EBA Releases Final Guidelines for Monitoring Compliance with MiCAR: Detailed Reporting Framework for Crypto Asset Issuers and Service Providers

The European Banking Authority (EBA) has published its final report on guidelines for templates to assist competent authorities in overseeing issuers’ compliance under the Markets in Crypto-Assets Regulation (MiCAR).

The reporting requirements for issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs) *fun fact: Not to be confused with the EMT European MiFID Template* cover several critical templates and specific data points to ensure regulatory compliance and transparency outlineing the need to report on own funds, including the minimum required, reserves, fixed overheads, and ratios between funds and reserves, with adjustments based on stress testing outcomes. Also it addresses the maturity ladder of reserve assets, requiring issuers to allocate assets, inflows, and outflows across time buckets based on their residual maturities, while ensuring accurate market value reporting and currency conversion.

In addition, issuers must provide information for significance assessments, such as market capitalization, token issuance, and major holders of qualifying stakes, with reporting tailored to acquisitions, disposals, or changes in holdings. It also tracks token transactions, inflows, and outflows involving the EU, assessing their frequency and aggregate value. Furthermore, the instructions emphasize the use of standardized codes, methodologies, and regulatory definitions, ensuring consistency across different reporting templates.

These templates also mandate granular reporting on reserve asset quality (e.g., credit quality steps, liquidity) and derivative impacts, ensuring compliance with EU financial regulations like Regulation (EU) 2023/1114 (MiCAR). Overall, the framework provides a comprehensive approach to monitoring ARTs and EMTs for stability, transparency, and compliance.

The reporting requirements for crypto asset service providers include providing detailed information on holders and transactions using specific templates. One template captures information on legal person holders, requiring their registered name, unique identifiers (such as LEI), holder classification (retail or non-retail), and country of registration. Another focuses on natural persons, requiring the hashed CONCAT—a pseudonymized identifier derived from nationality, birthdate, and name, processed via SHA-256—along with classification and country of habitual residence.

For transactions, the reporting includes the total number and aggregate value of transactions involving crypto assets used as means of exchange. It categorizes transactions as inflows to the EU (payee within the EU, payer outside) and outflows from the EU (payer within the EU, payee outside). The requirements emphasize consistency and adherence to regulatory standards, ensuring accurate aggregation of data for issuers and compliance with EU regulations.

As the regulatory landscape for crypto-asset management evolves, firms can turn to LPA, a distinct partner specializing in asset management regulation and regulatory reporting, to ensure compliance and streamline their reporting processes.