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MiCA's Reporting Requirements and New Obligations for VASPs and CASPs

Apr 23 2025

The Markets in Crypto-Assets (MiCA) regulation introduces a comprehensive and harmonized framework for the crypto industry across the European Union, setting new reporting requirements for Crypto-Asset Service Providers (CASPs) and Virtual Asset Service Providers (VASPs). These obligations are designed to improve transparency, strengthen consumer protection, and ensure financial stability within the digital asset ecosystem. Under MiCA, CASPs and VASPs must report on activities related to the issuance, trading, transfer, and custody of crypto assets, including asset-referenced tokens (ARTs) and e-money tokens (EMTs). This includes submitting detailed information to National Competent Authorities (NCAs) and the European Securities and Markets Authority (ESMA), covering operational data, consumer risk disclosures, and incidents affecting security access protocols or digital operational resilience. The regulation introduces enhanced disclosure requirements for crypto asset white papers, marketing communications, and public reporting on asset reserves, risk management practices, and internal governance. Additionally, service providers must implement systems to monitor and report suspicious activity and market abuse to prevent manipulation and illicit financial flows. For crypto businesses, complying with MiCA’s reporting framework will require strategic investment in RegTech solutions, robust data management systems, and internal training. While the reporting requirements may appear burdensome, they also offer a path to greater market legitimacy, investor confidence, and long-term scalability. MiCA marks a significant shift in the regulation of the European crypto markets. Those who adapt early and efficiently to its reporting requirements will not only ensure compliance but also gain a competitive advantage in a maturing regulatory landscape.

As the crypto industry matures, regulatory clarity is essential to ensure market integrity, investor protection, and systemic financial stability. The Markets in Crypto-Assets (MiCA) regulation, also known as the crypto assets act, adopted by the European Union (EU), introduces a comprehensive regulatory framework to govern crypto asset markets and the behavior of Crypto-Asset Service Providers (CASPs) and Virtual Asset Service Providers (VASPs). A pivotal part of MiCA’s enforcement mechanism lies in its robust reporting requirements. These obligations aim to increase transparency, prevent market abuse, and align crypto market practices with traditional financial systems.

Table of Contents

Introduction to MiCA

The Markets in Crypto-Assets (MiCA) regulation is a comprehensive regulatory framework established by the European Union to govern crypto assets in Europe. It aims to provide a uniform European legal framework for crypto-assets issuers and service providers not covered by existing financial services regulations. MiCA applies to the issuance, public offering, admission to trading, and provision of services related to crypto-assets, ensuring financial stability and protecting investors. The regulation distinguishes four main types of crypto-assets: e-money tokens, asset-referenced tokens, security tokens, and utility tokens.

Understanding MiCA and Its Scope

The MiCA regulation is the EU’s landmark crypto assets regulation aimed at regulating the issuance and trading of crypto assets, including e money tokens, asset referenced tokens, and other crypto assets not classified as financial instruments. MiCA applies to all entities that provide crypto asset services within the EU, such as crypto asset service providers, custodian wallet providers, and crypto asset issuers.

MiCA’s reporting framework is designed to integrate crypto asset markets into the broader international financial system, ensuring consistency with existing financial and anti-fraud laws. It addresses risks linked to market manipulation, money laundering, and terrorist financing, while also enhancing consumer protection.

Definition of Service Providers

A crypto asset service provider (CASP) is a legal person or other undertaking whose occupation or business is to provide one or more crypto-asset services to clients on a professional basis. CASPs must be authorized to provide such crypto-asset services in accordance with the provisions of the Regulation. The definition of CASPs includes providers of services such as custody and administration of crypto assets, operating trading platforms, executing orders, and providing exchange services between crypto assets and fiat currencies.

Key Reporting Obligations for CASPs and VASPs

1. Periodic Reporting to National Competent Authorities (NCAs)

Under MiCA, crypto asset service providers must submit detailed reports to their national competent authority on a regular basis. These include:

  • The volume and value of crypto asset transfers facilitated.

  • Lists of crypto asset services provided.

  • Data on portfolio management, custody, and trading platform operations.

  • Information about electronic money tokens and asset referenced tokens under management.

This reporting ensures transparency and disclosure requirements are met and that authorities can monitor systemic risks in real time.

2. Incident Reporting

In alignment with the Digital Operational Resilience Act, VASPs and CASPs must report any cybersecurity or operational incident that affects security access protocols, stored electronically customer data, or ongoing services.

Timely incident reporting helps mitigate disruptions in crypto markets and enhances trust among users and regulators alike. This requirement is part of the broader digital finance strategy aimed at ensuring the resilience and security of financial services in the digital age.

3. Suspicious Activity and Market Abuse Reporting

CASPs are obligated to report any behavior that may constitute market manipulation or suspicious transactions to relevant authorities, thereby preventing market abuse. This includes:

  • Unusual trading activity across a crypto asset trading platform.

  • Suspicious marketing communications relating to such crypto assets.

  • Violations of applicable national law and market abuse provisions.

This obligation aligns crypto reporting procedures with those required of investment firms and credit institutions in traditional finance.

4. Transparency on Public Disclosures

Entities must provide complete and accurate marketing communications and crypto asset white papers before offering or listing tokens for admission to trading. These documents must disclose:

  • Risks associated with crypto assets.

  • Details of the issuing legal entity.

  • Use of proceeds and rights of holders.

Reports and documents must be updated and made available via public channels to comply with public disclosure rules.

Regulatory Framework

The MiCA regulation provides a structured approach to prudential supervision of issuers of asset-referenced tokens and e-money tokens. It imposes new prudential obligations on issuers and offerors of asset-referenced tokens and e-money tokens, ensuring a high level of protection for retail investors and the integrity of the crypto-asset markets. The regulatory framework for asset-referenced tokens and e-money tokens is broadly similar, but the key difference is that only credit institutions or electronic money institutions are authorised to issue e-money tokens. The regulation also introduces liability against an issuer of asset-referenced tokens for the information contained in the white paper.

Implementation Timeline

The implementation of MiCA is set to happen in phases. The deadline of December 30, 2024, is recognized as a key implementation date for MiCA. As of June 30, 2024, only the provisions pertaining to e-money tokens and asset-referenced tokens have taken effect. The regulatory regime applies to e-money tokens and asset-referenced tokens, but not to other types of crypto-assets. The licensing and authorization phase for Crypto Asset Service Providers (CASPs) will begin in January 2025, with a grandfathering period of up to 18 months allowing existing providers to continue operations while transitioning to full compliance.

Reporting Requirements for Crypto Asset Issuers

Issuers of e money tokens, asset referenced tokens, and other crypto assets, which are considered legal persons, are required to:

  • File a crypto asset white paper with the relevant markets authority.

  • Report financial and prudential status, including own funds and technical standards adopted.

  • Provide updates on the number of tokens in circulation and significant changes in operations.

These requirements improve oversight of token economics and enhance financial stability across crypto asset markets.

Stablecoins and Electronic Money Tokens

MiCA introduces strict rules for stablecoins, also known as asset-referenced tokens, which are tokens that try to stabilize their value using the value of another asset or right. The regulation requires issuers of asset-referenced tokens to maintain a sound governance structure, meet own funds requirements, and create a reserve of assets to cover risks. E-money tokens, on the other hand, are electronic money tokens that represent official currencies. Only authorized credit institutions or electronic money institutions are permitted to offer e-money tokens to the public or seek admission to trading within the European Union. The regulation ensures that both asset-referenced token holders and e-money token holders retain a right of redemption against the issuer.

Integration with AML and Consumer Protection

MiCA’s reporting mechanisms are complemented by strong anti money laundering (AML) obligations. VASPs must:

  • Perform customer due diligence and identity verification.

  • Report data to help prevent market abuse and flag risks associated with terrorist financing.

These measures also include prudential requirements to ensure that entities maintain sound governance and financial stability.

This integrated framework helps align the crypto ecosystem with the EU’s AML directives.

The Role of the European Supervisory Authorities

The European Banking Authority (EBA) and European Securities and Markets Authority (ESMA) play key roles in standardizing and monitoring reporting procedures. They will issue binding technical standards to:

  • Harmonize reporting formats across member countries.

  • Define the content and frequency of reports.

  • Ensure that national competent authorities have the tools to enforce compliance effectively.

The European Commission also plays a crucial role in developing secondary legislation and ensuring the effective implementation of MiCA.

Challenges and Considerations for CASPs and VASPs

Complying with MiCA’s reporting regime will require:

  • Investment in automated data collection and reporting systems.

  • Training staff on regulatory framework requirements.

  • Close coordination with NCAs, the european banking authority, and european securities regulators.

Additionally, delegated acts by the European Commission will specify further details on compliance requirements for significant issuers.

Given the comprehensive nature of MiCA, non-compliance could result in:

  • Fines and license revocation.

  • Exclusion from operating within the european union.

  • Reputational damage and legal liability.

Conclusion

MiCA’s reporting obligations are a cornerstone of the EU’s effort to integrate crypto services into the regulated financial landscape. For crypto asset service providers, this new regime presents both a challenge and an opportunity: while the bar for compliance is high, meeting these standards can boost market credibility, protect consumers, and facilitate sustainable growth.

By embracing MiCA’s comprehensive regulatory framework, VASPs and CASPs will not only provide crypto asset services lawfully but also help build a resilient, transparent, and trustworthy crypto asset markets ecosystem. The transitional period allows existing providers to adapt to the new regulatory framework, ensuring a smoother transition to full compliance.

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