MiCA (Markets in Crypto-Assets Regulation) is often perceived as a purely European framework, but the latest white paper registry data reveals a strikingly different reality: the majority of entities filing white papers for token admission to trading in the EU are headquartered outside the bloc.
According to a study conducted by LegalBison at the end of February 2026, with data updated as of March 12, 2026, out of 441 independent token project filings in the MiCA registers, only 73 (17%) come from entities headquartered inside the EU or EEA. The other 275 with known head offices (62%) are based outside the EU, primarily in the British Virgin Islands (92 entities), Switzerland (61), and the Cayman Islands (44). For the remaining 93 entities, either the European Securities and Markets Authority (ESMA) did not include them, or there is no identifiable centralized entity (think of Bitcoin as an example).
MiCA's Design for Offshore Entities
MiCA governs where tokens are admitted for trading and by whom they are offered, not where the companies behind them are incorporated. This design choice produces the above data and has significant practical consequences for any offshore project evaluating its EU market access strategy. In simple terms: if you have a utility token or 'other token' as per the narrow MiCA definition launched from a non-EU country like the BVI, Panama, or Cayman Islands, you can still have your token admitted for trading in the EU.
MiCA allows a trading platform to take on the responsibility of filing a white paper, either on its own initiative or by written agreement with the project team. This second path is what most early analyses of MiCA missed. Large exchanges, such as Kraken's EU entity authorized in Ireland, filed 133 such records by itself. LCX, operating from Liechtenstein, filed 63. A German compliance provider filed 88 records on behalf of token projects. After stripping out these 284 proxy and compliance-provider filings, 477 records remain: token projects that engaged directly with a national regulator to satisfy the white paper requirement for EU access. Of those, only 73 confirm an EU or EEA head office. The rest are offshore entities reaching into the European market through a targeted regulatory filing, not through a corporate relocation.
Ireland and Malta as White Paper Go-To Jurisdictions
The 477 independent filings concentrate in two jurisdictions. Ireland lists 151 white papers from 147 distinct entities. Malta holds 145 white papers from 95 entities. Together, they account for two-thirds of all independent token project registrations. For any offshore project pursuing a crypto license in Europe, these are the two starting points the data supports.
Ireland's filer list includes Layer-1 blockchain networks (VeChain), DePIN protocols (DIMO Network), AI data projects (Giza, Venice.ai), DeFi infrastructure (Init Capital), and developer tooling (Subsquid). Malta's list includes fan token platforms (Socios, covering 50 sports clubs including FC Barcelona and AC Milan), DeFi protocols (WalletConnect), AI tokens (Ondo AI), and identity tooling (QuantiID Systems). Neither jurisdiction shows a category preference.
For offshore entities choosing between the two, the practical difference comes down to what each regulatory environment actually looks like. Ireland offers an English-language process inside a jurisdiction with a deep technology sector track record. Notably, only one out of 147 Irish filers has an Irish head office, confirming the pattern that Ireland is not a corporate home for these projects, only a point of regulatory access. The British Virgin Islands alone accounts for 47 of the 116 Irish filers with known head offices (41%). Malta, on the other hand, has 20 out of 95 entities with a Maltese head office, reflecting a decade of crypto-specific regulation that produced a local ecosystem of compliance professionals and legal advisors. For projects that want proximity to that ecosystem, Malta tends to produce a different kind of regulatory engagement.
Stablecoins and ARTs: Stark Contrast
MiCA classifies crypto-assets into three categories: Electronic Money Tokens (EMT), Asset-Referenced Tokens (ART), and other crypto-assets. The EMT register contains 36 records as of March 12, 2026. Issuing an EMT under MiCA requires prior authorization as an Electronic Money Institution (EMI) or a credit institution. A local entity is mandatory, and high capital and solvency requirements filter out startups at the entry point. France leads with 7 registrations (including Circle, the issuer of USDC and EURC, and Societe Generale), followed by the Netherlands with 6. The entities in the register are banks and licensed payment institutions, not token-native projects. The EMT market is an institutional product category defined by Circle, Societe Generale, and Paxos.
The ART register reads zero. This category was created for digital assets such as DAI, a stablecoin mimicking the value of the US dollar while being backed by a basket of assets including wrapped Bitcoin and Ether. The market clearly gravitated towards single-asset backed stablecoins. The authorization path for ART is structurally more demanding: capital requirements can reach 2% of average outstanding reserve asset value, and the authorization process is far more rigorous than for standard token issuance. No entity has completed that process anywhere in the EU.
Takeaways for Token Projects
- MiCA compliance for token issuance is operationally accessible to offshore entities. A BVI or Cayman company can satisfy the EU white paper requirement without moving its legal seat to Europe.
- Jurisdiction choice under MiCA still matters, as the approval process is heavily influenced by the regulator's expertise and the underlying legal assumptions.
- Ireland has processed the widest variety of token categories. Malta has the deepest local crypto compliance infrastructure.
- While the proxy model facilitates market access for assets with no centralized issuer, it remains an impractical route for early-stage projects.
- A token issuer seeking EU market access needs to engage the white paper process directly. For most projects, that means Ireland or Malta as the first practical option, regardless of where the legal entity is located.
- The July 1, 2026, deadline for crypto-asset service providers (CASPs) is approaching. Exchanges listing tokens for EU customers require a compliant white paper for each one. The closer that deadline gets, the less runway exists for token projects that have not yet filed. The register data shows that the projects moving now are predominantly offshore.