A recap on MiCAR white paper machine readability requirements

EU RegCORE Client Alert | EU Digital Single Market, financial services and crypto-assets

QuickTake

The EU's Markets in Crypto-Assets Regulation (EU) 2023/1114, commonly known as MiCAR, introduced a comprehensive framework for the regulation of crypto-assets across the EU, including detailed requirements for the publication of crypto-asset white papers. A key element of this framework is the requirement that white papers be made available in a machine-readable format, which is intended to facilitate supervisory oversight, data aggregation and comparability across the single market. This Client Alert summarises those obligations. 

Current status and outlook

As of March 2026, MiCAR has been fully applicable since 30 December 2024 for all categories of crypto-assets. ESMA and the EBA have published final versions of several of the relevant RTS and ITS and NCAs across Member States are actively processing white paper notifications. Issuers and their advisers should ensure they are consulting the latest versions of the applicable technical standards, as well as any guidance published by their home NCA, to ensure full compliance with the machine-readable format requirements.

In summary, the machine-readable white paper requirement under MiCAR represents a significant step towards standardised, technology-enabled disclosure in the crypto-asset space and issuers must take a proactive and technically informed approach to compliance.

How PwC Legal's “MiCAR START” offering can help clients

To address the compliance challenges outlined above, PwC Legal has developed “MiCAR START” (Submission, Traceability, Automation, Reporting & Transparency)—a joint PwC Legal –Auditchain Labs solution, powered by the Pacioli.ai platform—which delivers a proprietary, web3-enabled environment that transforms white paper preparation from a compliance burden into a streamlined, auditable and supervisory-ready process. The START offering provides clients with the following key capabilities:

1. Platform and Technology: Each client receives access to a dedicated, secure instance of the START platform, purpose-built for MiCAR compliance and provisioned exclusively for the client’s organisation. The platform enables collaborative white paper preparation between internal teams and external advisers, with full traceability, version control and role-based access. Intuitive, template-driven workflows guide users through the composition of compliant white papers for EMTs, ARTs and other crypto-assets, fully aligned with the MiCAR ITS. The platform performs real-time, automated validation of white paper content against the full MiCAR ITS rulebook and independent external technical validation is provided by the Pacioli.ai Validating Node, creating an additional layer of automated technical verification and a clear audit trail for supervisory purposes. Finalised white papers can be exported in iXBRL format for direct filing with regulators, as well as in .xls, .pdf and .html formats for internal review and publication.
2. PwC Legal, Regulatory and Advisory Support. Beyond the technology platform, PwC Legal provides a comprehensive suite of legal and regulatory advisory services, including MiCAR strategy and readiness advice, regulatory interpretation and scoping guidance and strategic support to ensure that white papers reflect both supervisory expectations and market best practice. PwC's and PwC Legal’s capital markets and regulatory specialists review draft white papers for accuracy, completeness, consistency and alignment with MiCAR disclosure principles, challenging assumptions and stress-testing risk disclosures. PwC and PwC Legal also support pre-filing engagement with competent authorities, preparation of supplementary materials and responses to supervisory queries.
3. Implementation, Training and Marketing Support. Auditchain Labs provides comprehensive documentation, live training sessions and hands-on implementation support to ensure client teams are fully equipped to operate the platform effectively. The platform can be configured to reflect the client’s branding, internal approval workflows and disclosure policies, with bespoke development services available for additional features or integrations. For issuers seeking to communicate their MiCAR compliance credentials to investors and the market, Auditchain Labs also provides marketing materials and communications support.