yields.digital · Regulatory Coverage Reference · v1.1 · October 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	Partial	MiCA classification marks each asset as ART, EMT, or other in reports today (provisional, pending legal review) - helping the CASP avoid inadvertently offering exposure to misclassified assets, which is the primary Art. 66(2) conduct risk. A planned NCA enforcement feed would monitor BaFin, ESMA, and other NCAs, raising 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. Asset classification: in reports today, provisional. NCA enforcement feed and early warning: planned.
Art. 75(8) CASP custody liability for loss of client crypto-assets Deck	Direct	LYRA risk scores - live today for every protocol we cover - 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 stored, and reports keep the source data that produced them. This is the single most important regulatory defense yields.digital provides to a CASP.
Art. 75 Internal custody policy and safekeeping arrangements Deck	Supporting	Protocol-level risk metadata (contract addresses, chain, version, LYRA risk tier) gives a structured input to the 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 risk-filtered yield rationale. A single API delivering risk-filtered pools across every protocol we cover 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	Planned	yields.digital holds protocol metadata - name, contract addresses, chain, LYRA risk scores - for every protocol it covers. A planned structured DORA ICT register export in JSON/CSV format would generate and version-track the register from that data, replacing a manually kept spreadsheet.
ESMA Machine-Readable Reporting
ESMA JSON & iXBRL Machine-readable reporting: iXBRL white papers (mandatory since Dec 2025) and JSON order book records (trading platforms) Deck	Planned	yields.digital plans ESMA JSON reporting and iXBRL white paper disclosure templates, generated from platform data. The iXBRL white paper format became mandatory 23 December 2025 (Implementing Regulation 2024/2984). JSON order book records (Delegated Regulation 2025/416) apply to CASPs operating a trading platform. The planned reporting module builds on the MiCA asset classification already carried in reports. Planned. iXBRL is already required for white papers; JSON order book records apply to trading-platform operators.
Transfer of Funds Regulation (TFR) / Travel Rule
TFR - Travel Rule Originator/beneficiary data for crypto-asset transfers Deck	Planned	A planned Travel Rule address registry would automate TFR compliance verification, integrated into async ERC-7540 vault flows. Today manual tagging of DeFi interactions is the Compliance Manager's workload; the registry would remove it. 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	Planned	Credit institutions issuing ARTs must attach an approved white paper including risk and reserve disclosures. Planned: risk model outputs and reserve composition data to 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	Supporting	The authorization application requires documented, operationalized risk management policies. yields.digital risk dashboards and reports give those policies operational substance (limit monitoring and automated alerts are planned) - 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	Planned	Annex II mandates detailed disclosure of reserve composition, risk factors, and investment policy in the white paper. Planned: reserve composition data, risk factor quantification (market, credit, liquidity), and investment policy parameters to feed the required Annex II sections.
Art. 22 Quarterly reporting on ARTs to competent authority Audit	Planned	Quarterly reports to the competent authority must cover: token holders, reserve value and composition, transaction volumes, and issuer exposure. Planned: aggregation of the data fields required for Art. 22 reporting, in the EBA-prescribed supervisory reporting template taxonomy. Planned; depends on conformance to EBA supervisory reporting template formats.
Art. 23 Restrictions on widely-used ARTs (transaction thresholds) Audit	Planned	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. Planned: transaction volume monitoring that tracks rolling thresholds and alerts as volumes approach 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	Planned	Issuers must submit a draft modified white paper to the competent authority for approval; the CA has 30 working days to approve or refuse. Planned: reserve composition and risk monitoring to detect 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 yields.digital risk metric cited is backed by a timestamped, reproducible data trail.
Art. 27 Act honestly, fairly, in holders' best interest Audit	Supporting	A conduct obligation the issuer owns. yields.digital risk metrics are timestamped and regularly refreshed, helping keep holder-facing risk data current 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	Planned	Issuers must publish monthly: tokens in circulation, total reserve value, and reserve composition by asset class. Planned: aggregating all three data points into disclosure-ready outputs, which depends on custodian data integration. Planned; depends on custodian data integration.
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 for the risk data and reports used in reserve management decisions - 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 risk dashboards and exportable risk reports that governance bodies consume - giving boards and senior management current visibility into risk positions rather than periodic manual reports; threshold alerts and limit-breach monitoring are planned. Direct for quantitative risk dimensions: LYRA scores market risk, fundamental risk, liquidity risk, and concentration risk (mapping to MiCA's market risk, credit risk, and concentration risk categories); stress testing and scenario analysis are planned. 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	Planned	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 of reserve asset valuation. Planned: monitoring of own funds adequacy against the regulatory floor, flagging any approach to breach ahead of time.
Art. 36 Reserve of assets - composition, management, and parity Audit	Planned	yields.digital plans reserve-composition monitoring against issued token value, with alerts when the reserve approaches a shortfall and forward-looking shortfall modelling under stress. This depends on 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: point-in-time snapshots of on-chain wallet positions, reconciled across two independent data sources, with timestamped records. 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	Planned	Reserve funds must be invested in highly liquid, low-risk assets liquidatable with minimal market impact. Planned: checking reserve investments against these constraints, with alerts when investments approach policy limits and documentation of how the investment policy is enforced. 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	Planned	Issuers are prohibited from granting any interest-like benefit to ART holders based on holding duration. Planned: yield and transaction monitoring that flags payments or distributions structurally resembling prohibited interest. Legal determination of what constitutes "interest" under MiCA remains the issuer's legal/compliance function.
Art. 43 Classification as significant ART Audit	Planned	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). Planned: monitoring of all three threshold metrics, 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	Supporting	Significant issuers face enhanced liquidity management, higher-frequency stress testing, interoperability requirements, and direct EBA supervisory data submissions. yields.digital's liquidity risk metrics are part of the underlying data foundation; stress testing and structured supervisory data outputs are planned. Full "Direct" requires confirmed implementation of EBA ITS supervisory reporting formats.
Art. 46 Recovery plan Audit	Planned	EBA Recovery Plan Guidelines require a multi-section document covering governance escalation triggers, communication plans, legal/contractual arrangements, and quantitative financial resilience scenarios. Planned: stress scenario modelling and reserve drawdown analysis for 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

Partial

MiCA classification marks each asset as ART, EMT, or other in reports today (provisional, pending legal review) - helping the CASP avoid inadvertently offering exposure to misclassified assets, which is the primary Art. 66(2) conduct risk. A planned NCA enforcement feed would monitor BaFin, ESMA, and other NCAs, raising 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. Asset classification: in reports today, provisional. NCA enforcement feed and early warning: planned.

Art. 75(8)

CASP custody liability for loss of client crypto-assets

Deck

Direct

LYRA risk scores - live today for every protocol we cover - 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 stored, and reports keep the source data that produced them. This is the single most important regulatory defense yields.digital provides to a CASP.

Art. 75

Internal custody policy and safekeeping arrangements

Deck

Supporting

Protocol-level risk metadata (contract addresses, chain, version, LYRA risk tier) gives a structured input to the 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 risk-filtered yield rationale. A single API delivering risk-filtered pools across every protocol we cover 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

Planned

yields.digital holds protocol metadata - name, contract addresses, chain, LYRA risk scores - for every protocol it covers. A planned structured DORA ICT register export in JSON/CSV format would generate and version-track the register from that data, replacing a manually kept spreadsheet.

ESMA Machine-Readable Reporting

ESMA JSON & iXBRL

Machine-readable reporting: iXBRL white papers (mandatory since Dec 2025) and JSON order book records (trading platforms)

Deck

Planned

yields.digital plans ESMA JSON reporting and iXBRL white paper disclosure templates, generated from platform data. The iXBRL white paper format became mandatory 23 December 2025 (Implementing Regulation 2024/2984). JSON order book records (Delegated Regulation 2025/416) apply to CASPs operating a trading platform. The planned reporting module builds on the MiCA asset classification already carried in reports. Planned. iXBRL is already required for white papers; JSON order book records apply to trading-platform operators.

Transfer of Funds Regulation (TFR) / Travel Rule

TFR - Travel Rule

Originator/beneficiary data for crypto-asset transfers

Deck

Planned

A planned Travel Rule address registry would automate TFR compliance verification, integrated into async ERC-7540 vault flows. Today manual tagging of DeFi interactions is the Compliance Manager's workload; the registry would remove it. 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

Planned

Credit institutions issuing ARTs must attach an approved white paper including risk and reserve disclosures. Planned: risk model outputs and reserve composition data to 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

Supporting

The authorization application requires documented, operationalized risk management policies. yields.digital risk dashboards and reports give those policies operational substance (limit monitoring and automated alerts are planned) - 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

Planned

Annex II mandates detailed disclosure of reserve composition, risk factors, and investment policy in the white paper. Planned: reserve composition data, risk factor quantification (market, credit, liquidity), and investment policy parameters to feed the required Annex II sections.

Art. 22

Quarterly reporting on ARTs to competent authority

Audit

Planned

Quarterly reports to the competent authority must cover: token holders, reserve value and composition, transaction volumes, and issuer exposure. Planned: aggregation of the data fields required for Art. 22 reporting, in the EBA-prescribed supervisory reporting template taxonomy. Planned; depends on conformance to EBA supervisory reporting template formats.

Art. 23

Restrictions on widely-used ARTs (transaction thresholds)

Audit

Planned

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. Planned: transaction volume monitoring that tracks rolling thresholds and alerts as volumes approach 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

Planned

Issuers must submit a draft modified white paper to the competent authority for approval; the CA has 30 working days to approve or refuse. Planned: reserve composition and risk monitoring to detect 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 yields.digital risk metric cited is backed by a timestamped, reproducible data trail.

Art. 27

Act honestly, fairly, in holders' best interest

Audit

Supporting

A conduct obligation the issuer owns. yields.digital risk metrics are timestamped and regularly refreshed, helping keep holder-facing risk data current 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

Planned

Issuers must publish monthly: tokens in circulation, total reserve value, and reserve composition by asset class. Planned: aggregating all three data points into disclosure-ready outputs, which depends on custodian data integration. Planned; depends on custodian data integration.

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 for the risk data and reports used in reserve management decisions - 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 risk dashboards and exportable risk reports that governance bodies consume - giving boards and senior management current visibility into risk positions rather than periodic manual reports; threshold alerts and limit-breach monitoring are planned. Direct for quantitative risk dimensions: LYRA scores market risk, fundamental risk, liquidity risk, and concentration risk (mapping to MiCA's market risk, credit risk, and concentration risk categories); stress testing and scenario analysis are planned. 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

Planned

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 of reserve asset valuation. Planned: monitoring of own funds adequacy against the regulatory floor, flagging any approach to breach ahead of time.

Art. 36

Reserve of assets - composition, management, and parity

Audit

Planned

yields.digital plans reserve-composition monitoring against issued token value, with alerts when the reserve approaches a shortfall and forward-looking shortfall modelling under stress. This depends on 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: point-in-time snapshots of on-chain wallet positions, reconciled across two independent data sources, with timestamped records. 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

Planned

Reserve funds must be invested in highly liquid, low-risk assets liquidatable with minimal market impact. Planned: checking reserve investments against these constraints, with alerts when investments approach policy limits and documentation of how the investment policy is enforced. 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

Planned

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

Art. 43

Classification as significant ART

Audit

Planned

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). Planned: monitoring of all three threshold metrics, 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

Supporting

Significant issuers face enhanced liquidity management, higher-frequency stress testing, interoperability requirements, and direct EBA supervisory data submissions. yields.digital's liquidity risk metrics are part of the underlying data foundation; stress testing and structured supervisory data outputs are planned. Full "Direct" requires confirmed implementation of EBA ITS supervisory reporting formats.

Art. 46

Recovery plan

Audit

Planned

EBA Recovery Plan Guidelines require a multi-section document covering governance escalation triggers, communication plans, legal/contractual arrangements, and quantitative financial resilience scenarios. Planned: stress scenario modelling and reserve drawdown analysis for 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.