MiCA White Paper Notification: How Non-CASP Token Issuers File in 2026

Short answer: You do not need to be a CASP to offer a token in the EU. Under MiCA, any legal person can make an offer to the public of a crypto-asset (other than a stablecoin-type ART or EMT) if it drafts a white paper, notifies it to the regulator of its home Member State at least 20 working days before publishing it, and then publishes it on its own website (MiCA, Articles 4 and 8, as of October 2026). The regulator does not approve the document, but it can ask for changes or stop the offer.

This guide walks a non-CASP token issuer through MiCA white paper notification step by step: who can notify, where, what to send, the timeline, the format, and when you can skip the white paper altogether. It covers "other crypto-assets" under Title II of MiCA, the category most utility and governance tokens fall into.

Do you need to be a CASP to notify a MiCA white paper?

No. A token offeror does not need a CASP licence.

MiCA splits two roles. A CASP (crypto-asset service provider) needs authorisation to run an exchange, custody, brokerage or similar services. An offeror is simply the legal person that offers its token to the public. Article 4(1) of MiCA lists what an offeror needs, and a CASP licence is not on the list:

• be a legal person (a natural person cannot be an offeror);
• draw up a white paper under Article 6;
• notify it under Article 8;
• publish it under Article 9;
• draft and publish marketing communications under Articles 7 and 9, if any;
• comply with the conduct rules in Article 14 (act honestly, fairly and professionally, manage conflicts of interest, treat holders equally).

Source: Regulation (EU) 2023/1114 (MiCA), as of October 2026.

A token issuer is not a CASP just because it sells its own token. You only need a CASP licence if you also provide crypto-asset services to clients, such as running a trading platform or holding client assets. If you need that licence too, see our Malta vs Estonia MiCA CASP licence comparison.

Also note that MiCA requires a company, not a founder acting personally. If you have not set one up yet, read do you need a company to launch a token.

Which regulator do you notify your white paper to?

You notify the competent authority of your "home Member State". MiCA Article 3(1)(33) defines it for Title II offerors like this:

Source: MiCA, Article 3(1)(33), as of October 2026.

A non-EU company can notify a MiCA white paper without opening an EU entity. A Cayman foundation or BVI company that offers its token in the EU picks its home Member State by where the offer or listing starts. For more on those structures, see Cayman foundation vs BVI company for a token launch.

What do you send with a MiCA white paper notification?

Article 8 of MiCA sets the core package. You send:

1. The white paper itself, drawn up under Article 6 and Annex I.
2. An explanation of why your token is not (a) excluded from MiCA under Article 2(4), for example because it is a financial instrument, (b) an e-money token, or (c) an asset-referenced token.
3. A list of host Member States where you plan to offer the token or seek admission to trading, if any.
4. The intended start date of the offer or admission to trading, and any later change to it.

Source: MiCA, Article 8(4)-(6), as of October 2026.

National regulators add their own practical requirements. The Estonian Financial Supervision and Resolution Authority, for example, also asks for a signed notification letter naming a contact person, the white paper in searchable electronic form, and proof that you paid its processing fee (Finantsinspektsioon, as of October 2026).

In Estonia, the fee for notifying a white paper for "other crypto-assets" is €1,000 (Finantsinspektsioon, as of October 2026). Other regulators set their own fees, so check your home authority's page before you file.

What must the white paper contain?

Article 6 and Annex I of MiCA set the content. The white paper covers the offeror, the issuer if different, the project, the offer, the token, the rights and obligations attached to it, the underlying technology, the risks, and the climate and environmental impact of the consensus mechanism.

A few items are mandatory word for word or close to it:

• On the first page: "This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The offeror of the crypto-asset is solely responsible for the content of this crypto-asset white paper."
• A statement from your management body that the white paper complies with Title II and is fair, clear and not misleading.
• A short, non-technical summary with set warnings.
• Clear warnings that the token may lose all its value, may not be transferable or liquid, and is not covered by investor compensation or deposit guarantee schemes.
• No claims about the token's future value.
• Information on the retail holder's 14-day right of withdrawal under Article 13, where it applies.

Source: MiCA, Articles 6 and 13, as of October 2026.

What format does a MiCA white paper have to be in?

Since 23 December 2025, white papers must be filed as a single XHTML file tagged with Inline XBRL (iXBRL), using ESMA's MiCA taxonomy (Commission Implementing Regulation (EU) 2024/2984; ESMA MiCA page, as of October 2026).

A PDF white paper is no longer enough for a MiCA notification. ESMA publishes the taxonomy and free Excel-based example tools that generate an iXBRL file for each token type, including "OTHR" for other crypto-assets. ESMA says use of those tools is voluntary and the output remains the preparer's responsibility.

How long does MiCA white paper notification take?

The legal minimum is 20 working days between notification and publication. Here is the full timeline under MiCA:

Source: MiCA, as of October 2026.

In practice, plan for more than 20 working days. Drafting, legal review of the classification explanation and iXBRL tagging usually take longer than the notification window itself.

Does the regulator approve the white paper?

No. Competent authorities may not require prior approval of a Title II white paper (MiCA Article 8(3)). The opposite applies to asset-referenced tokens, whose white papers need approval.

"No approval" does not mean "no review". Regulators can request changes, ask for extra information, or suspend or prohibit an offer. And the published version must be identical to the notified one (Article 9).

Under MiCA Article 15, the offeror and its management body are liable to token holders for incomplete, unclear or misleading information in the white paper. Any contract term that excludes or limits that liability has no legal effect.

When can you skip the white paper?

Some offers need no white paper at all. Two groups of exemptions exist.

Offers exempt from the white paper rules (Article 4(2)), where you still must be a legal person and follow the conduct rules:

• offers to fewer than 150 persons per Member State, acting on their own account;
• offers where total consideration in the EU over 12 months does not exceed €1,000,000;
• offers made only to qualified investors, where only they can hold the token.

Offers outside Title II altogether (Article 4(3)):

• tokens offered for free (not free if buyers give personal data or pay any fee);
• tokens created automatically as mining or validation rewards;
• utility tokens giving access to a good or service that already exists or is in operation;
• tokens usable only in a limited network of merchants (with a notification duty above €1,000,000 a year).

Source: MiCA, Article 4, as of October 2026.

All of these exemptions fall away once you announce that you plan to list the token (Article 4(4)). A listing ambition is the most common reason a "small" raise ends up needing a full white paper. For the difference between token types, see utility token vs security token.

Can a trading platform file the white paper for you?

Yes, for admission to trading. Under Article 5(3), the person seeking admission and the trading platform operator can agree in writing that the operator handles all or part of the white paper, notification and publication duties. You still have to give the operator all the information it needs, and you remain liable if that information is misleading (Article 15(3)).

This route only covers listings. If you also run your own public sale, the offer itself still needs your own notified white paper unless an exemption applies.

Which route fits your token launch?

Source: MiCA, Articles 4, 5 and 8, as of October 2026.

A practical checklist for non-CASP issuers

1. Set up or confirm the legal entity that will be the offeror. See our guide to token issuance.
2. Classify the token: not a financial instrument, not an EMT, not an ART. Write this up, because you must send it with the notification.
3. Fix your home Member State using the table above, and read that regulator's filing page and fee.
4. Draft the white paper to Annex I, then produce the iXBRL file.
5. File at least 20 working days before your publication date, with the host Member State list and start date.
6. Publish the identical version on your website before the offer starts, and keep it online while the public holds the token.
7. Track changes. A material change means a modified white paper, notified 7 working days before publication.

MiCA notification is a disclosure duty, not a licence. It is cheaper and faster than CASP authorisation, but the liability for what you write is real.

This article is general information, not legal advice. MiCA rules and national regulator practice change, so check the current text and your home regulator's guidance before you file.

Planning an EU token launch and not sure whether you need a white paper, an exemption or a CASP partner? Book a free 15-minute consultation with OnScale at contact@onscale.org.