Source: OJ L, 2025/422, 31.3.2025

Article 4 Information to be included in the crypto-asset white papers

Summary What does Article 4 of the RTS on sustainability indicators say?

Article 4 sets out the sustainability disclosure obligations for persons drawing up crypto-asset white papers under Regulation (EU) 2023/1114.

It establishes a tiered disclosure framework, distinguishing between what is mandatory, what becomes mandatory upon crossing an energy consumption threshold, and what remains entirely optional.

This article directly complements Article 5, which imposes parallel obligations on crypto-asset service providers, making Article 4 the white paper equivalent of those website disclosure requirements.

Important points:

Persons drawing up crypto-asset white papers must include the mandatory climate and environment-related indicators set out in Table 2 of the Annex in all white papers.
If the yearly energy consumption reported in Table 2 exceeds 500,000 kilowatt-hours, also include the supplementary indicators from Table 3 of the Annex.
Disclosure of the optional indicators in Table 4 of the Annex is voluntary, but if any are included, the corresponding sources and methodologies must also be provided.

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

1. Persons drawing up the crypto-asset white papers referred to in Articles 6, 19 or 51 of Regulation (EU) 2023/1114 shall provide in those white papers the information referred to in Article 6(1), first subparagraph, point (j), Article 19(1), first subparagraph, point (h), and Article 51(1), first subparagraph, point (g), of Regulation (EU) 2023/1114, as set out in Table 2 of the Annex, in the format set out therein.
1. The persons referred to in paragraph 1 shall also provide in the white paper the information set out in Table 3 of the Annex, in the format set out therein, where the yearly energy consumption as reported in Table 2, field S.8, of that Annex exceeds 500 000 kilowatt-hours.
2. Where the condition laid down in the first subparagraph is not met, the persons referred to in paragraph 1 may provide in the white paper information on one or more of the supplementary indicators listed in Table 3 of the Annex in the format of the templates set out therein. When such information is included, the corresponding information on sources and methodologies referred to in that Table shall also be provided.
1. The persons referred to in paragraph 1 may provide in the white paper information on one or more of the indicators listed in Table 4 of the Annex, in the format set out therein. When such information is included, the corresponding information on sources and methodologies, referred to in that Table, shall also be provided.

Relevant recitals

Recital 4 Single regulation for consistent linked disclosures

The information referred to in Article 6(1), first subparagraph, point (j), Article 19(1), first subparagraph, point (h), Article 51(1), point (g), and Article 66(5) of Regulation (EU) 2023/1114 to be included in the crypto-asset white papers and on the websites of crypto-assets service providers regards climate and other environment-related impacts of consensus mechanisms and is therefore closely linked. To ensure consistency, coherence and comparability of that information, it is appropriate to regulate it by way of a single Regulation.

Recital 9 Quantitative indicators of gross energy consumption and emissions

Key indicators should be used to easily understand the impacts on climate and other environment-related impacts of the consensus mechanisms. To incentivise the use of more climate and environmentally friendly consensus mechanisms and to prevent greenwashing practices, it is crucial to rely to the extent possible on quantitative metrics. Quantitative metrics should display gross energy consumption and emissions, without reflecting potential off-setting mechanisms.

Recital 10 Annual energy consumption as mandatory indicator

Annual energy consumption should be used as the key mandatory indicator because it is considered to be the most conducive to investor awareness of the impact of consensus mechanisms. Considering the key role of electricity in the operation of DLT networks, electricity consumption should be considered a suitable proxy for energy consumption.

Recital 11 Supplementary indicators for higher-consumption mechanisms

In order to ensure a proportionate approach to sustainability information, it is appropriate to require additional information with regard to consensus mechanisms with more significant climate and other environment-related adverse impacts, especially where they exceed a certain level of energy consumption. Therefore, supplementary key indicators on energy and greenhouse gas (GHG) emissions should be used for crypto-assets issued via consensus mechanisms with higher levels of yearly energy consumption in order to deepen investors’ understanding on the adverse impacts of such consensus mechanisms.

Recital 12 Voluntary indicators on waste and resource use

In addition to mandatory and supplementary key indicators, it should be possible to voluntarily include, in a specific part of the white papers or the websites of crypto-asset service providers, information on climate and other environment-related indicators that may be more complex to assess or for which it may be more difficult to find relevant data, for instance in relation to waste production and the use of natural resources, such as water.

Table of contents

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