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arXiv · 2609.26932

Asset-Class Specific Sustainability Disclosure: Lessons Learned from the EU MiCA Regulation

Ulrich Gallersdörfer·Lena Klaaßen·Christoph Kreiterling·Christian Stoll
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Abstract

Sustainability disclosure in the European Union has so far focused on corporate reporting and sustainability information attached to traditional financial products. Crypto-assets, with consensus-mechanism-driven environmental externalities and fragmented issuer structures, largely fell through this disclosure architecture. The EU Markets in Crypto-Assets Regulation (MiCA) introduces the first EU-wide, asset-class-specific sustainability disclosure regime for crypto-assets by mandating standardised sustainability indicators for both issuers and crypto-asset service providers. Drawing on a policy and legal analysis of MiCA and its Level 2 measures, and on early implementation evidence from public registers and market practice, this paper shows how the policy approach shifted from debates about restricting energy-intensive consensus mechanisms to a transparency regime built on quantitative metrics, machine-readable reporting, and methodological alignment with the broader EU sustainable-finance framework. The paper also highlights practical frictions in implementation, including data gaps, responsibility allocation between issuers and intermediaries, and cross-border supervisory fragmentation. The overview and quantitative summary of the ESMA Interim MiCA Register in this paper may also provide valuable information to regulators and market participants in the context of the European Commission's 2026 targeted consultation on the review of MiCA, including its specific question on environmental and sustainability reporting.

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Ulrich Gallersdörfer, Lena Klaaßen, Christoph Kreiterling, Christian Stoll. 2026-09-22. Asset-Class Specific Sustainability Disclosure: Lessons Learned from the EU MiCA Regulation. https://arxiv.org/abs/2609.26932

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