset white paper under MiCA Title II

A company that offers a crypto-asset to the public in the European Union, or seeks its admission to trading, must, unless an exemption applies, draw up a crypto-asset white paper, notify it to the competent authority and publish it. Competent authorities may not require prior approval of the white paper, and the offeror and its management are liable for what it says.

LexorCorp Global OÜ · published 11 November 2026

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In short

A company that offers a crypto-asset to the public in the European Union, or seeks its admission to trading, must, unless an exemption applies, draw up a crypto-asset white paper, notify it to the competent authority and publish it 13 . Competent authorities may not require prior approval of the white paper 39 , and the offeror and its management are liable for what it says 26 . Title II of the Markets in Crypto-Assets Regulation (MiCA) governs offers to the public and admissions to trading of crypto-assets other than asset-referenced tokens (ARTs) and e-money tokens (EMTs) — for example utility tokens 1 .

Order the application documents: Order

A company that offers a crypto-asset to the public in the European Union, or seeks its admission to trading, must, unless an exemption applies, draw up a crypto-asset white paper, notify it to the competent authority and publish it13. Competent authorities may not require prior approval of the white paper39, and the offeror and its management are liable for what it says26.

Information as of 10 November 2026. Every numbered statement of this page was checked in the official text named below and re-checked by a second reviewer on 2026-11-10. The page is general information, not legal advice; the authority decides on every application.

What the activity is

Title II of the Markets in Crypto-Assets Regulation (MiCA) governs offers to the public and admissions to trading of crypto-assets other than asset-referenced tokens (ARTs) and e-money tokens (EMTs) — for example utility tokens1. ARTs and EMTs are not covered here.

An "offer to the public" is a communication in any form presenting enough information on the terms and the crypto-assets for prospective holders to decide whether to buy2; the "offeror" is whoever offers crypto-assets to the public, including the issuer3. A person seeking admission to trading on a trading platform for crypto-assets is subject to the same core duties4.

Crypto-asset services (exchange, custody, transfer and similar) are not covered on this page.

The legal act and the authority

  • Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), Title II, Articles 4–15 and Annex I. Title II applies from 30 December 20245. Articles 4–15 do not apply to offers to the public that ended before 30 December 20246.
  • Commission Implementing Regulation (EU) 2024/2984 on forms, formats and templates for crypto-asset white papers, applicable from 23 December 20257.
  • Krüptovaraturu seadus (Crypto-Asset Market Act, KrüTS) in Estonia. An offeror of other crypto-assets is a crypto-asset market participant under the act, but only a few of its provisions apply to it8.
  • Competent authority: Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority) supervises compliance with MiCA under KrüTS9. The white paper is notified to the authority of the offeror's home Member State — for an offeror with its registered office in the EU, the Member State of that registered office10.
  • Register: the European Securities and Markets Authority (ESMA) keeps a register of white papers, including modified versions11, and makes the white paper available there by the starting date of the offer or admission to trading12.

Who must notify, and the main exemptions

A person may make an offer to the public of such a crypto-asset in the EU only if it is a legal person, has drawn up, notified and published a white paper (Articles 6, 8 and 9), has drafted and published any marketing communications (Articles 7 and 9), and complies with the duties of Article 1413. A person seeking admission to trading must meet the same conditions4. The trading-platform operator may take over these duties by written agreement14.

Article 4(2) — the white paper does not have to be drawn up, notified or published (and marketing communications need not be published) for an offer15:

  • to fewer than 150 natural or legal persons per Member State;
  • whose total consideration does not exceed EUR 1,000,000;
  • addressed solely to qualified investors.

Article 4(3) — Title II does not apply at all where the crypto-asset is offered for free, is created automatically as a reward for maintaining the ledger or validating transactions, is a utility token giving access to a good or service that exists or is in operation, or may be used only within a limited network of merchants16. An offer is not free if buyers must give personal data or the offeror receives any fee or benefit in exchange16.

The exemptions fall away once the offeror, or anyone on its behalf, announces an intention to seek admission to trading17. A white paper drawn up voluntarily for an exempt offer brings Title II into full effect18.

Requirements for the offeror

Whether requirements beyond Title II apply is specified for the client's situation. The conditions of Title II for the offeror are in Articles 4(1) and 1413:

  • Conduct duties: act honestly, fairly and professionally; communicate in a fair, clear and not misleading manner; identify, prevent, manage and disclose conflicts of interest; keep systems and security access protocols in line with the appropriate Union standards19; act in the best interests of holders and treat them equally unless preferential treatment is disclosed20.
  • Management body statement: the white paper must contain a statement by the management body confirming that it complies with Title II and that the information is fair, clear and not misleading21.
  • Safeguarding funds: an offeror with a time-limited offer must keep the funds or crypto-assets raised with a credit institution or a CASP providing custody22.
  • Refunds: if the offer is cancelled, funds collected must be returned within 25 calendar days23.
  • Right of withdrawal: retail holders may withdraw within 14 calendar days without fees or costs and without giving reasons; this does not apply where the crypto-asset was already admitted to trading before the purchase24.
  • Marketing communications must be identifiable as such, fair, clear and not misleading, consistent with the white paper and carry the prescribed "not reviewed or approved" statement; none may be disseminated before the white paper is published25.
  • Liability: the offeror and the members of its administrative, management or supervisory body are liable to holders for loss caused by incomplete, unfair, unclear or misleading information; contractual exclusion of that liability has no legal effect26.

Content of the white paper and documents filed

Content (Article 6 and Annex I). Information on the offeror (and issuer, if different), the project, the offer or admission to trading, the crypto-asset, the rights and obligations attached to it, the underlying technology, the risks, and the principal adverse climate and environmental impacts of the consensus mechanism27. Mandatory elements include the first-page statement that the white paper has not been approved by any competent authority28, no assertions about future value29, prescribed risk warnings30, a summary with fixed warnings31, the date of notification and a table of contents32. It must be machine-readable33: since 23 December 2025 in XHTML with Inline XBRL tagging, using the template in the Annex to Regulation (EU) 2024/29847.

Notification (Article 8). Filed with the white paper34:

  • an explanation of why the crypto-asset is not excluded from MiCA under Article 2(4) and is neither an EMT nor an ART;
  • a list of host Member States where the offer or admission is planned, and the intended starting date.

Finantsinspektsioon asks for a signed notification naming a contact person, the white paper in searchable electronic form, the annexes for the token type, the Member State list and starting date, and proof of fee payment, sent to whitepaper@fi.ee35.

State fee and time limits

  • Fee: EUR 1,000 processing fee for notifying a white paper under MiCA Article 8(1) (Financial Supervision Authority Act, Finantsinspektsiooni seadus, § 45⁵(3))36.
  • Timing: the white paper and the explanation must reach the authority at least 20 working days before the white paper is published37. The white paper must be published on the offeror's website before the offer or admission to trading starts and stay available while the crypto-asset is held by the public38.
  • No approval: competent authorities may not require prior approval of white papers or marketing communications39. The home authority passes the information to ESMA and host Member States within five working days40.
  • Modifications must be notified at least seven working days before publication41.
  • Authority's powers: Finantsinspektsioon may require the white paper to be amended or supplemented, suspend an offer for up to 30 consecutive working days, or prohibit it42. Breaching Articles 4–14 can cost a legal person a fine of up to EUR 5,000,000, twice the gain made or loss avoided, or 3% of consolidated turnover43.

The 20 working days is the law's minimum period, not a promise of an outcome; the authority may take the measures above.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ sells the service "Crypto-asset white paper (MiCA Title II) — drafting", priced from EUR 6,000 (one-time)44. It includes44:

  • drafting the crypto-asset white paper under MiCA Title II (Article 6, Annex I), or under Title III/IV for ARTs/EMTs according to scope;
  • a check of marketing communications (Article 7);
  • preparing the notification to the competent authority (Article 8).

Deliverables: the white paper in the required machine-readable format and the notification file; the client supplies token economics, rights, technology, issuer information and risks44. State fees, notary fees and the fees of the Financial Supervision Authority or any other public authority are not included in the price; they are paid separately44. LexorCorp Global OÜ gives no legal or tax advice, does no audit and promises no outcome or date; the offeror remains responsible for the white paper's content.

Order through the request form on the crypto page: order form.

Sources

  1. MiCA Title II heading — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  2. MiCA Art. 3(1)(12) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  3. MiCA Art. 3(1)(13) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  4. MiCA Art. 5(1) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  5. MiCA Art. 149(2) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  6. MiCA Art. 143(1) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  7. Implementing Regulation (EU) 2024/2984 Art. 2(1), Art. 4 — text in force from OJ text, applies from 23.12.2025
  8. KrüTS § 3(1)(3), § 2(3) — text in force from 01.07.2024 (hetkel kehtiv, RT I, 21.06.2024, 3)
  9. KrüTS § 26(1) — text in force from 01.07.2024 (hetkel kehtiv, RT I, 21.06.2024, 3)
  10. MiCA Art. 3(1)(33)(a), Art. 8(1) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  11. MiCA Art. 109(1)(a), (2) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  12. MiCA Art. 8(7) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  13. MiCA Art. 4(1) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  14. MiCA Art. 5(3) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  15. MiCA Art. 4(2) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  16. MiCA Art. 4(3) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  17. MiCA Art. 4(4) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  18. MiCA Art. 4(8) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  19. MiCA Art. 14(1) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  20. MiCA Art. 14(2) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  21. MiCA Art. 6(6) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  22. MiCA Art. 10(3) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  23. MiCA Art. 14(3) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  24. MiCA Art. 13(1), (4) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  25. MiCA Art. 7(1), (2) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  26. MiCA Art. 15(1), (2) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  27. MiCA Art. 6(1); Annex I Parts A–I — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  28. MiCA Art. 6(3) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  29. MiCA Art. 6(4) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  30. MiCA Art. 6(5) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  31. MiCA Art. 6(7) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  32. MiCA Art. 6(8) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  33. MiCA Art. 6(10) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  34. MiCA Art. 8(4), (6) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  35. Finantsinspektsioon, Information for Crypto-Asset Issuers on White Paper — text in force from page last updated 06.10.2025
  36. Finantsinspektsiooni seadus § 45⁵(3) — text in force from 01.10.2026 (RT I, 11.07.2026, 12); provision in force since 01.07.2024
  37. MiCA Art. 8(5) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  38. MiCA Art. 9(1) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  39. MiCA Art. 8(3) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  40. MiCA Art. 8(6)–(7) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  41. MiCA Art. 12(2) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  42. MiCA Art. 94(1)(i), (k), (l), (m) — text in force from consolidated version 09.01.2024 (latest on EUR-Lex)
  43. KrüTS § 40(2) — text in force from 01.07.2024 (hetkel kehtiv, RT I, 21.06.2024, 3)
  44. LexorCorp Global price list and service description (price list)

Official sources

The laws this article names, each linked to its official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Sources in the text are named without links; the official texts are linked under Official sources. To see which of our services your company needs, open the Business Navigator.

Order the application documents

We prepare the application documents and manage the process; the authority decides. Not legal advice.

Our fee: from €3,500; no VAT is added. State fees and the fees of the supervisory authority are not included in the price; you pay them yourself.

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