The European Commission (the “Commission”) has adopted two important updates under the Markets in Crypto-Assets Regulation (“MiCA”). Delegated Regulation (EU) 2025/1125 (the “Delegated Regulation”) and Implementing Regulation (EU) 2025/1126 (the “Implementing Regulation”) were originally issued on the 5th of June 2025 and together, they provide for the authorisation process for asset-referenced tokens (“ARTs”), providing the first layer of technical detail that turns MiCA’s general principles into practical obligations for issuers and competent authorities.
Under MiCA, issuers of ARTs must obtain authorisation before offering such tokens to the public or seeking their admission to trading. While MiCA sets out the general framework, the delegated and implementing acts specify the substantive and procedural requirements that applicants must meet. Regulation 2025/1125 sets the content requirements, whereas Regulation 2025/1126 standardises the format and process for the application itself.
The Delegated Regulation, adopted as per Article 18(6) of MiCA, establishes the list of information that an applicant must provide in an application for authorisation. This includes detailed data on governance, financial soundness, reserve assets, risk management, IT systems, and internal controls. It also obliges issuers to ensure that all information is accurate, complete, and kept up to date until the date of authorisation. The Regulation further emphasises proportionality, while ensuring that competent authorities receive the all the required information to be able to assess the applicant’s suitability and compliance.
The Implementing Regulation on the other hand was adopted under Article 18(7) of MiCA and complements this by prescribing the standard forms, templates, and procedures to be used in such applications. It establishes a uniform application template across all the Member States to create a consistent process. The Implementing Regulation also introduces procedural obligations, such as notification of changes to submitted information and acknowledgement of receipt, which aim to harmonise supervisory practices across the European Union.
These regulations entered into force on the 5th of October following their publication in the Official Journal of the European Union in September 2025.
