Oct 29, 2025

MiCA Supply Disclosure Requirements

MiCA Supply Disclosure Requirements

Meet MiCA disclosure requirements for token supply, emission schedules, and vesting. Tokenomics.com provides MiCA-compliant tokenomics audits and documentation aligned with Annex I of the EU Markets in Crypto-Assets Regulation.

Intro

Under the Markets in Crypto-Assets Regulation (MiCA), every issuer offering or listing a token in the EU must disclose its token supply mechanics in a verifiable, structured format.

Tokenomics.com converts these regulatory obligations into MiCA-compliant supply disclosures, aligned with Annex I, points (5) and (6) — detailing total supply, creation and destruction mechanisms, emission schedules, and vesting structures affecting circulating supply and price formation.

What MiCA Requires

MiCA Article 6 and Annex I require issuers to explain not only how many tokens exist, but also how and when they enter or leave circulation.

MiCA Article 6 and Annex I mandate that each whitepaper must include:

a. Supply Description
A detailed explanation of the number of crypto-assets in existence, whether the quantity is fixed or subject to change, and the mechanisms governing creation or destruction (mint/burn).

b. Supply Schedule and Release Conditions
Disclosure of the timeline and conditions under which new tokens enter circulation, including vesting, lockups, and emission rates.

c. Impact on Holders and Market Liquidity
An explanation of how supply events may influence the market price or liquidity of the token.

Common Gaps Found in Token Whitepapers

These gaps are precisely what regulators target when assessing MiCA whitepapers, making accurate tokenomics modeling a compliance necessity rather than a design choice.

Most projects fail MiCA readiness due to:
• Incomplete emission schedules (missing dates or unlock logic)
• Undefined mint/burn authorities or inflation limits
• Hidden or non-transparent treasury allocations
• Lack of clarity on vesting and circulating supply projections

Tokenomics.com audits each of these components to ensure full disclosure and model consistency.

How Tokenomics.com Helps

Our MiCA-compliant tokenomics audit produces a disclosure pack including:
• Verified total and maximum supply analysis
• Emission, vesting, and lock-up modeling under MiCA format
• Inflation, dilution, and float-velocity assessments
• Month-by-month and year-by-year circulating-supply projections
• Integration-ready text for MiCA whitepapers and exchange listings

The result: an audit-verified, regulator-friendly tokenomics section that passes Annex I scrutiny.

Why It Matters

Transparent supply design prevents investor misrepresentation and satisfies MiCA’s goals of market integrity, price stability, and fair disclosure. Projects failing to disclose accurate supply data may face enforcement actions or be denied EU listings.

In other words, they risk regulatory enforcement, de-listing from EU exchanges, or reputational damage during compliance review.

Building MiCA-aligned tokenomics from inception ensures cross-jurisdictional legitimacy and enhances investor trust in the underlying economic design.

Technical Disclosure Framework

To comply with Annex I of Regulation (EU) 2023/1114 (MiCA), each crypto-asset whitepaper must include precise disclosures on the quantity, issuance conditions, and mechanisms affecting token supply.
Below are the clauses most relevant to tokenomics and how Tokenomics.com maps them into verifiable audit deliverables.

Annex I, Point (5)

“A description of the number of crypto-assets in existence and whether the quantity is fixed or subject to change, together with a description of the mechanisms that determine the creation of new crypto-assets or the burning of existing crypto-assets.”


Our Implementation

  • Smart-contract reconciliation: extract on-chain variables controlling total supply, mint/burn permissions, and cap logic; verify against whitepaper declarations.

  • Elastic supply modeling: quantify algorithmic rebases, validator rewards, or interest-bearing mechanisms that expand or contract supply.

  • Governance triggers: map DAO votes or upgrade functions that could alter issuance parameters and evaluate their frequency thresholds.

  • Supply audit sheet: produce deterministic equations representing total supply (S), newly minted tokens (Mₜ), and burns (Bₜ) → Sₜ = S₀ + Σ(Mₜ – Bₜ) validated against historical or simulated emissions.

  • Regulatory disclosure text: formatted paragraph ready for MiCA Annex I insertion, describing fixed, capped, or variable supply with source references.

Annex I, Point (6)

“A description of the timeline of issuance and the total amount of crypto-assets to be issued, the release schedule for the crypto-assets, and the conditions of their offering to the public.”


Our Implementation

  • Emission schedule modeling: generate month-by-month and year-by-year emission curves, identifying cliffs, linear unlocks, and step-wise releases.

  • Vesting logic parsing: convert smart-contract vesting functions into quantitative tables (unlock %, token count, and cumulative float).

  • Float & liquidity mapping: simulate circulating supply over time to project float-to-FDV ratios and potential liquidity stress points.

  • Allocation verification: cross-check allocations (team, investors, treasury, community) against total issuance and lock-up conditions.

  • Dilution metrics: compute real vs. theoretical inflation, highlighting months with >10 % supply shocks.

  • MiCA-ready charts: produce regulator-friendly visuals (time × circulating supply) labeled for whitepaper annex inclusion.

MiCA Clause

Disclosure Requirement

Tokenomics.com Implementation

Article 6.1 (c)

Whitepaper accuracy and completeness

Multi-layer validation ensuring figures match on-chain data, investor docs, and legal drafts

Article 7 (2)

Updates to material information

Dynamic disclosure files versioned and timestamped for re-submission when supply assumptions change

Article 8 (1)

Public availability

Host continuous-disclosure dashboards for exchanges and investors showing current circulating supply

Annex I
(5–6)

Quantity, creation/destruction, and issuance timeline

Full quantitative model, contract verification, and MiCA-formatted disclosure paragraphs

Integrated Deliverables

  1. Supply Ledger Report (.xlsx) — token counts per category and period.

  2. Emission Model (.py / .csv) — reproducible Python model for regulator or exchange review.

  3. Disclosure Paragraphs (.docx) — ready to paste into the MiCA whitepaper annex.

  4. Graph Pack (.svg / .png) — emission curves, float evolution, inflation trends.

  5. Audit Attestation (.pdf) — signed summary confirming alignment between code and declared supply schedule.

  6. Interactive Tokenomics Audit (Web Dashboard) — A public-facing, read-only interface allowing the community, exchanges, and investors to view real-time supply data, vesting progress, and emission forecasts. This transparency layer strengthens credibility, supports MiCA’s principles of ongoing public availability (Article 8), and positions your project as an industry benchmark for open compliance.


FAQs
FAQs

MiCA Supply Disclosure FAQ

Clear answers to common questions on MiCA Annex I supply disclosures. Covers token quantity and issuance, emission schedules, vesting, mint and burn controls, allocations, circulating supply, and ongoing updates.

Clear answers to common questions on MiCA Annex I supply disclosures. Covers token quantity and issuance, emission schedules, vesting, mint and burn controls, allocations, circulating supply, and ongoing updates.

Clear answers to common questions on MiCA Annex I supply disclosures. Covers token quantity and issuance, emission schedules, vesting, mint and burn controls, allocations, circulating supply, and ongoing updates.

What does MiCA Annex I require for token supply disclosure (quantity, fixed vs elastic, mint and burn mechanisms)

Annex I points 5 and 6 require you to state how many tokens exist, whether the quantity is fixed, capped, or elastic, and to describe the mechanisms for mint and burn. Name who controls these functions, the conditions to use them, and link to the relevant contracts or governance.

What does MiCA Annex I require for token supply disclosure (quantity, fixed vs elastic, mint and burn mechanisms)

Annex I points 5 and 6 require you to state how many tokens exist, whether the quantity is fixed, capped, or elastic, and to describe the mechanisms for mint and burn. Name who controls these functions, the conditions to use them, and link to the relevant contracts or governance.

What does MiCA Annex I require for token supply disclosure (quantity, fixed vs elastic, mint and burn mechanisms)

Annex I points 5 and 6 require you to state how many tokens exist, whether the quantity is fixed, capped, or elastic, and to describe the mechanisms for mint and burn. Name who controls these functions, the conditions to use them, and link to the relevant contracts or governance.

How do I model and publish a MiCA-compliant emission and vesting schedule (dates, amounts, recipients)

Provide a dated table with month, amount released, cumulative circulating, percent of max supply, and recipient category. Include cliffs and linear unlocks. Publish the same data as CSV or XLSX and add a matching chart in SVG or PNG.

How do I model and publish a MiCA-compliant emission and vesting schedule (dates, amounts, recipients)

Provide a dated table with month, amount released, cumulative circulating, percent of max supply, and recipient category. Include cliffs and linear unlocks. Publish the same data as CSV or XLSX and add a matching chart in SVG or PNG.

How do I model and publish a MiCA-compliant emission and vesting schedule (dates, amounts, recipients)

Provide a dated table with month, amount released, cumulative circulating, percent of max supply, and recipient category. Include cliffs and linear unlocks. Publish the same data as CSV or XLSX and add a matching chart in SVG or PNG.

How is circulating supply calculated month by month under MiCA (TGE float, unlocks, burns, cumulative totals)?

Start from circulating supply at TGE, add each period’s unlocks and emissions, and subtract confirmed burns. Show cumulative circulating totals and the percent of maximum supply each month. Reconcile figures with the contract and your allocation ledger.

How is circulating supply calculated month by month under MiCA (TGE float, unlocks, burns, cumulative totals)?

Start from circulating supply at TGE, add each period’s unlocks and emissions, and subtract confirmed burns. Show cumulative circulating totals and the percent of maximum supply each month. Reconcile figures with the contract and your allocation ledger.

How is circulating supply calculated month by month under MiCA (TGE float, unlocks, burns, cumulative totals)?

Start from circulating supply at TGE, add each period’s unlocks and emissions, and subtract confirmed burns. Show cumulative circulating totals and the percent of maximum supply each month. Reconcile figures with the contract and your allocation ledger.

Who controls mint and burn and supply parameters under MiCA governance, and how must this be disclosed?

Identify the controller such as multisig, DAO, or immutable contract and describe proposal, quorum, approvals, and timelocks. If parameters can change, explain the exact process and limits. Link to the governance contract or policy.

Who controls mint and burn and supply parameters under MiCA governance, and how must this be disclosed?

Identify the controller such as multisig, DAO, or immutable contract and describe proposal, quorum, approvals, and timelocks. If parameters can change, explain the exact process and limits. Link to the governance contract or policy.

Who controls mint and burn and supply parameters under MiCA governance, and how must this be disclosed?

Identify the controller such as multisig, DAO, or immutable contract and describe proposal, quorum, approvals, and timelocks. If parameters can change, explain the exact process and limits. Link to the governance contract or policy.

Which files and formats should I provide for MiCA supply disclosure and exchange listings?

Share a CSV or XLSX emission table, an SVG or PNG supply curve, and a DOCX paragraph set for Annex I. Add a PDF attestation that reconciles code, tables, and narrative. Include a public read-only dashboard if you maintain ongoing Article 8 disclosures.

Which files and formats should I provide for MiCA supply disclosure and exchange listings?

Share a CSV or XLSX emission table, an SVG or PNG supply curve, and a DOCX paragraph set for Annex I. Add a PDF attestation that reconciles code, tables, and narrative. Include a public read-only dashboard if you maintain ongoing Article 8 disclosures.

Which files and formats should I provide for MiCA supply disclosure and exchange listings?

Share a CSV or XLSX emission table, an SVG or PNG supply curve, and a DOCX paragraph set for Annex I. Add a PDF attestation that reconciles code, tables, and narrative. Include a public read-only dashboard if you maintain ongoing Article 8 disclosures.

About the Author

Founder of Tokenomics.com

With over 750 tokenomics models audited and a dataset of 2,500+ projects, we’ve developed the most structured and data-backed framework for tokenomics analysis in the industry.

Previously managing partner at a web3 venture fund (exit in 2021).

Since then, Andres has personally advised 80+ projects across DeFi, DePIN, RWA, and infrastructure.

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