A bitcoin white paper with no issuer
Which white paper covers bitcoin in the EU? Not Satoshi Nakamoto’s 2008 paper. The bitcoin entries in ESMA’s interim MiCA register were drawn up by others. One comes from Hamburg data firm Crypto Risk Metrics GmbH, whose second version names the firm as “the person seeking admission to trading” and was notified on May 26, 2026. No issuing entity, the paper says, “can be determined in a formal legal sense”.
Another, listed under Liechtenstein’s regulator, comes from exchange LCX AG and is dated March 18, 2025. Article 5 of MiCA lets the person seeking admission to trading, or the trading platform itself, draw up the paper, which is how a token without an issuer gets one. For tokens already trading before December 30, 2024, Article 143 gives platform operators until December 31, 2027 to make sure one exists.
What ESMA’s file counted
ESMA’s file of white papers for tokens other than asset-referenced and e-money tokens held 1,071 entries in the update dated November 5, 2026. Five countries account for most of them.
| Home member state | White papers |
|---|---|
| Ireland | 405 |
| Germany | 171 |
| Malta | 169 |
| Netherlands | 87 |
| Liechtenstein | 74 |
One exchange group explains much of the Irish lead. A Kraken company appears in the column for the crypto-asset service provider on 152 rows, 145 of them under the Central Bank of Ireland, while Crypto Risk Metrics fills the issuer or offeror column on 148.
What sits on the first page
Article 6(3) of the regulation demands a prominent first-page statement, which begins “This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union.” Warnings follow that the token may lose its value in part or in full and is covered by neither investor compensation nor deposit guarantee schemes. Claims about its future value are banned.
The format is fixed too. Since December 23, 2025, papers must be machine-readable in inline XBRL under Implementing Regulation (EU) 2024/2984, according to an ESMA statement of November 28, 2025. The bitcoin paper’s second version says it was updated for exactly that. Stablecoins have their own versions. Circle’s USDC Terms send holders in the European Economic Area to its e-money token white paper.
Notified, not approved
Reading an ESMA listing as a regulator’s approval is the common mistake. Under Article 8, the paper goes to the national authority at least 20 working days before publication, and authorities “shall not require prior approval”.
That does not leave buyers without recourse. Article 15 makes the offeror or the person seeking admission to trading, along with the members of its management body, liable for losses caused by information that is incomplete, unfair, unclear or misleading, and any contract term limiting that liability has no legal effect, though the holder must prove the breach and show that it influenced the purchase.
To find a token’s paper, search ESMA’s file for its name or digital token identifier, then check the notification date.