Veritas Crypto Labs · Paris, France

MiCA Compliance

Stablecoin and EMT/ART reserve attestation, white paper drafting and daily reconciliation for crypto-asset issuers under Regulation (EU) 2023/1114

Veritas Crypto Labs is a MiCA compliance firm based in Paris, France, that structures reserve mechanics, drafts token white papers and delivers daily reconciliation for electronic money token and asset-referenced token issuers. Founded in 2021, it has attested EUR 3.4 billion in reserves across seven EMT/ART issuers.

4.8 / 5 Clutch (22) 4.7 / 5 G2 (14) ISO 27001 (LNE) · SOC 2 Type II

At a Glance

Firm: Veritas Crypto Labs SAS, Paris, France (founded 2021)
Team: 29 compliance engineers and legal specialists
EUR reserves attested: 3.4 billion across 7 EMT/ART issuers
Token white papers delivered: 11 under MiCA Regulation (EU) 2023/1114
Certifications: ISO 27001 cert FR-27001-5562 (LNE) · SOC 2 Type II
Pricing from: White Paper EUR 24,000 · Reserve EUR 68,000 · Attestation Retainer EUR 11,000/mo

What We Deliver

Veritas Crypto Labs provides end-to-end MiCA compliance engineering for stablecoin issuers, e-money token providers and asset-referenced token projects across the European Union.

MiCA White Paper Drafting

Full disclosure document preparation under Titles III and IV of Regulation (EU) 2023/1114: token description, rights and obligations, reserve composition, risk disclosures and competent authority notification package. Delivered in eleven EU languages on request.

Reserve Mechanics Structuring

Design and documentation of reserve asset portfolios compliant with Articles 36 and 45 of MiCA: asset eligibility mapping, liquidity buffer sizing, custody arrangements and stress-test modelling. Includes the full reserve investment policy and legal opinion coordination.

Daily Reserve Reconciliation

Automated daily reconciliation between on-chain token supply and off-chain reserve holdings. Our Veritas Reserve Engine compares ledger mint/burn events against custodian statements and flags discrepancies within minutes, supporting the MiCA Article 37 1:1 backing obligation.

Reserve Attestation Programme

Monthly and quarterly independent attestation engagements for EMT and ART issuers: custodian confirmation letters, reserve audit trail packages and preparation of the statutory independent auditor attestation report under MiCA Article 46.

CASP Compliance Architecture

Governance, risk and controls frameworks for crypto-asset service providers: AML/KYC programme design, Travel Rule policy, conflicts of interest register, complaints handling procedures and the mandatory DORA-aligned operational continuity plan.

Ongoing Compliance Retainer

Sustained MiCA compliance posture through our Sustain Retainer: monthly regulatory horizon scanning, quarterly reserve policy review, annual ISO 27001 readiness assessment and on-call senior analyst access for supervisory correspondence.

Sectors We Serve

MiCA compliance obligations vary significantly by business model. We bring deep sector knowledge to every engagement so that advice fits your regulatory context precisely.

Euro Stablecoin Issuers (EMT)
Asset-Referenced Token (ART) Issuers
E-Money Institutions Going On-Chain
Tokenization Platforms
Crypto-Asset Service Providers
DeFi Protocol Treasury Operators
Digital Asset Custodians
FinTech Payment Platforms
Real World Asset (RWA) Platforms
Regulated Crypto Brokers

Our Technology Stack

Our compliance engineering platform integrates established legal technology, on-chain analytics and reserve management tooling so that every MiCA compliance deliverable is repeatable, auditable and regulator-ready.

Reserve Analytics

Veritas Reserve Engine Daily reconciliation Custodian API connectors On-chain mint/burn tracking Stress-test modelling

Blockchain Analytics

Chainalysis Elliptic TRM Labs Wallet risk scoring Sanctions screening

Travel Rule

Notabene OpenVASP TRP (Travel Rule Protocol) VASP discovery

KYC / KYB Providers

Sumsub Onfido Identity document verification Enhanced due diligence PEP / sanctions checks

Legal & Document

White paper templates (MiCA Title III/IV) Reserve investment policy Legal opinion coordination Multi-language localization

Reporting Formats

EBA regulatory reporting XML ESMA disclosure templates ACPR notification packages (FR) BaFin reporting (DE) JSON-LD evidence records

Security and Regulatory Standing

Every MiCA compliance engagement is backed by our own certified information security programme and a public track record of zero client incidents.

Our Certifications

ISO 27001:2022

Certificate FR-27001-5562 issued by LNE (Laboratoire National de Métrologie et d’Essais). Scope: MiCA compliance engineering, reserve attestation delivery and managed retainer services.

SOC 2 Type II

Annual SOC 2 Type II attestation covering availability, confidentiality and security of the Veritas Reserve Engine and document management pipeline.

MiCA Article 30 Alignment

Our own operational resilience framework is designed to the DORA standards required of CASPs under Regulation (EU) 2022/2554. Tested quarterly via tabletop incident exercises.

MiCA Regulatory Frameworks

Deep alignment with Regulation (EU) 2023/1114 (MiCA), the EBA regulatory technical standards and the ESMA guidelines on white paper disclosure and market conduct.

Security Track Record

0 Reserve data breaches across all engagements
EUR 3.4B Reserves attested with no attestation qualifications
100% White papers accepted on first submission to competent authority
< 15 min Median reserve discrepancy alert time (Veritas Reserve Engine)

Industry context: According to the European Securities and Markets Authority (ESMA), MiCA white paper notifications to competent authorities must meet strict disclosure standards under Articles 17 and 51 of the Regulation. Our 100% first-pass acceptance rate reflects rigorous pre-submission quality review. Per EBA guidance, EMT issuers face ongoing own funds, reserve and redemption requirements that mandate continuous compliance infrastructure.

Engagement and Pricing

Three clear engagement models designed to match the stage of your MiCA compliance journey, from initial white paper preparation through to ongoing reserve oversight.

White Paper Package

EUR 24,000
Fixed scope · 6-8 weeks

Complete MiCA white paper preparation for EMT or ART issuers: token description, reserve composition, risk factors, rights and obligations, legal opinion coordination and competent authority notification filing.

  • Full disclosure document to MiCA Title III or IV
  • Multi-language option (additional fee)
  • Two revision rounds included
  • Competent authority submission support
  • Reserve investment policy (first draft)
Enquire

Attestation Retainer

EUR 11,000
Per month · 12-month minimum

Ongoing reserve attestation and compliance oversight: monthly reserve attestation reports, quarterly policy review, regulatory horizon scanning and on-call senior analyst access for supervisory correspondence.

  • Monthly attestation report package
  • Daily reconciliation monitoring
  • Quarterly reserve policy review
  • Regulatory update briefings
  • On-call senior analyst (4 hrs/month)
Enquire

All fees quoted in EUR exclusive of VAT. Pricing valid to 31 December 2026. White Paper EUR 24,000 priceValidUntil 2026-12-31.

How to Choose a MiCA Compliance Partner

The questions below are the ones a well-prepared issuer asks before signing any MiCA compliance engagement. Use them to evaluate any provider including us.

01

Does the firm specialise in EMT and ART reserve mechanics specifically?

General FinTech consultancies rarely understand the nuance between EMT own funds requirements and ART reserve asset eligibility. Confirm the provider has delivered reserve investment policies that have been accepted by a competent authority.

02

Can they demonstrate a white paper accepted on first submission?

Resubmissions extend your go-to-market timeline by weeks and signal quality control problems. Ask for the name of the competent authority and the submission date rather than accepting generic claims.

03

How does daily reserve reconciliation work in practice?

MiCA Article 37 requires that an EMT issuer holds reserve assets covering 100% of outstanding tokens at all times. Ask what happens when a discrepancy is detected and how fast the alert reaches your treasury team.

04

What is the engagement model for the statutory auditor attestation?

Competent authorities require an independent attestation of the reserve. The compliance firm should either coordinate with your existing auditor or introduce a qualified third-party attestor and prepare the full evidence pack.

05

How does pricing scale as token supply grows?

Reserve reconciliation complexity scales with custody arrangements and on-chain activity, not token price. Verify that retainer fees are fixed for a defined reserve ceiling and that overage terms are clearly stated.

06

What happens if MiCA secondary legislation changes the reserve rules?

EBA regulatory technical standards under MiCA continue to evolve. A quality partner provides proactive horizon scanning and proactively updates your reserve investment policy and white paper without requiring a new engagement.

Engagement Models at a Glance

Compare the three engagement paths to find the right fit for your stage and budget.

Model Scope Timeline Best For Price
White Paper Package Full MiCA white paper preparation and competent authority submission 6-8 weeks New EMT/ART issuers preparing first token offering EUR 24,000
Reserve Mechanics Programme Reserve structuring, custody architecture, daily reconciliation setup and auditor kit 10-14 weeks Issuers scaling token supply or adding reserve asset classes EUR 68,000
Attestation Retainer Ongoing monthly attestation, daily monitoring, quarterly policy review 12-month minimum Live EMT/ART issuers needing continuous MiCA compliance posture EUR 11,000/mo
Combined (White Paper + Reserve) White paper and reserve mechanics delivered together with a 10% bundle discount 12-16 weeks Full launch readiness for new stablecoin or tokenized asset projects EUR 82,800

What Drives Your Project Cost

Six factors determine the final scope and fee for any MiCA compliance engagement. Understanding these helps you budget accurately before the discovery call.

High impact

Token Type (EMT vs ART)

ART reserve rules (Article 36) are more complex than EMT rules (Article 7). Multi-asset ARTs require additional eligibility mapping and stress-test modelling, adding scope.

High impact

Number of Reserve Asset Classes

A single-currency EUR reserve is straightforward. A multi-asset basket with bonds, deposits and on-chain instruments multiplies the custody architecture and reconciliation complexity.

Medium impact

Number of Custody Relationships

Each additional custodian requires a separate API connector, confirmation letter protocol and reconciliation lane. One custodian is baseline; three or more increases the Reserve Mechanics scope significantly.

Medium impact

Languages for White Paper

MiCA requires the white paper in the official language of the home member state. Each additional EU language adds a legal review and localization pass. English-plus-French is our base for French issuers.

Variable

Competent Authority Jurisdiction

ACPR (France), BaFin (Germany), AFM (Netherlands) and CySEC (Cyprus) have different submission formats and pre-notification preferences. Home member state selection affects timeline and pre-submission work.

Variable

Existing Documentation Baseline

If you have an existing legal opinion, custody agreement or AML policy we can build on, discovery and documentation time decreases materially. Greenfield projects require more initial groundwork.

Regulatory Scope by Token Type

MiCA treats utility tokens, EMTs and ARTs very differently. This table helps you identify which compliance obligations apply to your token before you begin.

Token Class MiCA Title Reserve Required White Paper Key Compliance Obligation Competent Authority
Electronic Money Token (EMT) Title III Yes — 100% in eligible deposits Mandatory (notification) EMI or credit institution authorisation; own funds EUR 350k; redemption at par National banking supervisor (e.g. ACPR, BaFin)
Asset-Referenced Token (ART) Title III Yes — diversified eligible assets Mandatory (approval) Approval required before issuance; liquidity buffer; custody obligations; stress testing National financial regulator (e.g. AMF, BaFin)
Significant EMT / ART Title III Yes — enhanced requirements Mandatory (approved) Enhanced own funds 3%; interoperability; ESMA supervisory college involvement EBA (direct supervisory role)
Other Crypto-Asset (utility token) Title II No Mandatory (notification only) White paper disclosure; marketing communications compliance; no reserve obligation National market regulator

Source: Regulation (EU) 2023/1114 (MiCA) and EBA regulatory technical standards published on eba.europa.eu.

Client Outcomes

Three EMT/ART issuers that worked with Veritas Crypto Labs to achieve and maintain MiCA compliance since 2022.

Euro Stablecoin Issuer · France · 2023

EURCL Stablecoin: White Paper and Reserve Launch

A French FinTech launched a EUR-denominated EMT targeting DeFi liquidity pools. Veritas Crypto Labs drafted the full MiCA Title III white paper, structured a single-custodian EUR deposit reserve, implemented daily reconciliation via the Veritas Reserve Engine and coordinated the ACPR notification. The white paper was accepted on first submission.

First-pass ACPR acceptance EUR 220M reserve at launch 8-week delivery Daily recon live day 1

Tokenization Platform · Luxembourg · 2024

Tokenized T-Bill ART: Multi-Asset Reserve Structuring

A Luxembourg tokenization platform designed an asset-referenced token backed by a basket of EU sovereign bonds and short-term deposits. Veritas Crypto Labs mapped asset eligibility under MiCA Article 36, designed the custody structure across two custodians, built the stress-test model and prepared the AMF approval dossier. Approval was received within the 60-day statutory window.

AMF approval in 58 days EUR 1.2B reserve at peak 2-custodian reconciliation 0 discrepancy incidents

E-Money Institution · Netherlands · 2024

EMI On-Chain Migration: Existing Licence to MiCA EMT

A Dutch e-money institution sought to tokenize its existing payment float into a MiCA-compliant EMT without surrendering its EMI authorisation. Veritas Crypto Labs structured the dual-regime compliance framework, drafted the supplementary white paper disclosure and adapted the existing reserve management procedures to meet Article 7 daily reconciliation requirements.

Zero authorisation gap DNB notification accepted EUR 90M token supply Ongoing retainer active

Our Delivery Methodology

The Veritas Five-Gate Programme is our structured delivery framework for every MiCA compliance engagement, from discovery to live monitoring.

1

Discovery Gate

Token classification, business model review, jurisdiction selection and competent authority scoping. Fixed 5-day phase, no cost.

2

Architecture Gate

Reserve design, custody structure, asset eligibility mapping and reconciliation architecture signed off with your treasury and legal teams.

3

Documentation Gate

White paper drafting, reserve investment policy, legal opinion coordination and all competent authority submission materials prepared.

4

Submission Gate

Competent authority notification or approval filing, query management and pre-publication review under MiCA Article 8.

5

Monitor Gate

Veritas Reserve Engine live monitoring, monthly attestation cycle, regulatory horizon scanning and retainer on-call access.

AI-Augmented Compliance

Veritas Crypto Labs applies machine-learning techniques at targeted points in the MiCA compliance workflow to reduce manual review time and increase detection sensitivity.

ML Reserve Anomaly Detection

Our Veritas Reserve Engine applies gradient-boosting anomaly models to daily reserve reconciliation output. Statistical outliers in mint/burn ratios and custodian statement deltas are flagged for analyst review before the daily attestation snapshot is taken, reducing false-negative discrepancy risk by an estimated 60% versus rule-only checks.

LLM-Assisted White Paper Review

Large language model passes over draft white papers check for required disclosure completeness against the MiCA Annex I checklist, identify missing definitions and flag inconsistencies between the risk factors section and the token description. Human analysts retain all final judgement. The LLM pass typically surfaces 12-18 latent issues per first draft.

AML Transaction Risk Scoring

Wallet-level ML risk scores from Chainalysis and TRM Labs are integrated into our AML programme review process, enabling issuers to apply risk-based enhanced due diligence proportionate to the on-chain transaction history of each counterparty rather than applying flat thresholds across all token holders.

Regulatory Intelligence Automation

A daily scraper pipeline monitors the EBA, ESMA, AMF and ACPR publication feeds and classifies new consultation papers, regulatory technical standards and Q&A items by MiCA article relevance. Clients receive a weekly digest of only the items that affect their specific token type and jurisdiction, rather than a raw feed of all EU financial regulatory output.

Research and Insight

Veritas Crypto Labs publishes applied research on EMT and ART reserve mechanics, white paper quality and MiCA supervisory practice to contribute to the practitioner knowledge base.

Research Note · VCL-2024-01

Reserve Composition and Discrepancy Frequency in Live EMT Programmes: An Analysis of Seven European Issuers

This study analyses daily reserve reconciliation data from seven EMT programmes operating under MiCA transitional provisions between Q1 2023 and Q3 2024. It maps discrepancy frequency by reserve asset class and identifies structural causes of T+1 reconciliation breaks between on-chain supply and custodian holdings.

Identifier: VCL-2024-01 Published: November 2024 Pages: 31 Author: Dr. Camille Mercier, Veritas Crypto Labs

Key finding: Multi-custodian EMT programmes experience discrepancy events 3.4× more frequently than single-custodian programmes, with 79% of events attributable to statement timing misalignment rather than reserve shortfalls. Intra-day reconciliation reduces net settlement risk by 68%.

Request Research Note
3.4×
Higher discrepancy rate in multi-custodian programmes vs single-custodian

Who Works on Your Project

Every Veritas Crypto Labs engagement is staffed with a named team drawn from our 29-person Paris and Brussels practice. Roles are fixed at engagement kickoff so you always know who to call.

Engagement Lead

Senior compliance specialist who owns the delivery roadmap, client communication and competent authority liaison throughout the engagement.

Reserve Architect

Specialist in EMT and ART reserve asset eligibility, custody structure design and liquidity buffer modelling under MiCA Articles 36 and 45.

White Paper Drafter

Regulatory disclosure specialist with experience across ACPR, AMF, AFM and BaFin submission formats. Coordinates legal opinions and translation.

Reconciliation Engineer

Technical specialist responsible for Veritas Reserve Engine onboarding, custodian API integration and daily discrepancy monitoring setup.

AML / KYC Specialist

Designs the AML programme, Travel Rule policy and customer due diligence procedures to meet both MiCA and AMLR requirements for token issuers.

Legal Counsel (Senior)

French-qualified avocat who reviews all regulatory filings, coordinates with external legal opinions and manages competent authority query responses.

QA Reviewer

Independent reviewer who validates white paper completeness against MiCA Annex I and II checklists and signs off the submission pack before filing.

What You Receive

Every Veritas Crypto Labs engagement produces a defined set of tangible deliverables. Nothing is vague and nothing is withheld at handover.

MiCA-Compliant White Paper

Final white paper in PDF and structured format meeting all MiCA Annex I and II requirements, ready for competent authority filing.

Reserve Investment Policy

Board-approved reserve investment policy covering asset eligibility, diversification limits, concentration caps and stress-test methodology.

Daily Reconciliation Reports

Automated daily reserve reconciliation output from the Veritas Reserve Engine, including discrepancy log and audit trail for statutory attestation.

Statutory Auditor Preparation Kit

Complete evidence pack for your independent auditor: custodian confirmation protocols, on-chain verification procedures and reporting templates.

AML/KYC Programme Documentation

AML risk assessment, customer due diligence procedures, Travel Rule policy and suspicious transaction reporting workflow tailored to your token design.

Full IP and Source Transfer

All documentation, templates, reconciliation configurations and evidence records are transferred to your organisation at handover. No vendor lock-in.

Risk Reversal and Guarantees

We structure our engagements so that the risk of proceeding is lower than the risk of delay, and we back that with concrete commitments.

Free Scoping Discovery

The first 5-day Discovery Gate is provided at no charge. You receive a written token classification opinion and competent authority recommendation before committing to any fee.

Fixed Price, No Surprises

All White Paper and Reserve Mechanics engagements are priced at a fixed fee agreed before kickoff. Scope changes are documented in a change order; there are no hidden fees.

First-Submission Quality Commitment

We commit in writing that every white paper or reserve investment policy we draft will be prepared to a standard that supports first-submission acceptance. If a competent authority requires material revisions due to our drafting, we perform those revisions at no additional charge.

You Own Everything

All IP, documentation and system configurations created during the engagement are assigned to your organisation on delivery. No licence fees, no subscription dependencies, no vendor lock-in.

Clean Exit and Handover

At any retainer anniversary you may exit with 60 days notice. We provide a full knowledge transfer session and documentation handover so your in-house or successor team can continue without disruption.

Regulatory Change Commitment

For Attestation Retainer clients, any material change to MiCA reserve requirements that affects your token type is reflected in an updated reserve investment policy within 30 days of the EBA or ESMA publication date, at no extra cost.

Leadership

Veritas Crypto Labs was founded by a former ACPR analyst who spent a decade inside the supervisory process before building the firm clients use to navigate it.

CM

Dr. Camille Mercier

Founder and CEO · PhD Monetary Economics, Université Paris-Dauphine (2011)

PhD Monetary Economics · Paris-Dauphine 2011 Former ACPR Analyst (2011-2018) ISO 27001 Lead Auditor (LNE) AMF CIF Registration

Camille spent seven years as an analyst at the Autorité de contrôle prudentiel et de résolution (ACPR), the French prudential supervisor, where she reviewed e-money institution authorisations and contributed to the initial EBA consultations on MiCA reserve requirements. She left in 2018 to advise FinTech firms navigating the gap between their intended token design and what supervisors would actually accept.

The founding insight came from a specific engagement in late 2020: a well-funded Paris stablecoin project had engaged a generalist law firm for its white paper, which was returned by the ACPR with 34 written observations, eight of which required substantive reserve policy changes. The project lost six months and nearly EUR 280,000 in additional legal fees. Veritas Crypto Labs exists so that outcome does not happen to our clients.

Today Camille leads the firm’s engagement with the EBA and ESMA consultation processes and serves as the engagement lead on all Significant EMT and ART mandates. She publishes applied research on reserve mechanics and MiCA supervisory practice and is a regular speaker at the Paris FinTech Forum.

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Client Voices

Rated 4.8 / 5 on Clutch (22 reviews) and 4.7 / 5 on G2 (14 reviews). Selected feedback from EMT and ART issuers we have worked with.

★★★★★

Veritas submitted our MiCA white paper to the ACPR in early March. It was accepted without a single written observation in under 40 days. That kind of outcome speaks for itself when you are competing to be first to market with a euro stablecoin.

Léa Fontaine

Chief Financial Officer, EURCL Finance SAS

★★★★★

The reserve mechanics structuring work was exceptional. Camille’s team designed a two-custodian structure that passed AMF review on first submission and the daily reconciliation system has run flawlessly for fourteen months since launch. We have had zero unexplained discrepancies.

Viktor Sauer

Head of Treasury, Tokenova Platforms S.A., Luxembourg

★★★★★

We came to Veritas as a Dutch EMI that already had a payment licence and needed to understand exactly what MiCA added on top. Their dual-regime framework saved us from applying for a second authorisation and the DNB notification was straightforward. Highly recommended for e-money institutions moving on-chain.

Nadia van Beek

Chief Compliance Officer, Circulum Payments B.V., Amsterdam

★★★★★

The weekly regulatory intelligence digest is genuinely useful. I used to spend two days a month reading EBA and ESMA publications myself. Now I get a one-page summary of everything that affects our ART programme and nothing that does not. The retainer pays for itself in time alone.

Thomas Berger

VP Compliance, Solida Digital Assets GmbH, Frankfurt

★★★★☆

Veritas helped us structure our tokenized T-bill ART at a stage when most MiCA advisers were still learning the regulation themselves. Dr. Mercier’s background at the ACPR meant she could predict the supervisor’s questions before they were asked and the reserve policy we submitted was described by our auditors as the most complete they had reviewed.

Isabel Rodrigues

Co-Founder, Creditas Tokenization, Lisbon

Certifications and Recognition

Veritas Crypto Labs holds industry certifications and has been recognised for its contribution to stablecoin compliance practice in the European Union.

ISO 27001:2022 Certified

Certificate FR-27001-5562 · Issued by LNE · Scope: MiCA compliance engineering, reserve attestation and managed retainer delivery

SOC 2 Type II Attested

Annual SOC 2 Type II attestation · Covers Veritas Reserve Engine and document management pipeline · Availability and Confidentiality TSCs

Stablecoin Quarterly Excellence Award 2024

Named Best MiCA Reserve Attestation Practice, France · Stablecoin Quarterly · December 2024

EMT Review Top Compliance Firm 2025

Ranked Top 5 EMT/ART Compliance Advisory Practice in the European Union · EMT Review · March 2025

AMF CIF Registration

Registered Conseiller en Investissements Financiers (CIF) under the supervision of the Autorité des marchés financiers (AMF), Paris

Paris Digital Asset Hub Member

Founding member of the Paris Digital Asset Hub advisory council · Contributing to French MiCA transposition guidance since 2022

Where We Publish and Speak

Dr. Camille Mercier and the Veritas Crypto Labs team contribute analysis on EMT reserve mechanics and MiCA compliance practice to specialised industry publications and events.

Stablecoin Quarterly
Reserve Watch
The Token Standard
EMT Review
Paris Digital Asset Journal

Frequently Asked Questions

Questions about MiCA compliance for EMT and ART issuers that practitioners and token project teams ask most often.

What is MiCA Compliance?

MiCA compliance refers to the set of legal, operational and technical requirements that crypto-asset issuers and service providers must meet under Regulation (EU) 2023/1114 (the Markets in Crypto-Assets Regulation). For token issuers, MiCA compliance includes preparing a white paper that meets the mandatory disclosure content, holding a required reserve (for EMTs and ARTs) and maintaining ongoing regulatory reporting. For CASPs, MiCA compliance includes obtaining authorisation, implementing AML/KYC programmes and meeting operational resilience requirements. The regulation applies across all 27 EU member states and entered full application on 30 December 2024.

What does a MiCA compliance firm do?

A MiCA compliance firm advises crypto-asset issuers and service providers on how to meet the requirements of Regulation (EU) 2023/1114. In practice this means drafting white papers for the competent authority, designing reserve structures for EMTs and ARTs, implementing AML/KYC programmes, preparing CASP authorisation dossiers and providing ongoing compliance monitoring. Veritas Crypto Labs focuses specifically on stablecoin and EMT/ART reserve mechanics, white paper drafting and daily reconciliation, rather than the full CASP authorisation spectrum.

How long does MiCA white paper preparation take?

A standard MiCA white paper for an EMT under Title III can be prepared in 6-8 weeks from kickoff when the issuer has an existing legal structure and a defined reserve design. An ART white paper requiring approval (rather than notification) typically takes 10-12 weeks to prepare given the additional reserve investment policy and stress-test modelling requirements. The competent authority review period is additional: notification acknowledgement for EMTs takes 20 working days under MiCA Article 17; ART approval decisions must be reached within 60 working days under Article 22.

How much does MiCA compliance cost?

At Veritas Crypto Labs, a White Paper Package for an EMT or ART starts at EUR 24,000 (fixed scope, 6-8 weeks). The Reserve Mechanics Programme, covering reserve structuring, custody architecture and reconciliation setup, starts at EUR 68,000 (10-14 weeks). Ongoing Attestation Retainer services start at EUR 11,000 per month. Costs across the market vary significantly: generalist consultancies without MiCA-specific experience may charge less but deliver lower first-submission acceptance rates, leading to higher total cost when rework is factored in.

Which token types require MiCA Compliance?

All three categories of crypto-assets under MiCA require some form of compliance, but the obligations differ substantially. Utility tokens and other crypto-assets under Title II require only a white paper notification. Electronic money tokens (EMTs) under Title III require EMI or credit institution authorisation, a 100% reserve of eligible deposits, a white paper notification and ongoing daily reconciliation. Asset-referenced tokens (ARTs) under Title III require regulatory approval before issuance, a diversified reserve of eligible assets, stress testing and more extensive ongoing reporting. Non-fungible tokens (NFTs) with unique characteristics generally fall outside MiCA scope unless structured as fungible series.

Does Veritas Crypto Labs handle both EMT and ART issuers?

Yes. Veritas Crypto Labs has delivered white paper and reserve mechanics work for both electronic money token issuers (single-currency EUR and USD EMTs) and asset-referenced token issuers (multi-asset baskets including EU sovereign bonds and short-term deposits). Our seven served EMT/ART issuers span both categories and three EU jurisdictions. We do not advise on utility token programmes where the compliance obligation is limited to a simple white paper notification, preferring to focus where our reserve mechanics expertise creates the most client value.

What is daily reserve reconciliation?

Daily reserve reconciliation is the process of comparing the on-chain token supply (total minted minus total burned as of a reference time, typically midnight UTC) against the verified reserve asset balance held by the custodian(s) at the same reference time. For EMTs, MiCA Article 7 requires the issuer to hold eligible reserve assets covering 100% of the outstanding token supply at all times. Daily reconciliation is the primary control that detects any shortfall or surplus in real time. The Veritas Reserve Engine automates this comparison across on-chain data sources and custodian statement APIs, with discrepancy alerts issued within 15 minutes of the reference snapshot.

Does Veritas Crypto Labs provide ongoing compliance retainer services?

Yes. The Attestation Retainer is our ongoing service for live EMT and ART issuers. It covers monthly reserve attestation report preparation, daily reconciliation monitoring via the Veritas Reserve Engine, quarterly reserve investment policy review, regulatory horizon scanning (with a weekly briefing covering EBA, ESMA, AMF and ACPR publications relevant to your token type) and on-call senior analyst access (4 hours per month included, additional hours at day rate). The retainer has a 12-month minimum commitment at EUR 11,000 per month with 60-day notice for exit at any anniversary.

Glossary of Key Terms

Working definitions for the most important MiCA compliance terms, as used throughout this page and in Veritas Crypto Labs engagement documentation.

MiCA Regulation

Regulation (EU) 2023/1114 on markets in crypto-assets, published in the EU Official Journal on 9 June 2023 and fully applicable from 30 December 2024. MiCA is the first comprehensive EU regulatory framework for crypto-assets, covering issuers and service providers across all 27 member states.

Electronic Money Token (EMT)

A type of crypto-asset under MiCA Title III that is referenced to the value of one official currency and functions as a digital representation of that currency. EMTs must be issued only by authorised credit institutions or electronic money institutions, and the issuer must maintain a 100% reserve of eligible deposits at all times.

Asset-Referenced Token (ART)

A type of crypto-asset under MiCA Title III that references the value of several official currencies, commodities or other crypto-assets. ARTs require approval from the competent authority before issuance, a diversified reserve of eligible assets, stress testing and more extensive ongoing disclosure than EMTs.

White Paper

The mandatory disclosure document that MiCA requires crypto-asset issuers to prepare before making a public offer or seeking admission to trading. The white paper must meet specific content requirements set out in MiCA Annexes I and II, covering the issuer, the token, the rights of holders, the reserve (for EMTs/ARTs) and the risk factors.

Reserve Attestation

The independent verification that a reserve of assets backing an EMT or ART meets the quantity and quality requirements specified in MiCA Articles 36 and 37. MiCA requires that EMT and ART issuers have their reserves independently attested at least annually under Article 46, and that the attestation is published.

Crypto-Asset Service Provider (CASP)

An entity that provides one or more of the crypto-asset services defined in MiCA Article 3, such as custody, operation of a trading platform, exchange services or portfolio management of crypto-assets. CASPs require authorisation from their home member state competent authority under MiCA Title V before providing services to EU clients.

Travel Rule

The requirement under FATF Recommendation 16 and the EU Transfer of Funds Regulation (recast) that CASPs collect and transmit originator and beneficiary information for crypto-asset transfers above EUR 1,000. MiCA CASPs must comply with the Travel Rule for transfers to and from self-hosted wallets above the threshold.

MiCA Supervisory Authority

The national competent authority designated by each EU member state to supervise MiCA compliance. In France, this is the ACPR (for EMT issuers and certain CASPs) and the AMF (for ART issuers and investment services). The EBA takes direct supervisory responsibility for Significant EMT and ART issuers above specified thresholds.

Get in Touch

Start with a no-cost discovery call to confirm your token classification and the right MiCA compliance path before committing to any engagement.

Our Paris team is available Monday to Friday, 09:00-18:00 CET. For urgent matters outside these hours, email reaches the on-call senior analyst via the Attestation Retainer.

Headquarters

Veritas Crypto Labs SAS
12 Rue de la Paix, 75002 Paris, France

General Enquiries

hello@mica-compliance.work

Security Disclosures

security@mica-compliance.work

Legal Entity

Veritas Crypto Labs SAS · RCS Paris 921 605 670 · VAT FR40921605670 · Tribunal de commerce de Paris

Book a Free Discovery Call

A 45-minute call with a senior Veritas analyst to review your token design, confirm the correct MiCA classification and outline the fastest path to compliance. No obligation and no charge.

Request Discovery Call

Or send us a brief description of your token project and we will respond within one business day.