Reserve Reporting

Reserve reporting for the EMI issuing e-money tokens under MiCA.

MiCA Requirements (Regulation EU 2023/1114)

Reporting to Competent Authorities — Art. 22 (ARTs), Art. 56 (EMTs)

Requirement	Data to report	Legal basis	Applies to
Quarterly report	See list below	Art. 22	ARTs with issue value > €100M
At least twice-yearly report to EBA and ECB	See list below	Art. 56(3)	EMT issuers (for significance assessment)
Standard forms and templates	Per EBA/Commission templates	EBA ITS (Art. 22(7)); Commission Implementing Regulation (EU) 2024/2902	ARTs, EMTs (non-EU currency)

Data to report — quarterly report (Art. 22):

1. Number of holders
2. Value of issued tokens
3. Size of reserve
4. Avg no. and value of transactions per day
5. Estimate of transactions used as means of exchange within currency area

Data to report — twice-yearly EBA/ECB report (Art. 56(3), Art. 43(1) criteria):

1. Number of holders
2. Value issued / market cap / reserve size
3. Avg transactions per day (count and value)
4. Gatekeeper status
5. International significance of activities
6. Financial-system interconnectedness
7. Additional tokens issued (if any)
8. Art. 22–type data where applicable

Exact content and format in Commission delegated acts (Art. 43(11)).

Sources: Art. 22 | Art. 56 | Art. 43 (significance criteria)

Reserve Audit — Art. 36 (ARTs)

Issuers of asset-referenced tokens must mandate an independent audit of the reserve every six months. Results notified to competent authority without delay (latest 6 weeks), published within 2 weeks.

Note: Art. 36 is in Title III (ARTs). EMTs are governed by EMD2 safeguarding + Art. 54. Audit applicability for EMT reserves to be confirmed (EMD2 / national law).

Source: Art. 36(9)–(10)

Open Questions

#	Question	Answers
Q1	Does the Art. 36 six-month independent reserve audit apply to EMT issuers, or only to ART issuers?
Q2	What is the reporting frequency for EMT issuers below the significance threshold — twice yearly per Art. 56(3) only, or more?
Q3	What exactly must be auditable — on-chain data, internal records, or both?
Q4	Which templates/forms apply?
Q5	Number of holders, avg transactions per day (count and value): is this about EMI transactions or on-chain transactions?
Q6	What exactly should be automated vs decided by hand? Do we need an app that builds the report?