yields.digital · Regulatory Coverage Reference · v1.0 · March 2026

Full MiCA Article Coverage: What yields.digital Delivers

Maps yields.digital's delivery mechanisms across two regulatory scopes: (1) CASP obligations under MiCA Title V (Arts. 66, 75, 81; DORA; TFR; ESMA reporting); and (2) ART/EMT issuer obligations under MiCA Title III (Arts. 16-47). Articles where yields.digital has no material contribution are excluded. Regulatory framework and article number are shown on the left; the specific delivery mechanism is on the right.

Article	Coverage	How yields.digital delivers
MiCA Title V - CASP Obligations · Arts. 66, 75, 81
Art. 66 / 66(2) CASP conduct: fair, clear & not misleading communications Deck	Direct	MiCA Classification Engine automatically classifies stablecoins as ART, EMT, or other - preventing the CASP from inadvertently offering exposure to non-compliant or misclassified assets, which is the primary Art. 66(2) conduct risk. The NCA enforcement feed monitors BaFin, ESMA, and other NCAs in real time, triggering alerts before enforcement action materializes (as demonstrated by the BaFin/Ethena €600K coercive penalty for non-compliance with supervisory measures). Every client-facing data point - APY, TVL, risk tier - is timestamped and verified, ensuring communications are factually defensible. Deployed in Q2 roadmap (classification engine + NCA feed). Early warning system (Phase 1) live within weeks.
Art. 75(8) CASP custody liability for loss of client crypto-assets Deck	Direct	LYRA risk scores - live today for 6 protocols - provide the independent, quantitative, timestamped evidence trail that constitutes an NCA-defensible record. Art. 75(8) holds the CASP liable for losses attributable to it; without documented, auditable risk assessment at the point of deployment, there is no evidential defense in an NCA investigation. LYRA covers market risk, fundamental risk, liquidity risk, and concentration risk per protocol. Every score is timestamped and immutable. This is the single most important regulatory defense yields.digital provides to a CASP and can be live in 2-3 days.
Art. 75 Internal custody policy and safekeeping arrangements Deck	Partial	Protocol-level risk metadata (contract addresses, chain, version, LYRA risk tier) exports directly into a structured custody policy framework. For complex instruments like Curve liquidity pools - where the asset custody model is non-trivial - LYRA risk data provides the quantitative underpinning for the internal policy required under Art. 75. The Art. 75 policy document itself remains the CASP's responsibility.
Art. 81 Suitability assessment for portfolio management and investment advice Deck	Direct	Art. 81 requires that every allocation decision for a managed portfolio be backed by a documented suitability assessment. yields.digital creates an auditable Art. 81 evidence trail from day one: every pool selection is backed by timestamped APY data, LYRA risk scores, and documented risk-adjusted yield rationale. The single API delivering 159 pools across 6 protocols with risk-filtering means the Investment Manager's decisions are automatically documented against quantitative criteria - replacing the current state of spreadsheet reconciliation with no audit trail.
DORA (Digital Operational Resilience Act)
DORA Art. 28(3) ICT third-party service provider register Deck	Direct	yields.digital exports protocol metadata - name, contract addresses, chain, version, LYRA risk tier - as a structured DORA ICT register in JSON/CSV format, covering all 6 live protocols today and extending to 15 protocols through Q2. The register is auto-generated and version-tracked, eliminating the current spreadsheet. Deployable in 1-2 weeks (Phase 1). Full JSON/CSV register with version tracking ships in Q3.
ESMA Machine-Readable Reporting
ESMA JSON & iXBRL Machine-readable reporting: iXBRL white papers (mandatory since Dec 2025) and JSON order book (NCAs requesting by mid-2026) Deck	Direct	yields.digital's Q3 module delivers full ESMA JSON reporting and iXBRL white paper disclosure templates, auto-generated from live platform data. The iXBRL white paper format became mandatory 23 December 2025 (Implementing Regulation 2024/2984). NCAs are expected to begin requesting JSON order book data by mid-2026 (6 months after ESMA's November 2025 publication). Critical path dependency: the Q3 ESMA reporting module depends on the Q2 classification engine (MiCA asset classification) and reporting modules being stable - meaning Q2 must begin immediately. iXBRL white paper disclosure templates are scoped for Q2. Q2 classification engine is the critical path prerequisite. iXBRL compliance already required; JSON order book reporting expected mid-2026.
Transfer of Funds Regulation (TFR) / Travel Rule
TFR - Travel Rule Originator/beneficiary data for crypto-asset transfers Deck	Direct	Travel Rule address registry (Q2 roadmap) automates TFR compliance verification, integrated into async ERC-7540 vault flows. Currently manual tagging of DeFi interactions is the Compliance Manager's workload - this eliminates it entirely. The registry maps on-chain addresses to compliance records, ensuring every vault interaction meets the Travel Rule data requirement without manual intervention.
MiCA Title III - Asset-Referenced Token Issuer Obligations · Arts. 16-47
Art. 17 Requirements for credit institutions issuing ARTs Audit	Partial	Credit institutions issuing ARTs must attach an approved white paper including risk and reserve disclosures. yields.digital provides the risk model outputs and reserve composition data that populate the mandatory Annex II risk and reserve sections of the white paper - the quantitative evidence behind the notification.
Art. 20 Assessment of the application for authorisation Audit	Partial	The authorization application requires documented, operationalized risk management policies. yields.digital provides the live infrastructure that gives those policies operational substance - risk dashboards, limit monitoring, automated alerts - demonstrating to the competent authority that risk management is not merely stated policy but active and running.
Art. 19 Content and form of the ART white paper Audit	Partial	Annex II mandates detailed disclosure of reserve composition, risk factors, and investment policy in the white paper. yields.digital provides the live reserve composition data, risk factor quantification (market, credit, liquidity), and investment policy parameters that feed directly into the required Annex II sections.
Art. 22 Quarterly reporting on ARTs to competent authority Audit	Partial	Quarterly reports to the competent authority must cover: token holders, reserve value and composition, transaction volumes, and issuer exposure. yields.digital aggregates all underlying data fields required for Art. 22 reporting. Full "Direct" coverage is conditional on confirmed implementation of the EBA-prescribed supervisory reporting template taxonomy. Auditor note: The claim becomes Direct only when yields.digital outputs are confirmed to conform to EBA supervisory reporting template formats.
Art. 23 Restrictions on widely-used ARTs (transaction thresholds) Audit	Partial	When estimated quarterly averages exceed 1 million daily transactions and €200M daily transaction value within a single currency area, the issuer must cease issuance and submit a plan to the competent authority to reduce usage below the thresholds. yields.digital's transaction volume monitoring tracks rolling thresholds and provides automated alerts approaching the cap - enabling proactive regulatory notification before EBA intervention. Conditional on confirmed on-chain transaction monitoring capability across all supported chains.
Art. 25 Notification of material white paper changes Audit	Partial	Issuers must submit a draft modified white paper to the competent authority for approval; the CA has 30 working days to approve or refuse. yields.digital's reserve composition and risk monitoring detects material deviations in reserve profile or risk posture that would trigger the modification obligation - providing advance warning well before the approval process begins.
Art. 26 Issuer liability for white paper information Audit	Supporting	Civil liability under Art. 26 arises if reserve or risk disclosures are materially misleading. yields.digital's timestamped, auditable data lineage provides evidentiary defense - every reserve value and risk metric in the white paper is backed by a verified, reproducible data trail.
Art. 27 Act honestly, fairly, in holders' best interest Audit	Partial	A conduct obligation the issuer owns. yields.digital ensures that all holder-facing data - reserve values, risk metrics, performance - is current, verified, and not misleading at the point of disclosure, reducing the risk of inadvertent conduct breaches from stale or inaccurate data.
Art. 30 Ongoing information disclosure (monthly updates + immediate material events) Audit	Partial	Issuers must publish monthly: tokens in circulation, total reserve value, and reserve composition by asset class. yields.digital aggregates and structures all three data points into disclosure-ready outputs. Full automation to "Direct" is conditional on API-level custodian integration being confirmed. Conditional on confirmed real-time custodian data integration. Without this, yields.digital processes data but does not fully automate the obligation.
Art. 32 Identification, prevention, management and disclosure of conflicts of interest Audit	Supporting	A governance and policy obligation. yields.digital's audit trail and data lineage infrastructure supports the evidentiary record of reserve management decisions, investment transactions, and pricing sources - providing documentation that conflicts were identified and managed.
Art. 34 Governance arrangements, internal controls, and risk management Audit	Partial	Governance requires documented internal controls over risk management. yields.digital provides the real-time risk dashboards, threshold alerts, and limit breach monitoring that governance bodies consume - giving boards and senior management live visibility into risk positions rather than periodic manual reports. Direct for quantitative risk dimensions: LYRA provides continuous market risk, fundamental risk, liquidity risk, and concentration risk monitoring with stress testing and scenario analysis (mapping to MiCA's market risk, credit risk, and concentration risk categories). Partial overall because Art. 34 also mandates operational risk including ICT, cybersecurity, and business continuity - non-quantitative obligations that remain the issuer's internal responsibility and cannot be delegated to a risk modeling platform.
Art. 35 Own funds requirements Audit	Direct	Own funds must equal the greater of €350k, 2% of average reserve assets, or 25% of prior year fixed overheads. The 2% calculation is a quantitative function that flows directly from reserve asset valuation - a core yields.digital output. The platform monitors own funds adequacy against the regulatory floor continuously and flags any approach to breach ahead of time.
Art. 36 Reserve of assets - composition, management, and parity Audit	Partial	yields.digital monitors reserve composition in real time against issued token value, alerts when the reserve approaches a shortfall, and models forward-looking shortfall risk under stress. Full "Direct" is conditional on real-time custodian data integration. Note: legal segregation of reserve assets is a structural legal obligation the issuer must fulfill independently of technology. Also: EBA/Commission RTS defining "highly liquid financial instruments" for reserve purposes was still contested as of March 2026 - the compliance target is evolving.
Art. 37 Custody of reserve assets (independent custodian) Audit	Supporting	Art. 37 requires a legally independent, regulated custodian - a different legal entity from the issuer. yields.digital provides the reconciliation and audit trail layer that supports the independent custodian's audit process: continuous position reconciliation across custodians, timestamped records, and discrepancy flagging. yields.digital does not fulfill, and does not claim to fulfill, the custody obligation itself.
Art. 38 Investment of reserve assets (low-risk, highly liquid) Audit	Direct	Reserve funds must be invested in highly liquid, low-risk assets liquidatable with minimal market impact. yields.digital's portfolio compliance monitoring continuously checks reserve investments against these constraints - providing real-time alerts when investments approach policy limits and documenting enforcement of the investment policy. Conditional on EBA's definition of "highly liquid financial instruments" being finalized (RTS still in dispute as of March 2026).
Art. 40 Prohibition of granting interest in relation to ARTs Audit	Partial	Issuers are prohibited from granting any interest-like benefit to ART holders based on holding duration. yields.digital's yield and transaction monitoring layer flags payments or distributions that structurally resemble prohibited interest - an automated compliance check. Legal determination of what constitutes "interest" under MiCA remains the issuer's legal/compliance function.
Art. 43 Classification as significant ART Audit	Partial	EBA classifies ARTs as significant based on customer base (>10 million holders), market capitalisation (>€5bn), and transaction volumes (>2.5 million daily transactions and >€500M daily value). yields.digital monitors all three threshold metrics continuously, providing advance warning that a token is approaching significance criteria - enabling proactive regulatory engagement before formal classification.
Art. 45 Specific additional obligations for issuers of significant ARTs Audit	Partial	Significant issuers face enhanced liquidity management, higher-frequency stress testing, interoperability requirements, and direct EBA supervisory data submissions. yields.digital's infrastructure provides the underlying data foundation - enhanced liquidity monitoring, daily stress testing cycles, and structured supervisory data outputs - supporting significant-issuer compliance. Full "Direct" requires confirmed implementation of EBA ITS supervisory reporting formats.
Art. 46 Recovery plan Audit	Partial	EBA Recovery Plan Guidelines require a multi-section document covering governance escalation triggers, communication plans, legal/contractual arrangements, and quantitative financial resilience scenarios. yields.digital provides the stress scenario modeling and reserve drawdown analysis that constitutes the financial resilience section of the recovery plan - the quantitative inputs - but not the full plan document, which also requires governance, legal, and communications components.

Article

Coverage

How yields.digital delivers

MiCA Title V - CASP Obligations · Arts. 66, 75, 81

Art. 66 / 66(2)

CASP conduct: fair, clear & not misleading communications

Deck

Direct

MiCA Classification Engine automatically classifies stablecoins as ART, EMT, or other - preventing the CASP from inadvertently offering exposure to non-compliant or misclassified assets, which is the primary Art. 66(2) conduct risk. The NCA enforcement feed monitors BaFin, ESMA, and other NCAs in real time, triggering alerts before enforcement action materializes (as demonstrated by the BaFin/Ethena €600K coercive penalty for non-compliance with supervisory measures). Every client-facing data point - APY, TVL, risk tier - is timestamped and verified, ensuring communications are factually defensible. Deployed in Q2 roadmap (classification engine + NCA feed). Early warning system (Phase 1) live within weeks.

Art. 75(8)

CASP custody liability for loss of client crypto-assets

Deck

Direct

LYRA risk scores - live today for 6 protocols - provide the independent, quantitative, timestamped evidence trail that constitutes an NCA-defensible record. Art. 75(8) holds the CASP liable for losses attributable to it; without documented, auditable risk assessment at the point of deployment, there is no evidential defense in an NCA investigation. LYRA covers market risk, fundamental risk, liquidity risk, and concentration risk per protocol. Every score is timestamped and immutable. This is the single most important regulatory defense yields.digital provides to a CASP and can be live in 2-3 days.

Art. 75

Internal custody policy and safekeeping arrangements

Deck

Partial

Protocol-level risk metadata (contract addresses, chain, version, LYRA risk tier) exports directly into a structured custody policy framework. For complex instruments like Curve liquidity pools - where the asset custody model is non-trivial - LYRA risk data provides the quantitative underpinning for the internal policy required under Art. 75. The Art. 75 policy document itself remains the CASP's responsibility.

Art. 81

Suitability assessment for portfolio management and investment advice

Deck

Direct

Art. 81 requires that every allocation decision for a managed portfolio be backed by a documented suitability assessment. yields.digital creates an auditable Art. 81 evidence trail from day one: every pool selection is backed by timestamped APY data, LYRA risk scores, and documented risk-adjusted yield rationale. The single API delivering 159 pools across 6 protocols with risk-filtering means the Investment Manager's decisions are automatically documented against quantitative criteria - replacing the current state of spreadsheet reconciliation with no audit trail.

DORA (Digital Operational Resilience Act)

DORA Art. 28(3)

ICT third-party service provider register

Deck

Direct

yields.digital exports protocol metadata - name, contract addresses, chain, version, LYRA risk tier - as a structured DORA ICT register in JSON/CSV format, covering all 6 live protocols today and extending to 15 protocols through Q2. The register is auto-generated and version-tracked, eliminating the current spreadsheet. Deployable in 1-2 weeks (Phase 1). Full JSON/CSV register with version tracking ships in Q3.

ESMA Machine-Readable Reporting

ESMA JSON & iXBRL

Machine-readable reporting: iXBRL white papers (mandatory since Dec 2025) and JSON order book (NCAs requesting by mid-2026)

Deck

Direct

yields.digital's Q3 module delivers full ESMA JSON reporting and iXBRL white paper disclosure templates, auto-generated from live platform data. The iXBRL white paper format became mandatory 23 December 2025 (Implementing Regulation 2024/2984). NCAs are expected to begin requesting JSON order book data by mid-2026 (6 months after ESMA's November 2025 publication). Critical path dependency: the Q3 ESMA reporting module depends on the Q2 classification engine (MiCA asset classification) and reporting modules being stable - meaning Q2 must begin immediately. iXBRL white paper disclosure templates are scoped for Q2. Q2 classification engine is the critical path prerequisite. iXBRL compliance already required; JSON order book reporting expected mid-2026.

Transfer of Funds Regulation (TFR) / Travel Rule

TFR - Travel Rule

Originator/beneficiary data for crypto-asset transfers

Deck

Direct

Travel Rule address registry (Q2 roadmap) automates TFR compliance verification, integrated into async ERC-7540 vault flows. Currently manual tagging of DeFi interactions is the Compliance Manager's workload - this eliminates it entirely. The registry maps on-chain addresses to compliance records, ensuring every vault interaction meets the Travel Rule data requirement without manual intervention.

MiCA Title III - Asset-Referenced Token Issuer Obligations · Arts. 16-47

Art. 17

Requirements for credit institutions issuing ARTs

Audit

Partial

Credit institutions issuing ARTs must attach an approved white paper including risk and reserve disclosures. yields.digital provides the risk model outputs and reserve composition data that populate the mandatory Annex II risk and reserve sections of the white paper - the quantitative evidence behind the notification.

Art. 20

Assessment of the application for authorisation

Audit

Partial

The authorization application requires documented, operationalized risk management policies. yields.digital provides the live infrastructure that gives those policies operational substance - risk dashboards, limit monitoring, automated alerts - demonstrating to the competent authority that risk management is not merely stated policy but active and running.

Art. 19

Content and form of the ART white paper

Audit

Partial

Annex II mandates detailed disclosure of reserve composition, risk factors, and investment policy in the white paper. yields.digital provides the live reserve composition data, risk factor quantification (market, credit, liquidity), and investment policy parameters that feed directly into the required Annex II sections.

Art. 22

Quarterly reporting on ARTs to competent authority

Audit

Partial

Quarterly reports to the competent authority must cover: token holders, reserve value and composition, transaction volumes, and issuer exposure. yields.digital aggregates all underlying data fields required for Art. 22 reporting. Full "Direct" coverage is conditional on confirmed implementation of the EBA-prescribed supervisory reporting template taxonomy. Auditor note: The claim becomes Direct only when yields.digital outputs are confirmed to conform to EBA supervisory reporting template formats.

Art. 23

Restrictions on widely-used ARTs (transaction thresholds)

Audit

Partial

When estimated quarterly averages exceed 1 million daily transactions and €200M daily transaction value within a single currency area, the issuer must cease issuance and submit a plan to the competent authority to reduce usage below the thresholds. yields.digital's transaction volume monitoring tracks rolling thresholds and provides automated alerts approaching the cap - enabling proactive regulatory notification before EBA intervention. Conditional on confirmed on-chain transaction monitoring capability across all supported chains.

Art. 25

Notification of material white paper changes

Audit

Partial

Issuers must submit a draft modified white paper to the competent authority for approval; the CA has 30 working days to approve or refuse. yields.digital's reserve composition and risk monitoring detects material deviations in reserve profile or risk posture that would trigger the modification obligation - providing advance warning well before the approval process begins.

Art. 26

Issuer liability for white paper information

Audit

Supporting

Civil liability under Art. 26 arises if reserve or risk disclosures are materially misleading. yields.digital's timestamped, auditable data lineage provides evidentiary defense - every reserve value and risk metric in the white paper is backed by a verified, reproducible data trail.

Art. 27

Act honestly, fairly, in holders' best interest

Audit

Partial

A conduct obligation the issuer owns. yields.digital ensures that all holder-facing data - reserve values, risk metrics, performance - is current, verified, and not misleading at the point of disclosure, reducing the risk of inadvertent conduct breaches from stale or inaccurate data.

Art. 30

Ongoing information disclosure (monthly updates + immediate material events)

Audit

Partial

Issuers must publish monthly: tokens in circulation, total reserve value, and reserve composition by asset class. yields.digital aggregates and structures all three data points into disclosure-ready outputs. Full automation to "Direct" is conditional on API-level custodian integration being confirmed. Conditional on confirmed real-time custodian data integration. Without this, yields.digital processes data but does not fully automate the obligation.

Art. 32

Identification, prevention, management and disclosure of conflicts of interest

Audit

Supporting

A governance and policy obligation. yields.digital's audit trail and data lineage infrastructure supports the evidentiary record of reserve management decisions, investment transactions, and pricing sources - providing documentation that conflicts were identified and managed.

Art. 34

Governance arrangements, internal controls, and risk management

Audit

Partial

Governance requires documented internal controls over risk management. yields.digital provides the real-time risk dashboards, threshold alerts, and limit breach monitoring that governance bodies consume - giving boards and senior management live visibility into risk positions rather than periodic manual reports. Direct for quantitative risk dimensions: LYRA provides continuous market risk, fundamental risk, liquidity risk, and concentration risk monitoring with stress testing and scenario analysis (mapping to MiCA's market risk, credit risk, and concentration risk categories). Partial overall because Art. 34 also mandates operational risk including ICT, cybersecurity, and business continuity - non-quantitative obligations that remain the issuer's internal responsibility and cannot be delegated to a risk modeling platform.

Art. 35

Own funds requirements

Audit

Direct

Own funds must equal the greater of €350k, 2% of average reserve assets, or 25% of prior year fixed overheads. The 2% calculation is a quantitative function that flows directly from reserve asset valuation - a core yields.digital output. The platform monitors own funds adequacy against the regulatory floor continuously and flags any approach to breach ahead of time.

Art. 36

Reserve of assets - composition, management, and parity

Audit

Partial

yields.digital monitors reserve composition in real time against issued token value, alerts when the reserve approaches a shortfall, and models forward-looking shortfall risk under stress. Full "Direct" is conditional on real-time custodian data integration. Note: legal segregation of reserve assets is a structural legal obligation the issuer must fulfill independently of technology. Also: EBA/Commission RTS defining "highly liquid financial instruments" for reserve purposes was still contested as of March 2026 - the compliance target is evolving.

Art. 37

Custody of reserve assets (independent custodian)

Audit

Supporting

Art. 37 requires a legally independent, regulated custodian - a different legal entity from the issuer. yields.digital provides the reconciliation and audit trail layer that supports the independent custodian's audit process: continuous position reconciliation across custodians, timestamped records, and discrepancy flagging. yields.digital does not fulfill, and does not claim to fulfill, the custody obligation itself.

Art. 38

Investment of reserve assets (low-risk, highly liquid)

Audit

Direct

Reserve funds must be invested in highly liquid, low-risk assets liquidatable with minimal market impact. yields.digital's portfolio compliance monitoring continuously checks reserve investments against these constraints - providing real-time alerts when investments approach policy limits and documenting enforcement of the investment policy. Conditional on EBA's definition of "highly liquid financial instruments" being finalized (RTS still in dispute as of March 2026).

Art. 40

Prohibition of granting interest in relation to ARTs

Audit

Partial

Issuers are prohibited from granting any interest-like benefit to ART holders based on holding duration. yields.digital's yield and transaction monitoring layer flags payments or distributions that structurally resemble prohibited interest - an automated compliance check. Legal determination of what constitutes "interest" under MiCA remains the issuer's legal/compliance function.

Art. 43

Classification as significant ART

Audit

Partial

EBA classifies ARTs as significant based on customer base (>10 million holders), market capitalisation (>€5bn), and transaction volumes (>2.5 million daily transactions and >€500M daily value). yields.digital monitors all three threshold metrics continuously, providing advance warning that a token is approaching significance criteria - enabling proactive regulatory engagement before formal classification.

Art. 45

Specific additional obligations for issuers of significant ARTs

Audit

Partial

Significant issuers face enhanced liquidity management, higher-frequency stress testing, interoperability requirements, and direct EBA supervisory data submissions. yields.digital's infrastructure provides the underlying data foundation - enhanced liquidity monitoring, daily stress testing cycles, and structured supervisory data outputs - supporting significant-issuer compliance. Full "Direct" requires confirmed implementation of EBA ITS supervisory reporting formats.

Art. 46

Recovery plan

Audit

Partial

EBA Recovery Plan Guidelines require a multi-section document covering governance escalation triggers, communication plans, legal/contractual arrangements, and quantitative financial resilience scenarios. yields.digital provides the stress scenario modeling and reserve drawdown analysis that constitutes the financial resilience section of the recovery plan - the quantitative inputs - but not the full plan document, which also requires governance, legal, and communications components.