Rule · BLOCKER
ANNEX_III.NOT_APPROVED_STATEMENT
First-page statement that no competent authority has approved the white paper (wording only; first-page placement not checked)
- Citation
- Art. 51(3) MiCAR
- Canonical form
- Art. 51 Abs. 3 MiCAR
- Runs for
- Annex III · e-money tokens
- Severity if open
- BLOCKER
- Section key
not_approved_statement- Minimum words
- 0
- Listed terms (English)
this crypto-asset white paper has not been approved by any competent authority in any member state of the european union,the issuer of the crypto-asset is solely responsible for the content of this crypto-asset white paper- Listed terms (German)
- none
- 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
not_approved_statementis absent or empty, or holds only placeholder text such as TBD or TBC. - Review: the draft is German, because the German wording has not been checked against the German Official Journal; the section holds only a yes or no value; a listed English term does not appear.
- Pass: an English draft holds both listed terms. Matching ignores case and reads any run of spaces and line breaks as one space. A compound broken after its hyphen at a line end keeps the hyphen, so “crypto-” and “asset” on two lines match “crypto-asset”; a word split only for the line break (“Mem-”, “ber”) does not match and goes to review. Placement on the first page is not checked.
Legal basis
Art. 51(3) MiCAR
The citation and the English wording the rule checks were read in the EUR-Lex text of Art. 6(3) and Art. 51(3) MiCAR as mirrored in legalize-dev/legalize-eu (CELEX 32023R1114), not on EUR-Lex itself, which was unreachable from the build environment. The German wording has not been checked.
Synthetic examples
Each example is linted when this page is generated. The build fails if a result differs.
The section key is missing or empty.
{
"title": "Synthetic rule example",
"type": "emt",
"sections": {}
}Art. 51(3) MiCAR names the issuer, so the responsibility sentence is not found.
{
"title": "Synthetic rule example",
"type": "emt",
"sections": {
"not_approved_statement": "This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The offeror of the crypto-asset is solely responsible for the content of this crypto-asset white paper."
}
}The German wording has not been checked against the German Official Journal, so a German statement goes to review whatever it says.
{
"title": "Synthetic rule example",
"type": "emt",
"language": "de",
"sections": {
"not_approved_statement": "Synthetischer deutscher Beispieltext. Er gibt nicht den Wortlaut des Amtsblatts wieder."
}
}Both sentences in the English wording the rule checks. A pass says the words matched; the check cannot see whether the statement is on the first page.
{
"title": "Synthetic rule example",
"type": "emt",
"sections": {
"not_approved_statement": "This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The issuer of the crypto-asset is solely responsible for the content of this crypto-asset white paper."
}
}Limitations
- Reads one section key,
not_approved_statement. Text elsewhere in the draft is not considered. - Matches the English wording only. It cannot see whether the statement is on the first page, and it does not check that the person it names is the one responsible for the white paper.
- 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.
- PDF, DOCX, Markdown and heading-based XHTML drafts fill the section from a heading such as “Statement in accordance with Article 51(3)”, the label of field I.02 of Table 4 of Implementing Regulation (EU) 2024/2984, where the label is set as one (a Markdown “#” heading, an XHTML h1 to h6 or bold label, a DOCX heading or bold or capitals label, a PDF heading or field line), or, without one, from a line or paragraph that opens with the statement's first words. Numbered-field XHTML fills it from field I.02. Table cells are not read in DOCX, nor in heading-based XHTML where the text sits directly in a td or th element rather than in a p, div, li or bold element inside it, so a statement kept only there is reported missing.
- A German draft never passes: the German wording has not been checked against the German Official Journal.
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