While CASP licences grab headlines, MiCA's Title II disclosure regime has produced a nine-fold explosion of filed white papers. ESMA register data reveals 578 issuers, an Irish anomaly driven by exchange notifications, and a steady drumbeat of 150–200 filings per quarter.
Published: July 2026 · Data as of 16 July 2026 · Reading time: ~7 minutes
Key Takeaways
- 926 white papers for "other" crypto-assets (neither ARTs nor EMTs) are on file in ESMA's register, from 578 unique issuers — up from 103 papers and 55 issuers in July 2025.
- Ireland accounts for exactly half of all issuers (289 of 578) — an artefact of exchange-driven notifications, led by Kraken's Irish entity Payward with well over a hundred filings.
- Filing volume has settled into a rhythm of roughly 140–200 white papers per quarter since mid-2025.
- 267 register entries (29%) were notified by CASPs seeking admission to trading of existing tokens — a mechanism unique to Title II that lets exchanges, not issuers, do the paperwork.
- 248 entries carry a Digital Token Identifier (DTI), showing the ISO standard gaining real adoption through regulatory plumbing.
Title II: MiCA's Least Understood Register
Most crypto-assets are neither stablecoins nor service providers — they are tokens. For these, MiCA does not require authorisation but disclosure: a white paper notified to a national competent authority before a public offer or admission to trading in the EU. The register of these documents has become, in effect, the EU's official catalogue of lawfully offered tokens.
Its growth has been the steepest of any MiCA dataset:
| Snapshot | White papers | Unique issuers |
|---|---|---|
| 11 July 2025 | 103 | 55 |
| 11 September 2025 | 332 | 197 |
| Early November 2025 | 491 | 292 |
| Mid-January 2026 | 704 | 430 |
| 24 April 2026 | 836 | 524 |
| 16 July 2026 | 926 | 578 |
After the initial 2025 ramp-up, the filing cadence has stabilised at 140–200 papers per quarter — a regulatory production line rather than a gold rush.
The Irish Anomaly, Explained
Ireland's dominance — 289 of 578 issuers, and 344 of 926 papers — is the register's most striking feature, and it has little to do with Irish token projects. Title II allows the person seeking admission to trading, typically an exchange, to draw up and notify the white paper for an existing crypto-asset. Kraken's Irish entity (Payward Global Solutions) has used this mechanism at industrial scale, filing over a hundred notifications covering the tokens it lists — from major layer-1 assets to long-tail altcoins. Each token's "issuer" of record lands in the Irish column.
The same pattern explains Liechtenstein (72 papers, driven by LCX AG's 62 filings) and much of Luxembourg's count (Bitstamp Europe, 36). In total, 267 entries were notified by CASPs rather than original token issuers — with Kraken-related entities, LCX and Bitstamp the three most prolific filers.
| Country | White papers | Unique issuers | Driver |
|---|---|---|---|
| Ireland | 344 | 289 | Exchange notifications (Kraken/Payward) |
| Malta | 158 | 97 | Mixed: issuers + exchange filings |
| Germany | 142 | 19 | Few issuers, many papers — serial filers |
| Liechtenstein | 72 | 12 | LCX exchange notifications |
| Netherlands | 68 | 67 | Genuine issuer base, one paper each |
| Luxembourg | 52 | 17 | Bitstamp filings + fund-adjacent issuers |
| France | 26 | 18 | Domestic projects |
The contrast between Germany (19 issuers producing 142 papers) and the Netherlands (67 issuers producing 68 papers) is a study in market structure: Germany hosts a handful of professional issuance platforms filing serially, while the Dutch column reflects dozens of individual projects each filing once.
Why This Register Matters More Than It Looks
1. It is the EU's de facto token whitelist. Exchanges wanting to list a token for EU customers need a compliant white paper to exist. The register's growth curve is therefore a proxy for the breadth of the lawful European token market. 2. It shifted compliance work to exchanges. The CASP-notification route means the burden of documenting thousands of legacy tokens is being absorbed by a few large platforms — concentrating both the cost and the legal responsibility. 3. It is quietly standardising token identification. 248 entries carry an ISO 24165 Digital Token Identifier, giving supervisors a machine-readable map from legal disclosure to on-chain asset.
The Compliance Industry Behind the Numbers
At current pace, the register will pass 1,000 white papers in autumn 2026. Every entry represents legal drafting, NCA notification and ongoing update obligations — a recurring compliance market that did not exist two years ago. For law firms and consultancies in Dublin, Valletta and Vaduz, MiCA's least glamorous register may be its most lucrative.
Frequently Asked Questions
Does every crypto token need a white paper under MiCA? A MiCA-compliant white paper must be notified before a public offer in the EU or admission to trading on an EU platform, with limited exemptions (e.g. tokens offered to fewer than 150 persons per Member State, offers under €1 million over 12 months, or assets already qualifying under other exemptions).
Who can file a MiCA white paper? The offeror or issuer — but also, for tokens already trading, the CASP seeking admission to trading. 29% of current register entries were filed by CASPs, notably Kraken's Payward, LCX and Bitstamp.
Why does Ireland have so many crypto white papers? Because exchange-driven notifications are booked to the notifying entity's home state. Kraken's Irish entity has filed over a hundred white papers for tokens listed on its platform, placing Ireland far ahead of any other jurisdiction.
How many crypto-asset white papers exist under MiCA? 926 entries for other crypto-assets (non-ART, non-EMT) from 578 unique issuers, as of 16 July 2026 — plus 41 EMT white papers held in the separate EMT register.
Sources
- ESMA — Markets in Crypto-Assets Regulation (MiCA), interim register
- Regulation (EU) 2023/1114 (MiCA), Title II — EUR-Lex
- European Commission — Crypto-assets framework
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Analysis based on ESMA's interim MiCA register (other crypto-asset white papers file), snapshots 11 July 2025 – 16 July 2026. Quarterly series uses each entry's last register update date; issuer counts are unique legal-entity names.
Disclaimer: This article is provided for general information and analytical purposes only. It does not constitute legal, regulatory, investment, tax or any other form of professional advice, and it should not be relied upon as such. While we strive for accuracy, the underlying registers are updated frequently and figures may have changed since the stated data date. Always verify current information directly with official sources (ESMA, the European Commission, and national competent authorities) before making any decision. MICA Watch accepts no liability for any loss or damage arising from the use of this content.