출처 검증 리서치: ESMA MICA Register HOW

Verified source facts

1. ESMA groups the interim-register data into crypto-asset white papers, ART issuers, EMT issuers, authorised CASPs and non-compliant entities. 2. The ESMA page identifies September 9, 2026 as the latest update visible during this review. 3. ESMA warns that white papers recorded in the register have not been reviewed or approved by national competent authorities. 4. MiCA authorisation and transitional arrangements require reading the legal entity, jurisdiction, service scope and applicable dates rather than relying on a brand name.

Comparison at a glance

1. Control test: Legal name

A trading-control disclosure is meaningful only when converted into a testable rule. For legal name, inspect the regulated entity rather than a trading brand. Use a sandbox, non-production context, or the smallest reversible test available, then match the exact company name. Capture configuration and event evidence without recording credentials, and verify the documented cancel, reject, decrement, or history behavior.

Model the failure path, not just the setup path. Ask which strategy owns the maker and taker orders, which account boundary the venue evaluates, which message reveals intervention, and how reconciliation behaves after a partial fill or disconnect. Platform documentation describes supported settings; it cannot prove that an operator configured them correctly. In this dimension, brand-to-entity routing for a future session is therefore an explicit audit gap.

The legal name row should end with a concrete monitoring rule tied to the regulated entity rather than a trading brand. Make the operator match the exact company name, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; brand-to-entity routing for a future session remains a separate production risk until observed.

2. Control test: Identifier

For identifier, inspect LEI or other unique record key. Use a sandbox, non-production context, or the smallest reversible test available, then retain the identifier in the evidence file.

In this dimension, clerical errors in source submissions is therefore an explicit audit gap.

The identifier row should end with a concrete monitoring rule tied to LEI or other unique record key. Make the operator retain the identifier in the evidence file, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; clerical errors in source submissions remains a separate production risk until observed.

3. Control test: Home state

For home state, inspect which national authority owns supervision. Use a sandbox, non-production context, or the smallest reversible test available, then open the competent authority record.

In this dimension, cross-border servicing limits is therefore an explicit audit gap.

The home state row should end with a concrete monitoring rule tied to which national authority owns supervision. Make the operator open the competent authority record, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; cross-border servicing limits remains a separate production risk until observed.

4. Control test: Service scope

For service scope, inspect which crypto-asset services are authorised. Use a sandbox, non-production context, or the smallest reversible test available, then compare the intended job with the listed permissions.

In this dimension, account-level product availability is therefore an explicit audit gap.

The service scope row should end with a concrete monitoring rule tied to which crypto-asset services are authorised. Make the operator compare the intended job with the listed permissions, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; account-level product availability remains a separate production risk until observed.

5. Control test: Register category

For register category, inspect CASP, ART, EMT, white paper or non-compliant entity. Use a sandbox, non-production context, or the smallest reversible test available, then avoid mixing categories.

In this dimension, future category changes is therefore an explicit audit gap.

The register category row should end with a concrete monitoring rule tied to CASP, ART, EMT, white paper or non-compliant entity. Make the operator avoid mixing categories, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; future category changes remains a separate production risk until observed.

6. Control test: Update date

For update date, inspect weekly snapshot freshness. Use a sandbox, non-production context, or the smallest reversible test available, then record access time and download version.

In this dimension, submission lag from national authorities is therefore an explicit audit gap.

The update date row should end with a concrete monitoring rule tied to weekly snapshot freshness. Make the operator record access time and download version, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; submission lag from national authorities remains a separate production risk until observed.

7. Control test: White-paper status

For white-paper status, inspect publication without authority approval. Use a sandbox, non-production context, or the smallest reversible test available, then read issuer responsibility language.

In this dimension, accuracy of issuer disclosures is therefore an explicit audit gap.

The white-paper status row should end with a concrete monitoring rule tied to publication without authority approval. Make the operator read issuer responsibility language, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; accuracy of issuer disclosures remains a separate production risk until observed.

8. Control test: Transitional status

For transitional status, inspect legacy operation versus full MiCA authorisation. Use a sandbox, non-production context, or the smallest reversible test available, then check the applicable national deadline.

In this dimension, future enforcement action is therefore an explicit audit gap.

The transitional status row should end with a concrete monitoring rule tied to legacy operation versus full MiCA authorisation. Make the operator check the applicable national deadline, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; future enforcement action remains a separate production risk until observed.

9. Control test: Negative evidence

For negative evidence, inspect absence or non-compliant listing. Use a sandbox, non-production context, or the smallest reversible test available, then investigate with the authority before funding.

In this dimension, whether a new filing is pending is therefore an explicit audit gap.

The negative evidence row should end with a concrete monitoring rule tied to absence or non-compliant listing. Make the operator investigate with the authority before funding, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; whether a new filing is pending remains a separate production risk until observed.

10. Control test: Decision boundary

For decision boundary, inspect regulatory record versus safety or investment merit. Use a sandbox, non-production context, or the smallest reversible test available, then use the register as one due-diligence layer.

In this dimension, future operational conduct is therefore an explicit audit gap.

The decision boundary row should end with a concrete monitoring rule tied to regulatory record versus safety or investment merit. Make the operator use the register as one due-diligence layer, retain the venue response, and assign an owner for exceptions. Documentation quality is a useful signal, but it does not certify the exchange or the trading system; future operational conduct remains a separate production risk until observed.

Decision scenarios

Scenario 1: when legal name becomes decisive

Consider a reader whose main constraint is the regulated entity rather than a trading brand. The correct response is not to infer a universal platform or product winner. It is to match the exact company name, retain the evidence, and define a stop condition before funds or permissions are committed. If the evidence changes, the decision must be reopened. This produces a repeatable operating rule rather than a one-time opinion.

Scenario 2: when identifier becomes decisive

Consider a reader whose main constraint is LEI or other unique record key. It is to retain the identifier in the evidence file, retain the evidence, and define a stop condition before funds or permissions are committed.

Scenario 3: when home state becomes decisive

Consider a reader whose main constraint is which national authority owns supervision. It is to open the competent authority record, retain the evidence, and define a stop condition before funds or permissions are committed.

Scenario 4: when service scope becomes decisive

Consider a reader whose main constraint is which crypto-asset services are authorised. It is to compare the intended job with the listed permissions, retain the evidence, and define a stop condition before funds or permissions are committed.

Scenario 5: when register category becomes decisive

Consider a reader whose main constraint is CASP, ART, EMT, white paper or non-compliant entity. It is to avoid mixing categories, retain the evidence, and define a stop condition before funds or permissions are committed.

Scenario 6: when update date becomes decisive

Consider a reader whose main constraint is weekly snapshot freshness. It is to record access time and download version, retain the evidence, and define a stop condition before funds or permissions are committed.