Source: OJ L, 2025/421, 24.3.2025

Article 3 Identification of the crypto-asset and the related white paper

Summary What does Article 3 of the RTS on crypto-asset white paper classification say?

This article sets out the rules for identifying crypto-assets within a white paper using digital token identifiers.

It establishes a primary standard — the ISO 24165 Digital Token Identifier — and provides a fallback mechanism for situations where that standard is unavailable.

In the fallback scenario, ESMA plays a central role by approving an alternative Union-level identifier that must meet a defined list of quality characteristics.

Important points:

When drawing up a crypto-asset white paper, use the ISO 24165 Digital Token Identifier to identify both the white paper itself (with a type 3 identifier) and each individual crypto-asset it covers.
Where the ISO 24165 Digital Token Identifier is not available, use an alternative digital token identifier approved by ESMA at Union level instead.
Any ESMA-approved alternative identifier must meet eight specific characteristics, including being unique, neutral, reliable, open source, scalable, accessible, available at a reasonable cost, and subject to an appropriate governance framework.

Springlex's summary of the article, a reading aid, not a substitute for the legal text.

1. When the ISO 24165 Digital Token Identifier is provided, the crypto-asset white paper shall be identified with a valid identifier of type 3 pertaining to the group of crypto-assets to which the white paper relates.
1. When the ISO 24165 Digital Token Identifier is provided, the crypto-asset or crypto-assets to which the crypto-asset white paper relates shall be individually identified with a valid identifier assigned to each of the crypto-assets to which the white paper relates.
1. When the ISO 24165 Digital Token Identifier is not available, the crypto-asset white paper shall identify the crypto-assets to which the crypto-asset white paper relates, by using a digital token identifier approved by ESMA at Union level, which meets all of the following characteristics:
  1. unique;
  2. neutral;
  3. reliable;
  4. open source;
  5. scalable;
  6. accessible;
  7. available at a reasonable cost basis; and
  8. is subject to an appropriate governance framework.

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