Guides · MiCA marketing
MiCA marketing rules: the Article 7 checklist for crypto launches
By Arturo Ferrándiz Fernández, regulatory compliance consultant · Last reviewed 29 September 2026 · 7-minute read
In short. If you offer a token to people in the EU or want it listed on an EU platform, every landing page, post, video, ad or KOL campaign that promotes it is a marketing communication under Article 7 of MiCA. It must be recognisable as marketing, fair and not misleading, consistent with your white paper, point to that white paper, and carry a fixed statement that no authority has approved it. These rules have applied since 30 December 2024.
Who Article 7 applies to
Article 7 of Regulation (EU) 2023/1114 (MiCA) covers marketing for crypto-assets other than stablecoins: utility tokens, governance tokens, most staking and ecosystem tokens. It binds the offeror, the person seeking admission to trading and the operator of a trading platform when they prepare the communication. Stablecoins have their own, parallel rules: Article 29 for asset-referenced tokens and Article 53 for e-money tokens.
"Marketing communication" is read broadly. A pinned tweet announcing a sale, a Discord announcement with an APY, a landing page with a "Buy" button and a paid thread by an influencer all qualify. The channel does not matter; the promotional purpose does.
The four requirements of Article 7(1)
| Point | What it requires | What we see go wrong |
|---|---|---|
| 7(1)(a) | The communication is clearly identifiable as marketing. | Paid KOL threads and "community updates" that read as neutral news. |
| 7(1)(b) | The information is fair, clear and not misleading. | "Guaranteed 18% APY", "no risk", "fully protected", countdown timers with invented scarcity. |
| 7(1)(c) | It is consistent with the white paper, where one is required. | A website APY or supply figure that differs from the white paper, or promises the white paper never makes. |
| 7(1)(d) | It clearly states that a white paper has been published and gives the offeror's website address, a telephone number and an email address. | No link to the white paper and no contact details beyond a Discord invite. |
The mandatory statement
Article 7(1) also requires every marketing communication to contain this statement, clearly and prominently:
"This crypto-asset marketing communication has not been reviewed or 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 marketing communication."Regulation (EU) 2023/1114, Article 7(1), second subparagraph
Where the communication is prepared by the person seeking admission to trading or by the platform operator, "offeror" is replaced by the right reference. In practice: put it on the token page near the call to action, in the footer of every page that promotes the token, and in a form that fits posts, for example in the pinned post or bio of the campaign account and in the text of each paid placement.
No marketing before the white paper
Where a white paper is required, Article 7(2) prohibits disseminating marketing communications before it is published. Market soundings remain possible. This catches the common launch sequence of teasers, waitlists with a promised allocation and "whitelist now" campaigns weeks before the white paper exists. If you need a white paper, publish it first, then market. Our guide on white paper exemptions helps you work out whether you need one.
Before and after
| Before | After | Why |
|---|---|---|
| Stake ALBA to receive variable rewards. The current rate is 18% a year and can fall to zero. | Art. 7(1)(b): no certainty where there is none. | |
| You can lose all the value of the tokens you buy. They are not covered by any deposit or investor compensation scheme. | Art. 7(1)(b), and consistency with the white paper's risk section under Art. 7(1)(c). | |
| The sale closes on 15 November 2026 at 18:00 CET. | Invented scarcity is misleading; real limits are stated plainly. |
Influencers, KOLs and referral programmes
Paying someone to promote your token does not move the responsibility away from you. The statement in Article 7(1) makes the offeror "solely responsible" for the content. Brief your promoters in writing, give them approved wording including the statement, keep copies of what they publish and remove non-compliant posts quickly. Paid content must also be disclosed as such under the Unfair Commercial Practices Directive (Directive 2005/29/EC, Art. 7(2) and Annex I, point 11).
Who enforces it and what it costs
Authorities do not approve marketing in advance, but they supervise it. Competent authorities can require changes, suspend or prohibit marketing communications, and the authority of any Member State where you market can act and coordinate with your home authority (MiCA Arts. 7(3), 7(4) and 94). For infringements of Articles 4 to 14, Member States must provide for administrative fines of at least up to EUR 5 million or 3% of annual turnover for legal persons, and EUR 700,000 for natural persons (MiCA Art. 111(3)).
Checklist before you publish
- The page or post is clearly marketing, and paid content is labelled.
- No certain returns, no "no risk", no protection or insurance claims you cannot prove.
- Every figure (APY, supply, vesting, dates) matches the white paper.
- The white paper is published, and the communication says so with its address.
- The offeror's website, telephone number and email are stated.
- The Article 7 statement appears clearly and prominently.
- Risks are stated plainly next to the call to action.
- Promoters have written instructions and approved wording, and their posts are archived.
Check your own launch. The free scanner reads your website and flags the most common Article 7 problems in seconds. The MiCA Readiness Review reads everything you publish and gives you the corrected wording within 72 working hours.
This guide is general information about EU law as it stood on the date above. It is not legal advice and does not create a client relationship. Source: Regulation (EU) 2023/1114 on EUR-Lex.