Rule · BLOCKER

ANNEX_III.A

Information about the issuer of the EMT (authorisation or exemption, management body)

Citation: Annex III, Part A MiCAR
Canonical form: Anhang III Teil A MiCAR
Runs for: Annex III · e-money tokens
Severity if open: BLOCKER
Section key: issuer
Minimum words: 80
Listed terms (English): issuer, management body, address (pattern (?P<address>(?<!e-mail[ -])(?<!email[ -])(?<!contract )(?<!wallet )\baddress(?:es)?\b(?!\s+(?:the|this|these|those|risks?|issues?)\b)))
Listed terms (German): emittent, leitungsorgan, anschrift (pattern (?P<anschrift>(?<!e-mail-)(?<!e-mail )anschrift))
Package version: 1.2.1, built from source that may include unreleased changes
Source: rules/annex_iii.py

How the status is set

Missing: section issuer is absent or empty, or holds only placeholder text such as TBD or TBC.
Review: the section has fewer than 80 words, or a listed term does not appear (case-insensitive substring match, with any run of spaces and line breaks read as one space; a term shown with a pattern counts only where the pattern matches, so that a look-alike word does not stand in for it).
In a numbered-field XHTML draft, Review also follows when a field of the section holds only a placeholder such as TBD; the finding names the field by its number and, in English, by the template's name where the linter has one for that field.
Pass: none of the above. A pass means the check matched, nothing more.

Legal basis

Annex III, Part A MiCAR

https://eur-lex.europa.eu/eli/reg/2023/1114/oj/eng

Checked on 2026-10-27 against the Official Journal text in English and German (OJ L 150, 9.6.2023) and the consolidated version of 9 January 2024, and against the templates of Implementing Regulation (EU) 2024/2984. No amendment and no English or German corrigendum changes Art. 48, Annex III Part A or the templates.

Synthetic examples

Each example is linted when this page is generated. The build fails if a result differs.

MissingSection absent

The section key is missing or empty.

{
  "title": "Synthetic rule example",
  "type": "emt",
  "sections": {}
}

ReviewThin section

Every listed term appears, but the section is shorter than 80 words.

{
  "title": "Synthetic rule example",
  "type": "emt",
  "sections": {
    "issuer": "issuer management body address"
  }
}

PassSection that matches

This text passes and shows what the check measures: listed terms and length. It is not model disclosure wording and does not meet MiCAR.

{
  "title": "Synthetic rule example",
  "type": "emt",
  "sections": {
    "issuer": "Synthetic example naming issuer, management body, address. This synthetic sentence only adds length and states no fact about any issuer or token. This synthetic sentence only adds length and states no fact about any issuer or token. This synthetic sentence only adds length and states no fact about any issuer or token. This synthetic sentence only adds length and states no fact about any issuer or token. This synthetic sentence only adds length and states no fact about any issuer or token."
  }
}

Limitations

Reads one section key, issuer. Text elsewhere in the draft is not considered.
Matches words and counts length. It does not test accuracy, consistency with other sections or the point-level items of the cited Part.
Status and severity are fixed by the rule. A draft cannot waive or downgrade them.
The Annex III rules have not yet been run against a real EMT white paper.

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