Crypto-assets: EU Commission defines sustainability indicators

Transactions relating to crypto-assets, including their issuance, are validated and recorded through consensus mechanisms. These mechanisms concern rules and procedures for reaching an agreement on the validation of a transaction between distributed ledger technology (DLT) network nodes, which are also responsible for keeping records of all transactions in a distributed ledger.

Reaching consensus requires the use of materials and computing power that entail impacts on the climate and the environment that vary depending on the DLTs and their specific characteristics.

Therefore, for investors in crypto-assets, it is of fundamental importance to identify and communicate the aforementioned impacts, through accurate, correct, clear, non-misleading, simple, concise and comparable information.

To this end, mandatory, supplementary and optional indicators have been defined that the entities required to draft White Papers, as well as the providers of services for crypto-assets, must comply with.

Information to be included in White Papers

EU Regulation 2025/422 introduces new directives that integrate the content of White Papers on crypto-assets, i.e. the documents that issuing entities are required to publish in order to ensure transparency of information, helping the public to understand who is the responsible entity, the rights and obligations of the user, the technology underlying the transfer of crypto-assets and the related risks.

Specifically, the people who draft the White Papers must include in them the information contained in Table 2 attached to the aforementioned Regulation and, if the annual energy consumption (Table 2, field S.8), is greater than 500.000 kilowatt hours, the document must also indicate the data contained in the subsequent Table 3.

Information to include on websites

Crypto-asset service providers shall make the information available on their website by:

• making it available free of charge;
• providing it in the form of a downloadable file, in an easy-to-read format and with a legible font size. It shall be written in a style that facilitates understanding and comparison of the information relating to each of the crypto-assets in relation to which the crypto-asset service provider provides its services.

The information shall be made available in at least one of the official languages ​​of the home Member State of the service provider, or in a language customary in the sphere of international finance. However, where the service provider provides services in relation to a specific crypto-asset in a Member State other than its home Member State, the information shall also be made available in an official language of the host Member State or in a language customary in the sphere of international finance.

Service providers must review and update the above information periodically, at least once a year. In the event of substantial changes, the information must be updated without undue delay and accompanied by clear indications of the changes made. The date of publication of the information and the date of the last review or update must also be clearly indicated on the website.

The information to be included on the websites of the providers is that listed in the previous Table 2. They must also make available the data set out in Table 3 if both of the following conditions are met:

• the crypto-asset service provider provides one or more of the services referred to in art. 3 par. 1 point 16) letters b), c) and d) of Regulation (EU) 2023/1114;
• the annual energy consumption indicated in Table 2, field S.8, is greater than 500 000 kilowatt hours.

In addition to the mandatory and supplementary key indicators, it is possible to voluntarily include, in a specific part of the White Papers or the websites of crypto-asset service providers, information on climate indicators and other indicators related to the environment whose assessment may be more complex or for which it may be more difficult to find relevant data. Such information is specifically listed in Table 4 attached to EU Regulation 2025/422.