The effects of the Markets in Crypto-Assets Regulation (MiCA) have started to bite, and many crypto asset issuers across the EU are already facing delisting from exchanges. According to the European Securities and Markets Authority (ESMA), updated disclosure rules come into force on December 23, 2025.
By that time, tokens issued before MiCA became law must be brought into compliance to avoid being removed from exchanges. Binance has already delisted over 8 stablecoins, and as MiCA’s transition deadline nears, many token issuers could face the same fate.
The exchange has advised its users to convert their non-MiCA-compliant stablecoins to USDC, EURI, and other available options. However, although USDT, USDP, DAI, and several others have been delisted from European exchanges, users can still withdraw and deposit (albeit limited) these stablecoins.
The White Paper is Now a Licence to Operate
Every crypto asset issuer must now submit a white paper to remain listed on European exchanges. Without it, your token simply doesn’t exist in the EU’s legal system.
The white paper is similar to a prospectus in traditional finance and must be published at least 20 working days before launch.
The process depends on the type of digital asset, with white papers for asset-referenced tokens (ARTs) and e-money tokens (EMTs) requiring approval from a national authority before publishing. However, issuers of regular crypto-assets that do not require prior approval can begin operations as soon as they submit their white paper.
According to MiCA rules, the white paper must show who is behind the token and provide a full description of the asset, including the supply, issuance schedule, custody, and governance. Additionally, it must also show the risks associated with the token and complaint-handling mechanisms.
The Delisting Wave Could Reshape Europe’s Crypto Market
New requirements for the MiCA white paper are expected to come into force less than two months from now, and all token issuers must update their existing white papers to meet them. As a result, we could see a wave of delistings, mainly affecting smaller, older tokens that can’t meet MiCA requirements.
Unlike the vague, marketing-heavy white papers that once defined the Initial Coin Offering era, issuers must submit verifiable disclosures to national regulators and, in the case of stablecoins, have the white papers reviewed and approved before issuance.
The updated requirements will undoubtedly reduce the number of tokens available, but they will also boost investor confidence.
Enforcement Underway
After more than two years in the works, the EU’s crypto regime is no longer just policy. Regulators have started monitoring crypto exchanges to ensure only MiCA-compliant assets are listed.
In September, ESMA reportedly contacted more than a dozen exchanges across Europe about listings that lacked valid white papers.
While few delistings have occurred so far, industry observers expect that to change quickly as the December deadline looms.
Exchanges Brace for Delisting Pressure
Exchanges must verify that each list is supported by a valid white paper. If not, they’re required to restrict or delist it. Crypto-asset service providers (CASPs) that fail to do so may attract fines of up to €20 million or 5% of a firm’s total annual turnover, whichever is higher. Additionally, they may also lose their licence.
Because MiCA operates on a passporting model, delisting in one EU member state can trigger restrictions across all 27 member states. Some exchanges, including Bitstamp and Kraken’s EU branches, have begun internal audits to ensure all assets meet the disclosure standard. Binance, which holds licences in France and Italy, has already started trimming its existing tokens ahead of the December deadline.
Stablecoins Face the Toughest Oversight
Stablecoins have been under heavy scrutiny across the globe, not just in the EU. Many countries, including Australia and the US, have enacted legal frameworks for stablecoins to impose strict disclosure requirements.
MiCA classifies stablecoins as ARTs and EMTs, and issuers must wait for their white paper to be approved before putting their token on the market.
ESMA Chair Verena Ross said earlier this month that stablecoins “remain a focal point for systemic risk” and that ESMA and the European Banking Authority are coordinating to “enforce MiCA’s reserve and redemption provisions with zero tolerance.”
Regulators can review white papers and block fragile stablecoins from entering the European market by simply withholding approval.
Most major stablecoins, such as Circle’s EURC and Société Générale’s EURCV, have met the updated disclosure requirements and are available in all major exchanges. Some, like Tether’s USDT, have chosen to pause their operations or exit the market altogether.
Cross-Border Gaps
While MiCA aims for harmonisation, its implementation remains uneven across the bloc. National regulators still interpret disclosure thresholds and environmental reporting obligations differently.
Many issuers are choosing to submit their white papers or apply for a licence in countries like Malta, which have relaxed requirements. As a result, more countries are pushing for EU-level supervision, with France warning it might block issuers licensed in other countries from doing business in the country.
“We do not exclude the possibility of refusing the EU passport,” Marie-Anne Barbat-Layani told Reuters. “It’s very complex legally and not a very good signal for the single market – it’s a bit like the ‘atomic weapon’… but it’s still a possibility we hold in reserve.”The European Banking Authority (EBA) has warned that some issuers are using regulatory arbitrage to avoid stricter supervision, leading to opaque disclosures. The authority called on national authorities to share information on licence approvals and close regulatory gaps.
