Legal & Privacy
This page outlines how regulated CASPs (Crypto-Asset Service Providers) under MiCA (Markets in Crypto-Assets Regulation) in the EU should report data related to Circle’s EMTs (Electronic Money Tokens), USDC & EURC, ensuring compliance with MiCA regulations.
Legal Background and Context
The EU Commission has published an Implementing Regulation (IR) under MiCA to ensure uniform reporting requirements for CASPs and issuers of e-money tokens (EMTs) or asset-referenced tokens (ARTs). While this Regulation covers only EMTs and ARTs denominated in a currency that is not an official currency of a Member State, the European Banking Authority (EBA) has adopted additional guidelines that cover all reporting obligations on EMTs and ARTs, including for those EMTs that reference EU currencies.
For details, you can access:
- The EU Commission Implementing Regulation on Reporting Obligations on ARTs/EMTs denominated in a currency that is not an official currency of a Member State: Link to IR Document
- The EBA Guidelines on Reporting on ARTs/EMTs: Link to Guidelines Document
- The EBA 2-page overview of all ART/EMT reporting obligations: Link to the EBA explainer
Since both USDC and EURC are regulated EMTs under MiCA, CASPs providing services in relation to USDC and EURC are mandated to share both quarterly and daily data points with Circle France as the issuer.
Reporting Obligations and Frequency
CASPs are required to report data on both a quarterly and daily basis:
- Quarterly Reporting:
- Data Points: Information on token holders, transaction volumes, transactions associated to its uses as means of exchanges, amongst others.
- Please find more details in the Annex 3 (Reporting for CASPs - templates) and Annex 4 (Reporting for CASPs - instructions) of the EU Commission Implementing Regulation and the EBA Guidelines also linked above.
- Deadlines: Data must be submitted by the 21st of April, July, October, and January for the previous quarter.
- Daily Reporting:
- CASPs must provide end-of-business day (6:00 PM CET, France) information on token holdings (see S.08.00 in the CASP reporting template and find more information in the instructions).
These data points are critical for Circle to fulfill its regulatory obligations under MiCA.
How to Report
CASPs must send their data to the provisional reporting email address below. Ensure compliance with the specified templates and formats outlined in the EU Commission IR and EBA Guidelines.
Email for Reporting: [email protected]
For queries or assistance regarding reporting requirements, you may also reach out to the same email address [email protected]
FAQ
What format would Circle would like to receive the periodic MICA EMT report?
CASPs should use the template provided (Annex III).
Which conversion rate to use?
See general remarks on the template state (Page 18, VII) which Circle will abide by.
Items that are not denominated in the reporting currency shall be converted into the reporting currency by using the ECB spot exchange rate applicable on the reporting reference date.
What cut off time & timezone?
By close of business (GMT+1 - Central European Standard Time) on the 21st of April, July, October, and January for the previous quarter. If the remittance day is a public holiday in the Member State of the competent authority to which the report is to be provided, or a Saturday or Sunday, data shall be submitted on the following working day.