N
FIELD
CONTENTS
I.00
Table of contents
I.01 – Date of notification
I.02 – Statement in accordance with Article 51(3) of Regulation (EU) 2023/1114
I.03 – Compliance statement in accordance with Article 51(5) of Regulation (EU) 2023/1114
I.04 – Warning in accordance with Article 51(4), points (a) and (b) of Regulation (EU) 2023/1114
SUMMARY
I.05 – Warning in accordance with Article 51(6), second subparagraph of Regulation (EU) 2023/1114
I.06 – Characteristics of the crypto-asset
I.07 – Right of redemption
I.08 – Key information about the offer and/ or admission to trading
PART A - INFORMATION ABOUT THE ISSUER OF THE E-MONEY TOKEN
A.1 – Statutory name
A.2 - Trading name
A.3 – Legal form
A.4 – Registered address
A.5 – Head office
A.6 – Registration date
A.7 – Legal entity identifier
A.8 – Another identifier required pursuant to applicable law
A.9 – Contact telephone number
A.10 – E-mail address
A.11 – Response time (days)
A.12 – Parent company
A.13 – Members of the management body
A.14 – Business activity
A.15 – Parent company business activity
A.16 – Conflicts of interest disclosure
A.17 – Issuance of other crypto-assets
A.18 – Activities related to other crypto-assets
A.19 – Connection between the issuer and the entity running the DLT
A.20 – Description of the connection between the issuer and the entity running the DLT
A.21 – Newly established
A.22 – Financial condition over the past three years
A.23 – Financial condition since registration
A.24 – Exemption from authorisation
A.25 – E-money Token authorisation
A.26 – Authorisation authority
A.27 – Persons other than the issuer offering to the public or seeking admission to trading of the e-
money token in accordance with Article 51(1), second subparagraph of Regulation (EU) 2023/1114
A.28 – Persons other than the issuer offering to the public or seeking admission to trading of the e-
money token in accordance with Article 51(1), second subparagraph of Regulation (EU) 2023/1114
A.29 - Reason for offering to the public or seeking admission to trading of the e-money token by
persons referred to in Article 51(1), second subparagraph of Regulation (EU) 2023/1114
PART B - INFORMATION ABOUT THE E-MONEY TOKEN
B.1 – Name
B.2 – Abbreviation
B.3 – Details of all natural or legal persons involved in design and development
A DESCRIPTION OF THE CHARACTERISTICS OF THE E-MONEY TOKEN, INCLUDING THE DATA
NECESSARY FOR CLASSIFICATION OF THE CRYPTO-ASSET WHITE PAPER IN THE REGISTER
REFERRED TO IN ARTICLE 109, AS SPECIFIED IN ACCORDANCE WITH PARAGRAPH 8 OF THAT
ARTICLE
B.4 – Type of white paper
B.5 – The type of submission
B.6 – Crypto-assets characteristics
B.7 – Website of the issuer
B.8 – Starting date of offer to the public or admission to trading
B.9 – Publication date
B.10 – Any other services provided by the issuer
B.11 – Language or languages of the white paper
B.12 – Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto
assets to which the white paper relates, where available
B.13 – Functionally fungible group digital Token Identifier, where available
B.14 – Personal data flag
B.15 – LEI eligibility
B.16 – Home member state
B.17 – Host member states
PART C - INFORMATION ABOUT THE OFFER TO THE PUBLIC OF THE E-MONEY TOKEN OR ITS
ADMISSION TO TRADING
C.1 – Public offering or trading
C.2 – Number of units
C.3 – Trading platforms
C.4 – Trading platforms Market Identifier Code (MIC)
C.5 – Applicable law
C.6 – Competent court
PART D - INFORMATION ON THE RIGHTS AND OBLIGATIONS ATTACHED TO E-MONEY TOKENS
D.1 – Holder’s rights and obligations
D.2 – Conditions of modifications of rights and obligations
D.3 – Description of the rights of the holders
D.4 – Rights in implementation of recovery plan
D.5 – Rights in implementation of redemption plan
D.6 – Complaint submission contact
D.7 – Complaints handling procedures
D.8 – Dispute resolution mechanism
D.9 – Token value protection schemes
D.10 – Token value protection schemes description
D.11 – Compensation schemes
D.12 – Compensation schemes description
D.13 – Applicable law
D.14 – Competent court
PART E - INFORMATION ON THE UNDERLYING TECHNOLOGY
E.1 – Distributed ledger technology
E.2 – Protocols and technical standards
E.3 – Technology used
E.4 – Purchaser’s technical requirements
E.5 – Consensus mechanism
E.6 – Incentive mechanisms and applicable fees
E.7 – Use of distributed ledger technology
E.8 – DLT functionality description
E.9 – Audit
E.10 – Audit outcome
PART F - INFORMATION ON THE RISKS
F.1 – Issuer-related risks
F.2 – Token-related risks
F.3 – Technology-related risks
F.4 – Mitigation measures
PART G - INFORMATION ON THE SUSTAINABILITY INDICATORS IN RELATION TO ADVERSE IMPACT
ON THE CLIMATE AND OTHER ENVIRONMENT-RELATED ADVERSE IMPACTS
G.1 – Adverse impacts on climate and other environment-related adverse impacts
I.01
Date of notification
This white paper was notified to the Autorité de contrôle prudentiel et de résolution on November 26th, 2025 .
I.02
Statement in
accordance with
Article 51(3) of
Regulation (EU)
2023/1114
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 White Paper.
I.03
Statement in
accordance with
Article 51(5) of
Regulation (EU)
2023/1114
This crypto-asset white paper complies with Title IV of Regulation (EU) 2023/1114 of the European Parliament
and of the Council and to the best of the knowledge of the management body, the information presented in the
crypto-asset white paper is fair, clear, and not misleading and the crypto-asset white paper makes no
omission likely to affect its import.
I.04
Warning in
accordance with
Article 51(4),
points
(a) and (b) of
Regulation (EU)
2023/1114
The e-money token is not covered by the investor compensation schemes under Directive 97/9/EC of the
European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the
European Parliament and of the Council.
SUMMARY
I.05
Warning in
accordance with
Article 51(6),
second
subparagraph of
Regulation (EU)
2023/1114
Warning
This summary should be read as an introduction to the crypto-asset white paper. The prospective holder
should base any decision to purchase this e-money token on the content of the crypto-asset white paper as a
whole and not on this summary alone.
The offer to the public of this crypto asset does not constitute an offer or solicitation to purchase financial
instruments and any such offer or solicitation can be made only by means of a prospectus or other offer
documents pursuant to the applicable national law.
This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of
the European Parliament and of the Council or any other offer document pursuant to European Union or
national law.
I.06
Characteristics
of the crypto-
asset
EURC is an e-money token ("EMT"), available on public blockchain networks. EURC provides a faster, safer,
and more efficient way to send, spend, and exchange money around the world.
For every EURC issued by Circle SAS and remaining in circulation, Circle SAS will hold either one euro
("EUR") or an equivalent amount of EUR-denominated assets on behalf of holders, in order to facilitate the
frictionless movement of the e-money tokens, utilizing blockchain technology. As a fully reserved e-money
token, EURC is backed by an equivalent amount of euro-denominated assets held by Circle SAS and
redeemable 1:1 for euros.
I.07
Right of
redemption
The holders of this e-money token have a right of redemption at any time and at par value. This applies to
holders of EURC globally. Conditions and processes for redemption of EURC are detailed in our Redemption
I.08
Key information
about the offer
and/ or
admission to
trading
EURC is only available for issuance through the Circle Mint service and it is accessible only to institutions
located in supported jurisdictions. For a complete list of currently supported jurisdictions, please consult our
Website. EURC is listed across different regulated crypto-asset service providers and Circle SAS intends to
seek its admission to trading on future MiCA-compliant trading platforms.
PART A - INFORMATION ABOUT THE ISSUER OF THE E-MONEY TOKEN
A.1
Statutory name
A.2
Trading name
A.3
Legal form
A.4
Registered
address
Not applicable as LEI is provided in A.7
A.5
Head office
Not applicable as LEI is provided in A.7
A.6
Registration date
A.7
Legal entity
identifier
A.8
Another
identifier
required
pursuant to
applicable law
A.9
Contact
telephone
number
A.10
E-mail address
A.11
Response time
(days)
A.12
Parent company
A.13
Members of the
management body
Identity
Business Address
Function
A.14
Business activity
Circle SAS is a Digital Asset Services Provider registered with the AMF under number E2024-111, authorised
to provide digital assets custody and trading of digital assets against other digital assets since April 15th, 2024.
Circle SAS is also an Electronic Money Institution registered with the ACPR under number 17788, and
A.15
Parent company
business activity
A.16
Conflicts of
interest disclosure
We frequently engage with a wide variety of blockchain and digital asset industry participants, as well as
startups and growth companies, and maintain relationships with a significant number of crypto-asset projects,
developers, and investors. These transactions and relationships could create potential conflicts of interest in
management decisions that we make. For instance, certain of our officers, directors, and employees are active
investors in crypto-asset projects and other growth companies themselves, and may make investment
decisions that favor projects in which they have personally invested. Many of our large shareholders also make
A.17
Issuance
of other
crypto-
assets
A.18
Activities related
to other crypto-
assets
A.19
Connection
between the
issuer and the
entity running the
DLT
A.20
Description of the
connection
between the
issuer and the
entity running the
DLT
Circle SAS offers EURC on 5 blockchains: Avalanche, Base, Ethereum, Stellar, and Solana. Circle SAS will
likely add additional blockchain support in the future and update the relevant sections of the White Paper
accordingly.
For each of these blockchains, Circle has entered into agreements with the blockchain entity or foundation,
where it exists, responsible for its adoption, by which Circle agrees to design and deploy EURC on blockchain
networks, to make it available on the Circle Mint application, and to offer support to Circle clients accordingly.
Circle, for regulatory reasons (including transaction monitoring), and as part of its commitment to support the
ecosystem, runs a node on each of the supported blockchains.
It is common practice for the relevant blockchain foundation to support Circle's technical development efforts
through a one-off financial compensatory payment.
A.21
Newly established
A.22
Financial
condition for the
past three years
A.23
Financial condition
since registration
Circle SAS was created on June 30th, 2023.
Between June 30th, 2023, and July 1st, 2024, Circle SAS did not engage in any commercial activities. The
company was formally incorporated on July 10th, 2023, but its operational activities, including the issuance of
EURC, commenced on July 1st, 2024, after the completion of the necessary regulatory approvals.
Circle SAS started its activities of issuance of EURC on July 1st, 2024. The share capital of Circle SAS as of
September 30th, 2025 corresponds to €159,000,000.00. In FY2024, Circle SAS reported a turnover (Net
Banking Income) equal to €3,300,119. As of December 31st, 2024, Circle SAS reported corporate cash of
€17,871,528 and net assets of €26,309,821.
A.24
Exemption from
authorisation
A.25
E-money token
authorisation
Circle SAS is a licensed Electronic Money Institution under n°737158 and a registered Digital Assets Services
Provider in France under n°E2024-111.
A.26
Authorisation
authority
A.27
Persons other
than the issuer
offering to the
public or
seeking
admission to
trading of the e-
money token in
accordance with
Article 51(1),
Not applicable.
second
subparagraph,
of Regulation
(EU) 2023/1114
A.28
Persons other
than the issuer
offering to the
public or
seeking
admission to
trading of the e-
money token in
accordance with
Article 51(1),
second
subparagraph,
of Regulation
(EU) 2023/1114
A.29
Reason for
offering to the
public or seeking
admission to
trading of the e-
money token by
persons referred
to in Article 51(1),
second
subparagraph, of
Regulation (EU)
2023/1114
PART B - INFORMATION ABOUT THE E-MONEY TOKEN
B.1
Name
B.2
Abbreviation
B.3
Details of all
natural or legal
persons involved
in design and
development
Identity
Business Address
A DESCRIPTION OF THE CHARACTERISTICS OF THE E-MONEY TOKEN, INCLUDING THE DATA NECESSARY FOR
CLASSIFICATION OF THE CRYPTO-ASSET WHITE PAPER IN THE REGISTER REFERRED TO IN ARTICLE 109, AS SPECIFIED IN
ACCORDANCE WITH PARAGRAPH 8 OF THAT ARTICLE
B.4
Type of white
paper
B.5
The type of
submission
B.6
Crypto-asset
characteristics
EURC is defined as an e-money token pursuant to Article 3.1(7) of MiCA.
by Article 56 of MiCA.
EURC is a digital token pegged to the EUR and was first issued by Circle LLC in June 2022. From July 1st,
2024, Circle LLC ceased issuing EURC, and Circle SAS became the sole issuer of EURC.
EURC is fully backed by an equivalent amount of EUR-denominated assets held by Circle SAS with regulated
financial institutions in segregated accounts separate from Circle SAS’s corporate funds, on behalf of, and for
the benefit of, EURC holders (the "Segregated Accounts"). This means that for every EURC issued by Circle
SAS and remaining in circulation, Circle SAS holds on behalf of holders either one EUR or an equivalent
amount of EUR-denominated assets in its Segregated Accounts (the "EURC Reserves").
The EURC Reserves are independently reviewed by leading accounting firms, providing monthly confirmation
that they match or exceed the EURC in circulation. EURC is not designed to create returns for holders,
B.7
Website of the
issuer
B.8
Starting date of
offer to the
public or
admission to
trading
B.9
Publication date
May 31st, 2024 and amended on September 12th, 2024 and December 24th, 2025 .
B.10
Any other services
provided by the
issuer
Circle SAS is a registered Digital Assets Services Provider in France under n°E2024-111. It provides digital
B.11
Language or
languages of the
white paper
B.12
Digital token
identifier code
used to uniquely
identify the
crypto-asset or
each of the
several crypto
assets to which
the white paper
relates, where
available
Blockchain
DTI Code
Avalanche
Base
Ethereum
Solana
Stellar
B.13
Functionally
fungible group
digital token
identifier, where
available
B.14
Personal data flag
B.15
LEI eligibility
B.16
Home Member
State
B.17
Host Member
States
PART C - INFORMATION ABOUT THE OFFER TO THE PUBLIC OF THE E-MONEY TOKEN OR ITS ADMISSION TO TRADING