The RCA Briefing — Issue 0042

1 Sept 2026

Registers fill, private-market files stay thin

1. 01 · The Policy Shift

   ESMA's Article 109 interface is now a weekly desk source, not a project

   National competent authorities continue to populate white-paper and CASP records into the EU public register. RCA now treats a change in that register as a primary event: it is dated, machine-classifiable, and citable. It is still not a merit review of the issuer.

2. 02 · Why It Matters

   Practical impact

   Venue onboarding, banking KYB and fund-administrator checks can now start from a public EU record rather than a PDF emailed by the token sponsor. They still cannot end there. Holder rights, group structure and extra-EU characterisation remain off-register.

3. 03 · Issuer Watch

   Tokenised private-credit vehicles still fail the eight-question public file

   This week's registry refresh found the same pattern as the July investigation: product pages and partner logos are abundant; legal-issuer extracts, valuation policies and transfer restrictions are not. The gap is widest where origination sits in an offshore SPV and the token is the public interface.

   Open Ondo Finance in the registry

4. 04 · Data Watch

   Median public evidence coverage on private-market names remains 'fragmented'

   Across the gold-standard registry sample, EMT and registered-fund issuers cluster at developing-to-strong. Tokenised private-market issuers remain at limited-to-fragmented. The RCA Transparency Index will not average these into a single market score.

5. 05 · The Source

   MiCA Article 109 and the ESMA public register

   Tier 1In forceEU

   MiCA Article 109 — Register of crypto-asset white papers, issuers of ARTs and EMTs, and CASPs

   EUR-Lex / ESMA/9 Jun 2023/RCA review 28 Aug 2026

   Proves

   ESMA must maintain a public register of white papers, ART/EMT issuers and CASPs, with machine-readable classification by asset type.

   Does not prove

   That appearance on a national or ESMA list is a quality, solvency or investment recommendation.