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]
If you prefer to share the file via secure Trusted Data Format (TDF) encryption, please upload your file here.
FAQ
What are some common mistakes Circle has seen in the previous quarters submissions?
To further assist our Partners, we have put together a downloadable guide which highlights common reporting mistakes for specific forms, file formats, and naming conventions.
Most notably, we’d like to point your attention to S 06.00 - Information on holders - For natural persons: Based on recent EBA feedback, we strongly recommend all CASPs to use a hashed CONCAT code and submit pseudonymous data only instead of PII. You can find the exact hashing methodology that needs to be followed strictly in our guide or in the EBA guidelines. Please let us know in advance in case you will not be able to follow this approach as we have to ensure consistency on our end.
What format would Circle would like to receive the periodic MICA EMT report?
To support consistent and efficient reporting, Circle has prepared standardized template files to assist CASPs in providing the required information under MiCAR. These templates align with the structure and instructions of Annex III (CASP reporting) and are designed to minimize errors and ensure data is submitted in a format that issuers can readily reconcile.
CASPs may complete and submit the templates using Excel, Google Sheets, or .csv format, depending on their internal systems and preferences. CASPs that do not use either Annex III provided by the EBA or Circle’s standardized templates, may face delays or rejections of their submissions during data computation by Circle systems.
Circle Standardized Template Files
What should a CASP do if it has no reportable data for a given period?
CASPs must still submit a “Nothing to Report” confirmation to Circle by the reporting deadline. This ensures completeness and avoids gaps in issuer consolidation.
How should file submissions be named?
CASPs must follow the standardized naming convention:
- Daily files (S 08.00): MICA_S08.00_YY.MM.DD - CASP NAME
- Quarterly files: MICA_YYYY_QX_ALL - CASP NAME
This avoids confusion and supports automated reconciliation.
Are CASPs required to report in token units or EUR?
All monetary values must be reported in EUR only, using the ECB spot exchange rate at the reporting date. Reporting in token units.
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 is the 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.
How should CASPs handle transactions involving non-custodial wallets?
For transaction reports (S 07.01, S 07.03, and S 07.05), CASPs must include transactions with non-custodial wallets on a best-effort basis, using available information. CASPs should make reasonable estimates where full visibility is not possible. However, internal wallet rotations or self-transfers that do not change beneficial ownership must be excluded.
What if a CASP discovers an error after submission?
CASPs must promptly resubmit the corrected file using the same naming convention with a version suffix (e.g., _V2). The updated file should be sent to the reporting mailbox with a note indicating it replaces the earlier submission.