In the EEA, the Markets in Crypto-assets Regulation ("MiCA") requires all crypto-assets listed from January 1st 2025 onwards to have a MiCA-compliant whitepaper (“whitepaper”) and accompanying explanatory notes. This regulatory requirement is clearly defined and must be satisfied, without exception. In line with ESMA’s implementation timeline, whitepapers must be produced in XBRL format from 23 December 2025, in accordance with the MiCA taxonomy and ESMA guidance. The whitepaper must be published on the European Securities Markets Authority (“ESMA”) interim register and on Kraken’s website.
Any project seeking to be listed on Kraken, in the EEA, must produce a whitepaper in XBRL format and submit it to a National Competent Authority (“NCA”) at least 20 business days prior to the target listing date. The listing date will be impacted if the whitepaper isn’t submitted or if the whitepaper submitted doesn’t comply with MiCA. In addition to the whitepaper, an explanatory note must also be produced.
A whitepaper template has been approved by the European Parliament and can be found here. The template for crypto-assets other than asset-referenced tokens or e-money tokens can be found from page 5–23. Guidelines on templates for the preparation of explanatory notes and the standardised test for the classification of crypto-assets can be found here from page 20–23, as prepared by the ESAs (ESMA, EIOPA and the EBA). ESMA has also published materials supporting the required XBRL taxonomy and format, which can be found here and here.
In addition, under Commission Delegated Regulation (EU) 2025/421, the issuer must include a valid and renewed Legal Entity Identifier (LEI), provide the ISO 24165 Digital Token Identifier (DTI) and the Functionally Fungible Group DTI (FFG-DTI).
Further, the provisions of Implementing Regulation (EU) 2024/2984 must also be taken into account. This regulation defines the mandatory structure and content format of the Crypto-Asset Whitepaper and further requires that the document be submitted in a machine-readable format. Specifically, the regulation mandates the use of XBRL-based documents. In this context, additional technical and reporting requirements apply under the MiCA taxonomy published by ESMA, which can be found here: https://www.esma.europa.eu/document/mica-taxonomy-2025. The iXBRL format will strictly apply from 23 December 2025.
Kraken recommends project teams consider seeking advice from a specialist firm or legal counsel where the knowledge or experience to draft the whitepaper doesn’t exist in-house. Kraken has relationships with specialist firms who can assist in the drafting of whitepapers and can make introductions upon request. Where a project team elects to draft the whitepaper in-house, the whitepaper (.docx) and explanatory note (.docx) templates can be leveraged (Kraken accepts no liability for inaccuracies in these templates).
Kraken is required to publish ESG/Sustainability indicator data for all assets listed and made available in the EEA. Project teams are required to complete the questionnaire below, which contains the info required to generate the ESG/Sustainability indicators.
The whitepaper must be submitted to an NCA, e.g. Central Bank of Ireland, BaFin, MFSA, etc. at least 20 business days before the asset is admitted to trading. The NCA submits the whitepaper to ESMA, who in turn publishes it on their interim register.
Each NCA has a process in place for whitepaper submission, in some cases the NCA may charge a fee. The project team must provide evidence to Kraken that the whitepaper has been submitted, and the listing date will be a minimum of 20 business days from this date.
The project team must also submit the whitepaper to Kraken, who will assess it against its asset listing policy requirements. Kraken will publish the whitepaper on their website in line with regulatory requirements.
In all cases the project team must provide Kraken with permission to use the submitted whitepaper. Where the whitepaper has been submitted by a third party, the project team must obtain permission from that third party for Kraken to utilize the whitepaper.
Provide Kraken with permission by emailing [email protected], required language:
Pursuant to Article 5(4)(b) of the Markets in Crypto-Assets (MiCA) Regulation, on behalf of XXXXXXXX project team we hereby grant Kraken permission to use ASSET NAME MiCA white paper for the purpose of fulfilling your regulatory obligations. This consent is provided to alleviate the need for Kraken to draft a separate white paper
The project team must ensure that any changes or updates that are material in nature are updated on the whitepaper, in a timely manner.
Disclaimer - the above is for informational purposes only. Project teams are responsible for determining and satisfying their regulatory requirements. Kraken reserves the right to request additional information if deemed necessary. Filing a whitepaper does not guarantee that your asset will be approved for listing on Kraken.