Three Formats, One Regulatory Requirement
Crypto-asset issuers approaching MiCAR compliance for the first time typically have their whitepaper in one of two formats: PDF or HTML. Some have both. Under MiCAR (EU 2023/1114), neither is accepted for regulatory submission. The only format that national competent authorities will accept is iXBRL.
This does not mean your existing PDF or HTML whitepaper is wasted. It means it needs to be converted. Understanding the differences between these formats helps you understand why the conversion is necessary and what it involves.
PDF: The Industry Standard That Regulators Cannot Process
PDF (Portable Document Format) has been the default format for crypto whitepapers since Bitcoin's original whitepaper was published as a PDF in 2008. It preserves layout, fonts, and formatting across all devices. It is great for sharing documents that need to look the same everywhere.
But from a data perspective, PDF is a black box. The content is stored as visual instructions: coordinates for text placement, font specifications, image positions. There are no semantic tags telling a computer "this is the issuer's name" or "this is the energy consumption figure." A regulator reviewing a PDF must read it manually. Automated systems cannot reliably extract structured data from a PDF.
Can you submit a PDF to an NCA? No. MiCAR requires iXBRL.
HTML: Closer, But Still Missing the Data Layer
HTML (HyperText Markup Language) is the language of the web. If your whitepaper is published on your website, it is in HTML. HTML provides more structure than PDF. Headings, paragraphs, lists, and tables are explicitly defined. Search engines can parse HTML content, and the document structure is machine-readable to some extent.
However, HTML lacks the structured data tags that regulators need. An HTML heading that says "Issuer: MiCAR Foundation" tells a browser to render it as a heading, but it does not tell a regulatory system that "MiCAR Foundation" is the value of the "IssuerLegalName" concept in the ESMA taxonomy. HTML describes presentation. iXBRL describes both presentation and meaning.
Can you submit HTML to an NCA? No. MiCAR requires iXBRL. However, converting HTML to iXBRL is technically simpler than converting PDF, since iXBRL is built on top of HTML.
iXBRL: The Required Format Under MiCAR
iXBRL (Inline eXtensible Business Reporting Language) combines HTML's visual presentation with XBRL's machine-readable data tags. When you open an iXBRL file in a browser, it looks like a normal web page. Underneath, every required data point is tagged with a concept from the ESMA 2025 taxonomy.
This dual nature is why regulators chose iXBRL. Investors and the public can read the whitepaper as a formatted document. Regulators and automated systems can extract structured data without any manual processing. ESMA can maintain a searchable, comparable register of all submitted whitepapers across the EU.
Side-by-Side Comparison
| Capability | HTML | iXBRL | |
|---|---|---|---|
| Visual formatting | Excellent | Good | Good |
| Machine-readable structure | None | Basic | Full |
| Taxonomy-tagged data | No | No | Yes |
| Automated data extraction | Unreliable | Limited | Complete |
| Accepted by EU NCAs | No | No | Yes |
| Conversion difficulty to iXBRL | Higher | Lower | N/A |
| Custom branding support | Full | Full | Full |
The Conversion Path: From PDF or HTML to iXBRL
If you have an existing whitepaper in PDF or HTML, the path forward is conversion. The process involves extracting your content, restructuring it to meet MiCAR's ITS requirements, filling any information gaps, tagging every required data point with the ESMA taxonomy, and validating the final file.
HTML-to-iXBRL conversion is generally faster because iXBRL is an extension of HTML. The document structure is already compatible, so the main work is adding the XBRL tags and ensuring taxonomy compliance. PDF-to-iXBRL conversion requires an additional step of rebuilding the document structure from the PDF's visual representation.
Either way, our iXBRL conversion service handles the full process. You provide your existing whitepaper, and we deliver a validated, taxonomy-compliant iXBRL file ready for NCA submission.
What If You Do Not Have a Whitepaper Yet?
If you are starting from scratch, there is no reason to create a PDF or HTML whitepaper first and then convert it. Our whitepaper drafting service produces the document directly in iXBRL format, saving you the conversion step entirely. The whitepaper is drafted based on your input, tagged with the ESMA taxonomy from the start, and delivered ready for submission.
Get your whitepaper in the right format
iXBRL is the only accepted format for MiCAR whitepaper submissions. If you have an existing whitepaper in PDF or HTML, our iXBRL conversion service will get it into shape. If you are starting fresh, our whitepaper drafting service builds it in iXBRL from day one.
