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File S7-2026-27/Issue 0042/38 days left

The RCA Briefing — Issue 0038

4 Aug 2026

White papers are now liable documents. They are still not the whole file.

  1. 01 · The Policy Shift

    RTS 2025/421 classification is live in the register pipeline

    Machine-readable white-paper classification is not a curiosity. It is how Article 109 becomes queryable. RCA's source library now stores classification as a field alongside the PDF.

  2. 02 · Why It Matters

    Practical impact

    Compliance systems can ingest a classified white paper as a structured object. They still need a human (or a desk) to record what the form does not contain: group map, extra-EU characterisation, key control.

  3. 03 · Issuer Watch

    Notification is not authorisation — and the marketing still blurs them

    This week's source review again found issuer and intermediary pages describing a notified crypto-asset white paper as if it were an approved prospectus. Under MiCA those are different legal events.

  4. 04 · Data Watch

    Desk rule: every profile shows what the source proves and what it does not

    The two-line evidence block is now mandatory on articles, issuer files and asset files. It is the cheapest way to stop a register extract being over-read as comfort.

  5. 05 · The Source

    Commission Delegated Regulation (EU) 2025/421

RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.