Crypto-asset activities

Crypto-asset service means any of the following services and activities related to any crypto-asset:

  • providing custody and administration of crypto-assets on behalf of clients
  • maintaining a trading platform for crypto-assets
  • exchanging crypto-assets for funds
  • exchanging crypto-assets for other crypto assets
  • executing orders for crypto-assets on behalf of clients
  • placing of crypto-assets
  • receiving and transmitting orders for crypto-assets on behalf of clients
  • providing advice on crypto assets
  • providing portfolio management on crypto assets
  • providing transfer services for crypto-assets on behalf of clients

Each service is defined in more detail in Article 3(1)(17-26) of the MiCA Regulation.

The provision of a crypto-asset service requires authorisation. Authorisation must be applied for from the competent authority of the applicant’s home Member State. The competent authority in Finland is the Financial Supervisory Authority (FIN-FSA). 

Upon receipt of an authorisation application, the FIN-FSA shall, within five working days, notify the crypto-asset service provider applying for authorisation in writing that the application has been received. Within 25 working days of receipt of an authorisation application, the FIN-FSA must assess whether the application contains all the required information (completeness assessment). At this stage, however, the FIN-FSA will not assess the quality of the information provided. The FIN-FSA may ask the applicant to supplement the application if some or all of the required information is missing. The FIN-FSA will set a deadline for the submission of any missing information. If the application remains incomplete after the submission of additional information, the FIN-FSA may refuse to continue examining the application (decision not to examine the application).

The FIN-FSA will notify the applicant when the application is complete, i.e. when it contains all the required information. Thereafter, the FIN-FSA has 40 working days to carry out a substantive assessment of the application. During this period, the FIN-FSA has the opportunity to request further clarifications, but only the first of these requests will suspend the 40 working day assessment period, for a maximum of 20 working days.

The FIN-FSA must notify the applicant of its decision within five working days of the date of the decision on the authorisation application.

In accordance with MiCA, crypto-asset services may also be provided by financial entities that already have another authorisation granted by the FIN-FSA than an authorisation as a crypto-asset service provider. Except for credit institutions, the range of allowed crypto-asset services is limited based on the type of authorisation, as set out in Article 60(2)–(6) of MiCA. However, financial entities, including credit institutions, must submit a notification of the matter to the FIN-FSA before providing these services. The notification procedure for financial entities wishing to provide crypto-asset services is set out in Article 60 of MiCA as follows:

  • The notification must be submitted to the FIN-FSA at least 40 working days before the financial entity intends to provide crypto-asset services for the first time. The FIN-FSA must notify the financial entity in writing within five working days that the notification has been received.
  • Within 20 working days of receipt of the information, the FIN-FSA must assess whether all the required information has been submitted.

A financial entity may not commence the provision of services before the FIN-FSA has confirmed in writing to the financial entity that the notification is complete.

The provision of crypto-asset services requires authorisation. The content of a crypto-asset service provider’s authorisation application is set out in Article 62 of MiCA, and more detailed requirements are laid down in Commission Delegated Regulation (EU) 2025/305.

Key content requirements for an authorisation application are the following:

  • Contact details of the undertaking (including LEI code) and constitutional documents (Article 1 of Commission Delegated Regulation (EU) 2025/305
  • Programme of operations for a three-year period, including among other things a description of the services to be provided, targeted clients and geographical areas of operation, as well as any group strategy (Article 2 of Commission Delegated Regulation (EU) 2025/305), including:
    • Policies and procedures on outsourcing (Article 73 of MiCA; Article 2(1)(k) and (l) of Commission Delegated Regulation (EU) 2025/305)
    • Financial forecasts under different stress scenarios (Article 2(1)(m) of Commission Delegated Regulation (EU) 2025/305)

  • Descriptions of prudential safeguards and minimum capital (Article 67 of MiCA; Article 3 of Commission Delegated Regulation (EU) 2025/305)
    • Note: Entities intending to provide services under both MiCA and the Act on Payment Institutions (297/2010) must comply separately with the respective prudential requirements.
  • Description of governance arrangements (Article 68 of MiCA; Article 4 of Commission Delegated Regulation (EU) 2025/305), including, among other things:
    • Organisation description
    • Description of internal control functions, allocation of responsibilities, reporting lines, and staff competence
      • Including a description of risk assessment and risk management procedures (Article 62(2)(i) of MiCA)
    • Complaints handling procedures (Article 71 of MiCA; Article 11 of Commission Delegated Regulation (EU) 2025/305 and Commission Delegated Regulation (EU) 2025/294)
    • Prevention and management of conflicts of interest (Article 72 of MiCA; Commission Delegated Regulation (EU) 2025/1142)
    • Wind-down plan (Article 74 of MiCA)
    • Pricing and sustainability information on crypto-assets associated with the services (Article 66 of MiCA and Commission Delegated Regulation (EU) 2025/422)
    • Record-keeping procedures for crypto-asset services, activities, orders and transactions (Commission Delegated Regulation (EU) 2025/1140)
    • Policies and procedures for preventing market abuse (Article 92 of MiCA; Commission Delegated Regulation (EU) 2025/885)
    • Policies and procedures to protect persons reporting infringements (Article 116 of MiCA; Act on the Protection of Persons Who Report Breaches of Union and National Law (1171/2022, so-called Whistleblower Act))
  • Continuity plan (Article 5 of Commission Delegated Regulation (EU) 2025/305; Commission Delegated Regulation (EU) 2025/299)
  • Policies, procedures, risk assessments and risk management methods for the prevention of money laundering and terrorist financing and compliance with sanctions (Article 6 of Commission Delegated Regulation (EU) 2025/305) (see guidance, in Finnish)
  • Management competence and fit & proper assessments (Article 7 of Commission Delegated Regulation (EU) 2025/305 and EBA/ESMA Joint Guidelines EBA/GL/2024/09 (ESMA75-453128700-10))
  • Owner fit & proper assessments (Article 8 of Commission Delegated Regulation (EU) 2025/305 and Commission Delegated Regulation (EU) 2025/414 and EBA/ESMA Joint Guidelines EBA/GL/2024/09 (ESMA75-453128700-10))
  • Descriptions of information systems (including assessments of compliance with DORA) (Article 9 of Commission Delegated Regulation (EU) 2025/305)
  • Description of the segregation and safeguarding of client assets (Article 70 of MiCA; Article 10 of Commission Delegated Regulation (EU) 2025/305)
  • Service-specific requirements: The applicant must also provide certain additional statements, depending on the type of crypto-asset services provided. Service-specific requirements are set out in Articles 75–82 of MiCA and in Articles 2(2)–(3) and 12–17 of Commission Delegated Regulation (EU) 2025/305, as well as in ESMA guidelines.

See also ESMA's Supervisory Briefing on Authorisation of CASPs under MiCA.
The regulatory framework is discussed in more detail on the FIN-FSA website under Capital markets -> Crypto-asset activities. 

Crypto-asset services may also be provided under another authorisation. Deposit banks may provide all crypto-asset services on the basis of a notification. In addition, the following entities are entitled to provide certain crypto-asset services: central securities depositories, investment firms, electronic money institutions, fund management companies, alternative investment fund managers, and stock exchanges. Entities providing crypto-asset services on the basis of any of the above authorisations must submit a notification in accordance with Article 60 of MiCA. More detailed requirements for the content of the notification are set out in Commission Delegated Regulation (EU) 2025/303. 

Key content requirements for the notification are the following:

  • Programme of operations for a three-year period, including among other things a description of the services to be provided, targeted clients and geographical areas of operation, as well as any group strategy (Article 1 of Delegated Regulation (EU) 2025/303), including:
    • Policies and procedures on outsourcing (Article 73 of MiCA; Article 1(1)(k) and (l) of Delegated Regulation (EU) 2025/303)
    • Financial forecasts under different stress scenarios (Article 1(1)(m) of Delegated Regulation (EU) 2025/303)
  • Continuity plan (Article 2 of Commission Delegated Regulation (EU) 2025/303; Commission Delegated Regulation (EU) 2025/299)
  • Policies, procedures, risk assessments and risk management methods for the prevention of money laundering and terrorist financing and compliance with sanctions (Article 3 of Commission Delegated Regulation (EU) 2025/303) (see guidance, in Finnish)
  • Descriptions of information systems (including assessments of compliance with DORA) (Article 4 of Commission Delegated Regulation (EU) 2025/303))
  • Description of the segregation and safeguarding of client assets (Article 70 of MiCA; Article 5 of Commission Delegated Regulation (EU) 2025/303)
  • Service-specific requirements: The notifier must also provide certain additional statements, depending on the type of crypto-asset services provided. Service-specific requirements are set out in Articles 75–82 of MiCA and in Articles 1(2)–(3) and 6–11 of Commission Delegated Regulation (EU) 2025/303, as well as in ESMA guidelines. 

Financial entities providing crypto-asset services on the basis of another authorisation, i.e. through the notification procedure, are required to comply with largely the same requirements as entities authorised as crypto-asset service providers. However, financial entities are not required to submit information demonstrating compliance with all of these requirements as part of the notification. Financial entities must nevertheless have this information available for the FIN-FSA’s ongoing supervision. 

Financial entities are not subject to the prudential requirements laid down in Article 67 of MiCA or the ownership requirements laid down in Articles 83–84 of MiCA. 

See also, as applicable ESMA’s Supervisory Briefing on Authorisation of CASPs under MiCA. The regulatory framework is discussed in more detail on the FIN-FSA website under Capital markets -> Crypto-asset activities.

Issuance, offering to the public and seeking admission to trading of EMTs

An e-money token may, as a general rule, be offered to the public or admitted to trading in the Union only if the issuer is a credit institution or an electronic money institution and has fulfilled the notification obligations and the crypto-asset white paper requirements laid down in MiCA for e-money tokens. MiCA does not provide for a separate authorisation for issuers of e-money tokens. Instead, the issuance of e-money tokens is subject to the issuer holding an existing authorisation as a credit institution or an electronic money institution. See

MiCA applies alongside other regulation for electronic money institutions and credit institutions in a complementary manner when these institutions issue an EMT. An issuer of an EMT must:

  • notify the FIN-FSA of its intention to issue an EMT at least 40 working days in advance
  • submit to the FIN-FSA a crypto-asset white paper related to the EMT at least 20 working days before its date of publication (see tab ‘Crypto-asset white papers’)
  • submit a recovery plan and a redemption plan to the FIN-FSA within six months of offering the e-money token to the public or its admission to trading (see EBA guidelines Guidelines on recovery plans under MiCAR | European Banking Authority and Guidelines on redemption plans under MiCAR | European Banking Authority)

Other persons may also, with the written consent of the issuer, offer an EMT to the public or seek its admission to trading. Such persons are not obliged to apply for authorisation.

Custody, administration or transfer of EMTs

If an electronic money institution intends to provide clients with custody, administration or transfer services for EMTs it has issued, it must notify the FIN-FSA of this in advance. See items ‘Providing crypto-asset services under other authorisation, i.e. notification procedure’, ‘Key content of the notification of a crypto-asset service provider’ and ‘Authorisation application and notification forms’.

If an electronic money institution intends to provide crypto-asset services related to crypto-assets other than EMTs it has issued itself, the electronic money institution must apply separately for authorisation as a crypto-asset service provider. In addition, if an electronic money institution intends to offer crypto-asset services other than custody, administration and transfer services related to EMTs it has issued itself, the electronic money institution must apply separately for authorisation as a crypto-asset service provider.

Credit institutions do not need to apply separately for authorisation in the above-mentioned situations. Credit institutions must, however, make a corresponding advance notification of the provision of services.

Issuance, offering to the public and seeking admission to trading of ARTs

As a general rule, an ART may only be issued by an entity specifically authorised as an issuer of ART. Authorisation is always granted for the issuance of one specific ART. Credit institutions are allowed to issue ARTs based on notification.

Processing an application

The FIN-FSA must assess within 25 working days of receiving an application for authorisation whether all of the required information has been included in the application. A deadline will be set for any request for further clarification, by which time the applicant must provide the missing information.

The FIN-FSA must prepare a draft decision on granting or denying authorisation within 60 working days of an application having been deemed to contain all of the necessary information. The FIN-FSA submits the draft decision for information to the European Banking Authority, the European Securities and Markets Authority, the European Central Bank and, if necessary, also to other central banks. The above parties must submit their views on the draft decision to the FIN-FSA within 20 working days. The FIN-FSA must make a decision on whether to grant or deny authorisation within 25 working days of the submission of the views of the above parties to the FIN-FSA.

A credit institution must notify the FIN-FSA at least 90 working days before an intended issuance. An ART must not be issued before the FIN-FSA has approved the notification and the white paper.  The approval procedure for the crypto-asset white paper of an asset-referenced token issued by a credit institution is set out in more detail in Commission Delegated Regulation (EU) 2025/296. 

Other persons may also, with the written consent of the issuer of an ART, offer the ART to the public or seek its admission to trading. Such persons are not obliged to apply for authorisation.

Key content of the application for authorisation of an issuer of an asset-referenced token

The content of the application for authorisation is set out in Article 18 of MiCA, and more detailed requirements are laid down in Commission Delegated Regulation (EU) 2025/1125. Key content requirements for an authorisation application are the following:

  • Crypto-asset white paper for ART (see tab ‘Crypto-asset white papers’)
  • Legal assessment of the nature of the crypto-asset
  • Contact information and instruments of incorporation of the entity
  • Programme of operations: description of the business model
  • Statement that the business model does not jeopardise market integrity, financial stability or operation of financial systems, or expose the issuer to serious money laundering or terrorist financing risks
  • Statements that any crypto-asset service providers acting as partners comply with anti-money laundering and counter-terrorist financing requirements.
  • Statements on prudential safeguards and minimum capital
  • Statement on governance arrangements, including
    • Statements and policies regarding the composition, custody and investment of the reserve of assets
    • Statements on the issuance and redemption mechanisms and the validation of transactions
    • Statements of holders’ rights
    • Liquidity management policy
    • Statement on the management of conflicts of interest
    • Descriptions of complaints handling procedures
  • Competence and fit & proper reports regarding management
  • Fit & proper reports regarding owners
  • Continuity plan and descriptions of information systems and information security (including statements of compliance with the DORA Regulation)

In addition, issuers of ARTs must, within six months of authorisation being granted, submit a recovery plan and a redemption plan to the FIN-FSA (see EBA guidelines Guidelines on recovery plans under MiCAR | European Banking Authority and Guidelines on redemption plans under MiCAR | European Banking Authority).

Key content of the notification of an issue of an asset-referenced token by a credit institution

The contents of the notification are provided for in Article 17 of MiCA. Key content requirements for the notification are the following:

  • Crypto-asset white paper for ART (see tab ‘Crypto-asset white papers’)
  • Legal assessment of the nature of the crypto-asset
  • Programme of operations: Description of the business model
  • Statement on governance arrangements, including
    • statements and policies regarding the composition, custody and investment of the reserve of assets
    • statements on the issuance and redemption mechanisms and the validation of transactions
    • statements of holders’ rights
    • liquidity management policy
    • statement on the management of conflicts of interest
    • descriptions of complaints handling procedures
  • Continuity plan and descriptions of information systems and information security (including statements of compliance with the DORA Regulation)

In addition, issuers of ARTs must, within six months of authorisation being granted, submit a recovery plan and a redemption plan to the FIN-FSA. A recovery plan must also be submitted to the Finnish Financial Stability Authority if the issuer is a credit institution.

A crypto-asset service provider must use the appropriate form when making an application or notification. It is possible to add attachments to the form. The crypto-asset service provider’s authorisation application must be submitted using this form. The notification of the provision of crypto-asset services must be submitted using this form. The FIN-FSA recommends that at least the following information is submitted together with the form:

  • contact details of the company’s designated contact person
  • contact details of the person representing the company in the authorisation or notification matter (if different from the company’s contact person)
  • the company’s billing details
  • the information to be entered in the public register under Article 109(5) of MiCA, or an indication of the annex to the application or notification where the information is provided.

The applicant or notifier must notify the FIN-FSA without undue delay of any changes to the information provided in the application or notification. The applicant or notifier must submit updated information using the forms referred to above.

Fit&Proper materials concerning reliability and suitability related to applications must be sent to the FIN-FSA's registry by separate e-mail and using this form.

A company applying for authorisation as an ART issuer must also use the appropriate form. The authorisation application must be submitted using this form.

Authorisation application and notification forms with their attachments are submitted to the FIN-FSA’s registry: kirjaamo(at)finanssivalvonta.fi or by post to Finanssivalvonta, Registry, PO Box 103, 00101 Helsinki. More information on, among other things, secure email as well as registry contact information.

 

 

For non-urgent MiCA-related matters, you can contact us at: MiCAquestions(at)finanssivalvonta.fi

Please note, however, that we do not read the email box daily and do not accept via this email address MiCA-related authorisation applications or other urgent contacts requiring action.

A fee is charged for processing an authorisation application or notification, as set out in the schedule of processing fees. A processing fee is charged for both positive and negative decisions. If the processing of a case is suspended due to the applicant’s withdrawal of their application, a fee will be charged for costs incurred in processing the case up to the time of cancellation.

In addition to the processing fee, companies providing crypto-asset services are charged an annual supervision fee. Supervision fees are regulated by the Act on the Supervision Fees of the Financial Supervisory Authority (1209/2023).

How are issuance, offering to the public and seeking admission to trading of crypto-assets regulated?

Regulation of issuance, offering to the public and seeking admission to trading of crypto-assets depends on the type of crypto-asset. There are three types of crypto-assets:

  • asset-referenced tokens (ARTs)
  • electronic money tokens (EMTs)
  • crypto-assets other than asset-referenced tokens (ARTs) or electronic money tokens (EMTs) (“other crypto-assets”)

What is offering of crypto-assets to the public?

Offering of crypto-assets to the public means any communication to persons, in any form and through any channel, that provides sufficient information about the terms of the offering and the crypto-assets being offered to enable potential holders to make a decision on the purchasing of these crypto-assets.

An electronic money token whose reference asset is the official currency of a Member State is considered to be offered to the public in the Union.

What is admission to trading of crypto-assets?

Admission to trading means that the crypto-asset is admitted to trading on at least one trading platform. The related obligations under MiCA may apply either to the person seeking admission of the crypto-asset to trading, or, in certain cases, to the operator of the trading platform.

How is marketing of crypto-assets regulated?

Marketing communications of crypto-assets must generally comply with all of the following requirements:

  • Marketing communications must be clearly identifiable as marketing communications.
  • The information must be fair, clear and not misleading..
  • The information must be consistent with the crypto-asset white paper.
  • Marketing communications must not be disseminated prior to the publication of the crypto-asset white paper.
  • Marketing communications must be submitted for information to the FIN-FSA on request.
  • In marketing communications, it must be clearly stated that a crypto-asset white paper has been published.

In addition to the general requirements mentioned above, marketing communications relating to an asset-referenced token and an e-money token must comply with all of the following requirements:

  • Marketing communications must include the issuer’s website address, telephone number and email address.
  • Marketing communications and any modifications thereto must be published on the issuer’s website.
  • Marketing communications shall contain a clear and unambiguous statement that the holders of the asset-referenced token or electronic money token have a right of redemption against the issuer at any time.

In addition to the general requirements mentioned above, marketing communications relating to crypto-assets other than ARTs and EMTs must comply with all of the following requirements:

  • Marketing communications must clearly include the website address, telephone number and email address of the offeror, the person seeking admission of the crypto-asset to trading, or the operator of the trading platform.
  • Marketing communications must be modified as necessary, and any modifications must be published on the website of the person seeking admission to trading or the operators of the trading platforms. Modified information must be provided upon request to the FIN-FSA.

Marketing communications must be available on the website of the offeror or the persons seeking admission to trading for as long as the crypto-assets are held by the public.

An asset-referenced token may, as a general rule, be offered to the public or sought for admission to trading in the Union only by the issuer of the asset-referenced token. The issuer may be an undertaking that is established in the Union and has been authorised by the competent authority of its home Member State. An applicant for authorisation must submit a crypto-asset white paper for the ART as part of the application for authorisation. The issuer may also be a deposit bank. A deposit bank must give notice of its intention to issue an ART and, prior to issuance, submit a crypto-asset white paper for the ART together with the said notification. 

Upon the written consent of the issuer of an asset-referenced token, other persons may also offer the asset-referenced token to the public or seek the admission to trading of that asset-referenced token. An authorised undertaking and a deposit bank are always obliged to draw up a crypto-asset white paper, even if a third party is handling offering to the public or seeking admission to trading with the consent of the issuer. Likewise, if the exemption from the authorisation requirement under Article 16(2) of MiCA could be applied to the issuance, the issuer is still obliged to publish a crypto-asset white paper.

The FIN-FSA must approve the crypto-asset white paper for the ART before issuance. The approval procedure is set out in more detail in Commission Delegated Regulation (EU) 2025/296. For more information on the submission of an authorisation application or a notification form, including appendices, see Applying for authorisation > Authorisation application and notification forms.

This section only deals with the content, publication and modification of crypto-asset white papers. For more information on the issuance, offering and seeking admission to trading and authorisations of ARTs, see Application for authorisation > Authorisations and notifications related to asset-referenced tokens (ARTs).

What are the content requirements for a crypto-asset white paper?

MiCA contains detailed requirements for the content of a crypto-asset white paper for an ART. The white paper must include all of the regulatory required information. See the content requirements regarding the crypto-asset white paper for ARTs in Article 19 and Annex II of the MiCA.

A crypto-asset white paper is drawn up in Finnish, Swedish or English. If an ART is also offered in a Member State other than the issuer’s home Member State, the crypto-asset white paper must also be drawn up in an official language of the host Member State or in English.

The crypto-asset white paper must be drawn up in a machine-readable format. More detailed guidance on the presentation format is provided in Commission Implementing Regulation (EU) 2024/2984. In addition, the European Securities and Markets Authority (ESMA) has published guidelines and model examples for preparing the crypto-asset white paper in machine-readable format (see MiCA White Paper Taxonomy 2025). Due to limitations of the FIN-FSA’s case management system, the crypto-asset white paper is also requested to be submitted in PDF format.

Publication of a crypto-asset white paper

A crypto-asset white paper approved by the FIN-FSA must be published on the website of the issuer of the ART. The approved crypto-asset white paper must be publicly available by the date of the commencement of the offering to the public of the ART or of the admission to trading of the said ART.

The approved crypto-asset white paper must be available on the issuer’s website for as long as the ART is held by the public.

Modification of a crypto-asset white paper

An obligation regarding the modification of a crypto-asset white paper for an ART is set out in Article 25 of MiCA.

Notification of changes relating to asset-referenced tokens and approval of the modified crypto-asset white paper

The issuer of an asset-referenced token must notify its home Member State’s competent authority (the FIN-FSA) of intended changes to its business model that are likely to have a significant impact on the purchase decisions of asset-referenced token holders or potential holders. Intended changes must be notified at least 30 working days before they enter into force. The notification obligation concerns changes that occur after the granting of authorisation under Article 21 of MiCA or after the approval of the crypto-asset white paper under Article 17 of MiCA for deposit banks. Examples of situations that trigger the notification obligation are set out in Article 25(1)(a)–(j) of MiCA.

The issuer of the ART must draw up a draft modified crypto-asset white paper and ensure that the order of the information presented therein is consistent with the original crypto-asset white paper. The issuer must submit a draft to the FIN-FSA. The FIN-FSA must approve, or refuse to approve, the draft modified crypto-asset white paper within 30 working days of acknowledgement of receipt thereof. During its examination of the draft modified crypto-asset white paper, the FIN-FSA may request any additional information or explanations concerning the white paper. When the FIN-FSA makes such a request, the time limit of 30 working days shall commence only when the FIN-FSA has received the additional information requested.

The notification of intended changes and the draft of the modified crypto-asset white paper are submitted to the FIN-FSA Registry by email to kirjaamo(at)finanssivalvonta.fi. The email must be titled “Modification of crypto-asset white paper”.

Publication of a modified crypto-asset white paper

The issuer of the ART must publish the modified crypto-asset white paper on its website. The modified crypto-asset white paper must be available on the issuer’s website for as long as the ART is held by the public.

In principle, only an issuer that is a credit institution or electronic money institution may offer an EMT to the public or seek its admission to trading. In addition, it is required that the issuer has published a crypto-asset white paper in accordance with Article 51 of MiCA and submitted the said crypto-asset white paper for information to the FIN-FSA.

Under certain conditions, other persons may also, with the written consent of the issuer, offer an EMT to the public or seek its admission to trading. Credit institutions or e-money institutions as referred to above are always obliged to draw up a crypto-asset white paper, even if a third party is handling offering to the public or seeking admission to trading with the consent of the issuer.

This section only deals with the content, publication and modification of crypto-asset white papers. For more information on the issuance, offering and seeking admission to trading of EMTs, see the section Crypto-asset activities on the FIN-FSA’s website. See also related regulation in Title IV of MiCA.

What are the content requirements for a crypto-asset white paper?

MiCA contains detailed requirements for the content of a crypto-asset white paper for an EMT. The white paper must include all of the regulatory required information.

A crypto-asset white paper is drawn up in Finnish, Swedish or English. If an EMT is also offered in a Member State other than the issuer’s home Member State, the crypto-asset white paper must also be drawn up in an official language of the host Member State or in English.

The crypto-asset white paper must be drawn up in a machine-readable format. More detailed guidance on the presentation format is provided in Commission Implementing Regulation (EU) 2024/2984. In addition, the European Securities and Markets Authority (ESMA) has published guidelines and model examples for preparing the crypto-asset white paper in machine-readable format (see MiCA White Paper Taxonomy 2025). See the content requirements regarding a crypto-asset white paper for EMTs in Article 51 and Annex III of MiCA. Due to limitations of the FIN-FSA’s case management system, the crypto-asset white paper is also requested to be submitted in PDF format.

Submission of a crypto-asset white paper to the FIN-FSA

As a rule, the issuer of EMTs must be authorised as an electronic money institution or a credit institution. The issuer must notify the FIN-FSA in advance of its intention to offer an EMT to the public or seek its admission to trading. The notification must be made at least 40 working days before the start of the offering or the application for admission to trading. The notification is submitted to the FIN-FSA Registry by email at kirjaamo(at)finanssivalvonta.fi, using secure email. The email must be titled “Notification of the issuance of an e-money token”. More information on the encryption of email is available under Contact information. For more information, see Applying for authorisation > Authorisations and notifications related to electronic money tokens (EMTs).

 A white paper describing the EMT must be notified to the FIN-FSA at least 20 working days before it is published. The white paper must be submitted to the FIN-FSA by email at the address kirjaamo(at)finanssivalvonta.fi, using a secure email connection. More information on the encryption of email is available under Contact information. The white paper may be submitted at the same time as the notification referred to in the paragraph above.

Note that the FIN-FSA does not approve white papers on EMTs. The issuer is therefore responsible for the content of the white paper in accordance with Article 52 of MiCA.

In connection with the submission of the white paper, the following information must be provided to the FIN-FSA:

  1. The name, legal form and legal entity identifier of the issuer.
  2. The commercial name, visiting address, telephone number, email and website of the issuer.
  3. The starting date, or, if not available at the time of the notification, the intended starting date, of the offer to the public or the admission to trading.
  4. Any other services provided by the issuer not covered by MiCA, with a reference to the applicable Union or national law.
  5. The issuer’s date of authorisation as a credit institution or electronic money institution and, where applicable, of withdrawal of either authorisation.

Publication of a crypto-asset white paper

The issuer of an EMT must publish on its website a crypto-asset white paper before offering the EMT to the public in the Union or seeking admission to trading of the EMT.

Modification of a crypto-asset white paper

Any significant new factor, any material mistake or any material inaccuracy that is capable of affecting the assessment of the e-money token shall be described in a modified crypto-asset white paper drawn up by the issuers. A modified crypto-asset white paper must be submitted for information to the FIN-FSA. The modified crypto-asset white paper and the reasons for the modification must be submitted to the FIN-FSA at least seven working days before publication. The modified crypto-asset white paper must be submitted to the FIN-FSA Registry by email to the address kirjaamo(at)finanssivalvonta.fi using secure email. The email must be titled “Modification of crypto-asset white paper”.

The modified crypto-asset white paper must be published on the issuer’s website.

Offering crypto-assets other than ARTs or EMTs requires, as a rule, that the offeror has drawn up a crypto-asset white paper, submitted it for information to the competent authority of the home Member State (the FIN-FSA) and published it, and has complied with the other provisions of Article 4 of MiCA.

The admission to trading of these other crypto-assets also requires a crypto-asset white paper in accordance with Article 5 of MiCA and compliance with the other provisions of Article 5.

When is it not necessary to draw up a crypto-asset white paper?

It is not necessary to draw up, submit to the FIN-FSA and publish a white paper for a crypto-asset other than an ART or an EMT when one of the following exemptions applies to the offering:

  • The crypto-assets are offered to fewer than 150 persons
  • The total consideration of the offering does not exceed EUR 1,000,000 over a period of 12 months
  • The offering is addressed solely to qualified investors and only qualified investors can hold the crypto-assets.

In the above-mentioned cases, however, the offeror must be a legal person and must comply with the requirements set out in Article 14 of MiCA. Even the legal person requirement and Article 14 of MiCA do not apply if the crypto-asset is offered for free or created automatically as a reward for the maintenance of a distributed ledger (DLT) or the validation of transactions. These requirements also do not apply if the offer is for a utility token that represents the right of access to an existing product or service. The requirements are also waived if the crypto-asset can only be used to acquire products and services within a limited network of service providers.

None of the above-mentioned exception criteria can be applied in the event of an admission to trading of the crypto-asset being sought. 

When a person seeks admission to trading of a crypto-asset, a crypto-asset white paper needs to be drawn up only in connection with the first admission to trading. There is therefore no need to draw up a white paper separately for each platform in connection with listing. One condition is that the white paper must be kept up to date as regulatorily required.

What are the content requirements for a crypto-asset white paper?

MiCA contains detailed requirements for the content of a crypto-asset white paper. The white paper must include all of the regulatory required information. The crypto-asset white paper must include information about a 14-day right of withdrawal.

A crypto-asset white paper is drawn up in Finnish, Swedish or English. The crypto-asset white paper must be drawn up in a specified machine-readable format. More detailed guidance on the presentation format is provided in Commission Implementing Regulation (EU) 2024/2984. In addition, the European Securities and Markets Authority (ESMA) has published guidelines and model examples for preparing the crypto-asset white paper in machine-readable format (see MiCA White Paper Taxonomy 2025). Due to limitations of the FIN-FSA’s case management system, the crypto-asset white paper is also requested to be submitted in PDF format.

See content requirements for other crypto-assets in Article 6 and Annex I of the MiCA.

Submission of crypto-asset white paper and other information to the FIN-FSA

Crypto-asset white papers for crypto-assets other than ARTs or EMTs are submitted for information to the FIN-FSA.

The FIN-FSA does not check or approve these crypto-asset white papers.

The crypto-asset white paper notification should be accompanied by an explanation as to why the crypto-asset in question does not fall outside the scope of MiCA or is not an EMT or ART.

If the intention is to offer a crypto-asset or seek its admission to trading also in other Member States, a list of these Member States should be submitted to the FIN-FSA in the notification.

The following must be submitted to the FIN-FSA:

  1. A crypto-asset white paper
  2. An explanation of the applicability of MiCA
  3. A list of host Member States (if applicable)

This information must be submitted at least 20 working days before the date of publication of the crypto-asset white paper.

Publication of a crypto-asset white paper

The crypto-asset white paper must be published on the offeror’s website within a reasonable time before offering to the public begins and, in any case, before the start of the offer period. A corresponding requirement applies to a situation in which an entity is seeking admission to trading of a crypto-asset. The crypto-asset white paper must be available on the website for as long as the crypto-asset is held by the public.

Modification of a crypto-asset white paper

The published crypto-asset white paper must be modified whenever there is a significant new factor, material mistake or material inaccuracy. The modified crypto-asset white paper and the reasons for the modification must be submitted to the FIN-FSA at least seven working days before publication. The FIN-FSA must also be notified on the intended date of publication. The obligation to modify the crypto-asset white paper continues for the duration of the subscription period of the offering or for as long as the crypto-asset is admitted to trading.

Publication of result of offering to public

The offeror of crypto-assets must publish the result of the offering on its website within 20 working days of the end of the subscription period. If no end date is set for the subscription period, the offeror must publish on its website at least monthly the number of crypto-assets in circulation.

Asset safeguarding arrangements

During the offering to the public, only a credit institution and a crypto-asset service provider that provides custody and administration of crypto-assets on behalf of clients can take care of the custody of the funds or crypto-assets collected.

A fee is charged for processing an authorisation application of an ART issuer, as set out in the schedule of processing fees. A processing fee is charged for both positive and negative decisions. If the processing of a case is suspended due to the applicant’s withdrawal of their application, a fee will be charged for costs incurred in processing the case up to the time of cancellation. 

Crypto-asset issuers, offerors to the public, and persons seeking admission to trading are charged an annual supervision fee. Supervision fees are regulated by the Act on the Supervision Fees of the Financial Supervisory Authority (1209/2023).