Crypto whitepapers must be submitted to BaFin as XHTML files from 23 December 2025

Under MiCAR, providers of crypto-assets (including stablecoins, asset-referenced tokens (ARTs), utility tokens and cryptocurrencies) are generally required to publish a white paper and submit it to the competent authority of the home Member State before offering the crypto-asset to the public or applying for its admission to trading. The German supervisory authority BaFin is the competent authority, if your home Member State is Germany.

In the case of asset-referenced tokens (ARTs), the white paper must be submitted together with the application for authorisation. For utility tokens and cryptocurrencies, the white paper must be filed with BaFin no later than 20 days prior to the start of the public offer or the application for admission to trading.

As from 23 December 2025, Implementing Regulation (EU) 2024/2984 will apply, specifying the required content and format of the white paper. Under this regulation, white papers must be prepared as XHTML documents using XBRL. The use of inline XBRL technology – embedding XBRL mark-ups within XHTML documents – allows white papers to be both machine-readable and easily accessible for human users.

The German law firm Kronsteyn supports you throughout the entire process of your crypto-asset offering. The firm drafts your white paper (also in XHTML) or reviews your existing white paper. Your contact person: Attorney at law Dr. Hendrik Müller-Lankow.