2025/421 — White Paper Classification
Commission regulatory technical standard on White Paper Classification, with MiCA mandate, status and source metadata.
Instrument
Commission Delegated Regulation (EU) 2025/421 (RTS)
Drafted by
ESMA
Legal basis
Status
In force
In force
13 April 2025 (twentieth day after OJ publication on 24 March 2025)
Applies from
23 December 2025
Source
Recitals
In accordance with Regulation (EU) 2023/1114, the register of crypto-asset white papers, of issuers of asset-referenced tokens and e-money tokens, and of crypto-asset service providers (‘register’) established in accordance with Article 109 of Regulation (EU) 2023/1114 is to contain information allowing the register to facilitate the accessibility of white papers classified on the basis of the types of crypto-assets set out in that Regulation. The data necessary for the classification of crypto-asset white papers should support national competent authorities in their task of verifying that the requirements of Regulation (EU) 2023/1114 are applied consistently.
To ensure the most efficient operation of the register, competent authorities should submit the data to the European Securities and Markets Authority (ESMA) in the same format as the white paper. Furthermore, to minimise costs, ESMA and competent authorities should be able to derive the relevant data for the classification of white papers in the register from the information disclosed in crypto-asset white papers. To minimise the changes in the data required as of the date of application of Article 110 of Regulation (EU) 2023/1114, the data used to classify crypto-asset white papers should comprise the data that competent authorities will provide to the European Single Access Point (ESAP) in accordance with Article 5(1), point (e), of Regulation (EU) 2023/2859 of the European Parliament and of the Council.
To ensure efficient processing of data, legal persons drawing up the crypto-asset white paper and identified therein by an ISO 17442 legal entity identifier (LEI) should ensure that such LEI is valid and duly renewed. Where the person drawing up the white paper does not have a LEI, the register should contain an identifier that ensures similar characteristics for the purposes of the register.
Crypto-assets that are not financial instruments cannot at present be described by using the ISO Classification of Financial Instruments (CFI) code. A standard universal method of classification is being developed. However, this method of classification will not be finalised before the application of this Regulation. Hence, to identify the crypto-asset white papers consistently in the register referred to in Article 109(1) of Regulation (EU) 2023/1114, an international standard identifier for digital tokens, the Functionally Fungible Group Digital Token Identifier (FFG DTI) should be used. Furthermore, to identify the crypto-assets and to allow users to retrieve the main characteristics of the crypto-assets, including their technology-specific features, and to group tokens issued on several blockchains that are pertaining to the same crypto-asset white paper, the ISO 24165 Digital Token Identifiers (DTI) should be used. The FFG DTI and the DTI are appropriate for the purposes of the register since they respect the principles of uniqueness, neutrality, reliability, open source, scalability, accessibility on a cost-recovery basis and they are offered under an appropriate governance framework.
Since this Regulation concerns the classification of crypto asset white papers and is therefore linked to Commission Implementing Regulation (EU) 2024/2984 which concerns standard forms, formats and templates for the white paper, it is necessary to align the dates of application of the two Regulations. The deferred application is also necessary to enable persons drawing up crypto-asset white papers and competent authorities to adapt to the requirements laid down in this Regulation.
This Regulation is based on the draft regulatory technical standards submitted to the Commission by ESMA.
ESMA has conducted open public consultations on the draft regulatory technical standards on which this Regulation is based, analysed the potential related costs and benefits and requested the advice of the Securities and Markets Stakeholder Group established in accordance with Article 37 of Regulation (EU) No 1095/2010 of the European Parliament and of the Council,
Article 1 — Data for the classification of crypto-asset white papers
The data necessary for the classification of crypto-asset white papers is set out the Annex.
The data set out in the Annex shall be provided in a common format in accordance with the ISO 20022 standard.
By way of derogation from paragraph 2 of this Article, where the data set out in the Annex is included in the crypto-asset white paper referred to in Article 6, Article 19 or Article 51 of Regulation (EU) 2023/1114, the data set out in the Annex to this Regulation may be provided in the same machine-readable format in which the crypto-asset white paper was prepared in accordance with Implementing Regulation (EU) 2024/2984.
Article 2 — Legal Entity Identifiers
When using the ISO 17442 Legal Entity Identifier, persons drawing up a crypto-asset white paper referred to in Articles 6, Article 19 or Article 51 of Regulation (EU) 2023/1114 shall ensure that the identifier is: a) valid and issued in accordance with the terms of any of the Local Operating Units of the Global Legal Entity Identifier System; b) included in the Global Legal Entity Identifier database maintained by the Central Operating Unit appointed by the Regulatory Oversight Committee.
Article 3 — Identification of the crypto-asset and the related white paper
When the ISO 24165 Digital Token Identifier is provided, the crypto-asset white paper shall be identified with a valid identifier of type 3 pertaining to the group of crypto-assets to which the white paper relates.
When the ISO 24165 Digital Token Identifier is provided, the crypto-asset or crypto-assets to which the crypto-asset white paper relates shall be individually identified with a valid identifier assigned to each of the crypto-assets to which the white paper relates.
When the ISO 24165 Digital Token Identifier is not available, the crypto-asset white paper shall identify the crypto-assets to which the crypto-asset white paper relates, by using a digital token identifier approved by ESMA at Union level, which meets all of the following characteristics: a) unique; b) neutral; c) reliable; d) open source; e) scalable; f) accessible; g) available at a reasonable cost basis; and h) is subject to an appropriate governance framework.
Article 4 — Entry into force and application
This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.
This Regulation shall apply from 23 December 2025.
Annex — Data necessary for the classification of crypto-asset white papers in the register referred to in Article 109 of Regulation (EU) 2023/1114
Legend
{ALPHANUM-n}
Up to n alphanumerical characters
Free text field.
{DATE_TIME_FORMAT}
ISO 8601 date and time format
Date and time in the following format: YYYY-MM-DDThh:mm:ss.ddddddZ. — ‘YYYY’ is the year, — ‘MM’ is the month, — ‘DD’ is the day, — ‘T’ – means that the letter ‘T’ shall be used, — ‘hh’ is the hour, — ‘mm’ is the minute, — ‘ss.dddddd’ is the second and its fraction of a second, — Z is UTC time. Dates and times shall be recorded in UTC.
{DATEFORMAT}
ISO 8601 date format
Dates shall be formatted in the following format: YYYY-MM-DD.
{DECIMAL-n/m}
Decimal number of up to n digits in total of which up to m digits can be fraction digits
Numerical field for both positive and negative values. — decimal separator is ‘.’ (full stop), — negative numbers are prefixed with ‘-’ (minus); Values are rounded and not truncated.
{DTI}
9 alphanumerical characters
Digital Token Identifier as defined in ISO 24165 standard
{FFG DTI}
9 alphanumerical characters
Code to identify a group of equivalent Digital Token Identifiers as defined in ISO 24165 standard type 3
{INTEGER-n}
Integer number of up to n digits in total
Numerical field for both positive and negative integer values.
{LEI}
20 alphanumerical characters
Legal entity identifier as defined in ISO 17442
{MIC}
4 alphanumerical characters
Market identifier as defined in ISO 10383
1
Type of crypto-asset white paper
The type of crypto-asset white paper notified. Where the crypto-asset white paper concerns asset-referenced tokens, the code ‘ARTW’ shall be used. Where the crypto-asset white paper concerns e-money tokens, the code ‘EMTW’ shall be used. Where the crypto-asset white paper concerns crypto-assets other than asset-referenced tokens and e-money tokens the code ‘OTHR’ shall be used.
Choice from list of predefined values: ‘ARTW’ ‘EMTW’ ‘OTHR’
2
Name of the issuer
Name of the issuer
Free alphanumerical text
3
Legal form of the issuer
Legal form
ISO standard 20275 ‘Financial Services – Entity Legal Forms (ELF)’
4
Legal entity identifier of the issuer, where available
Legal entity identifier of the issuer, where available
{LEI}
5
Other identifier of the issuer required pursuant to applicable national law, where available
Other identifier of the issuer required pursuant to applicable national law, where available
Free alphanumerical text
6
Legal entity identifier of the entity that drew up the crypto-asset white paper, where available
Legal entity identifier of the entity that drew up the crypto-asset white paper, where available
{LEI}
7
Other identifier of the entity that drew up the crypto-asset white paper required pursuant to applicable national law, where available
Other identifier of the entity that drew up the crypto-asset white paper required pursuant to applicable national law
Free alphanumerical text
8
Identifier of operator of the trading platform
Segment market identifier code (MIC) for the trading platform operated by the crypto-asset service provider (CASP), where available, otherwise operating MIC
{MIC}
9
Commercial name or trading name of the issuer, where available
Commercial name or trading name of the issuer, where available
Free alphanumerical text
10
Physical address of the issuer
Physical address of the issuer
Free alphanumerical text
11
Telephone number of the issuer, where available
Telephone number of the issuer, where available
Free alphanumerical text
12
Email of the issuer, where available
Email of the issuer, where available
Free alphanumerical text
13
Website of the issuer
Website of the issuer
Free alphanumerical text
14
Home Member State
Home Member State as defined in Article 3, point (33), of Regulation (EU) 2023/1114
Closed list of EU Member States
15
Host Member States
Host Member State as defined in Article 3, point (34), of Regulation (EU) 2023/1114.
Closed list of EU Member States
16
Starting date of offer to the public or admission to trading
Starting date or, if not available at the time of the notification by the competent authority, the intended starting date of offer to the public or admission to trading
YYYY-MM-DD
17
Any other services provided by the issuer
Any other services provided by the issuer not covered by Regulation (EU) 2023/1114, with a reference to the applicable Union or national legal acts regulating that service, where applicable
Free alphanumerical text
18
The date of authorisation, where applicable
The date of authorisation by the competent authority, where applicable
YYYY-MM-DD
19
The date of withdrawal of authorisation, where applicable
The date of withdrawal of authorisation by the competent authority, where applicable
YYYY-MM-DD
20
Publication date
Effective or intended publication date of the crypto-asset white paper or of the modified crypto-asset white paper, as applicable
YYYY-MM-DD
21
Date and time of notification
Date and time of the latest notification of the white paper to the competent authority
YYYY-MM-DD Thh:mm:ss.ddddddZ.
22
Language or languages of the crypto-asset white paper
Language or languages in which the crypto-asset white paper is drafted. Where multiple languages have been used, this field shall be reported as many times as necessary
Closed list of EU languages
23
Record identifier
Unique identifier of the uploaded record, assigned by the sending competent authority
{ALPHANUM-500}
24
Data file reference
Reference code needed to link the data file with corresponding metadata file
{ALPHANUM-500}
25
The type of submission
Type of submission
NEWT = New MODI = Modify EROR = Error CORR = Correction
26
Version
Version of the dataset (data and metadata)
{INTEGER-50}
27
Digital Token Identifier used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available
Code used to uniquely identify the crypto-asset or each of the several crypto assets to which the crypto-asset white paper relates, where available
ISO 24165 Digital Token Identifier {DTI}
28
Functionally Fungible Group Digital Token Identifier, where available
Code used to uniquely identify the functionally fungible group to which the digital asset belongs (i.e. common to each of the several assets to which the crypto-asset white paper relates), i.e. code used to identify the white paper ISO 24165 DTI of type = 3 (i.e. functionally fungible group), where available
ISO 24165 [FFG DTI]
29
Personal data flag
Flag indicating if the submitted crypto-asset white paper contains personal data
‘true’ – Yes ‘false’ – No
Related
crypto-asset service provider — defined term used on this page
crypto-asset service provider — defined term used on this page
crypto-asset service provider — defined term used on this page
legal entity identifier — defined term used on this page
crypto-asset service — defined term used on this page
competent authority — defined term used on this page
offer to the public — defined term used on this page
home Member State — defined term used on this page
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