Paxos
Paxos Europe
MiCA CASP EMT Data Reporting for USDG
Background
The EU Commission has published an Implementing Regulation (IR) under Markets in Crypto-Assets Regulation (MiCA) to ensure uniform reporting requirements for Crypto-Asset Service Providers (CASPs) and issuers of e-money tokens (EMTs). While this Regulation covers only EMTs denominated in a currency that is not an official currency of a Member State, the European Banking Authority (EBA) has adopted additional guidelines that cover all reporting obligations on EMTs, including for those EMTs that reference EU currencies.
Since USDG is a regulated EMT under MiCA, CASPs providing services in relation to USDG must share both quarterly and daily data points with Paxos Issuance Europe Oy’s (PIE) as USDG’s issuer. This page outlines how regulated CASPs under MiCA in the EU should report these quarterly and daily data points to PIE.
Reporting Obligations and Frequency
CASPs are required to report data on both a quarterly and daily basis:
Quarterly Reporting:
Data Points: Information on token holders, transaction volumes, transactions associated to its uses as means of exchanges, amongst others.
Deadlines: Data must be submitted on 21 April, 21 July, 21 October and 21 January for the previous quarter.
Additional information: More can be found in Annex 3 (Reporting for CASPs - templates) and Annex 4 (Reporting for CASPs - instructions) of the EU Commission Implementing Regulation and the EBA Guidelines also linked below.
Daily Reporting:
CASPs must provide end-of-business day (23:59pm UTC timezone) information on token holdings (see S.08.00 in the CASP reporting template and find more information in the instructions).
PIE requires these data points to fulfill its regulatory obligations under MiCA.
How to Report
CASPs must submit reporting data to Paxos Issuance Europe Oy (PIE) using different channels depending on the reporting frequency:
Daily Reporting (Template S 08.00 - Token held by CASP)
Daily reporting is fulfilled through the Paxos platform, which is the mandatory channel for this obligation. CASPs must register the wallet address(es) in which they hold USDG on behalf of their clients on the Paxos platform. PIE will derive end-of-business-day (23.59 UTC timezone) token holdings from the registered addresses.
To get started:
Create or sign in to your account on the Paxos Dashboard. New entities should follow the onboarding guide
Submit the wallet address(es) holding USDG for your CASP
Keep your registered wallet list up to date whenever addresses are added, rotated, or retired
CASPs that have not yet registered their wallets may temporarily submit daily S 08.00 reports by email to usdg-mica-reporting@paxos.com. Please complete wallet registration as soon as possible.
Quarterly Reporting (S 06.xx - S 07.xx Templates)
Quarterly reports must be submitted by email to: usdg-mica-reporting@paxos.com
Templates: Use the templates at Annex III of the EU Commission Implementing Regulation, completed per the Annex IV instructions and the EBA Guidelines.
Reporting currency: All monetary values must be reported in EUR only, converted at the ECB spot exchange rate on the reporting reference date. If that date falls on a weekend or other non-publication day, use the most recent available ECB rate.
Deadlines: By close of business, Finnish time (EET/EEST), on 21 April, 21 July, 21 October and 21 January for the previous quarter.
Platform submission is not yet available for quarterly reporting.
For questions, contact usdg-mica-reporting@paxos.com.
FAQ
What format should CASPs use for their periodic MICA EMT reports?
Use the templates at Annex III of the EU Commission Implementing Regulation. Excel or .csv formats are accepted.
Which conversion rate should be used?
See general remarks on the template at Sec. VII(14), which PIE will follow.
Items that are not denominated in the reporting currency must be converted into the reporting currency by using the ECB spot exchange rate applicable on the reporting reference date.
What is the cut off time & timezone for quarterly reporting?
By close of business (23:59pm UTC) on the 21st of April, July, October, and January for the previous quarter. If the remittance day is a public holiday in the Member State of the competent authority to which the report is to be provided, or a Saturday or Sunday, data shall be submitted on the following working day.
Are CASPs required to report in token units or EUR?
All monetary values must be reported in EUR only, at the ECB spot rate on the reporting reference date. Token units alone do not satisfy the requirement.
What if a CASP has no reportable data for a given period?
Submit a "Nothing to Report" confirmation to usdg-mica-reporting@paxos.com by the deadline.
