mica-research

name	mica-research
description	Research and populate EU MiCA compliance data (the `mica` field) for a tracked stablecoin in the Pharos dashboard. Use when adding or auditing MiCA authorization status, token type, competent authority, or issuer authorization in `shared/data/stablecoins/coins/*.json`.

MiCA Research

Research a stablecoin's standing under the EU Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114) and write a sourced mica object into the coin's per-coin JSON entry when the evidence supports it.

Read First

• Read docs/mica-tracker.md — the source of truth for the mica schema, the status criteria table, EMT/ART rules, sourcing requirements, and legal framing. Defer to it for classification; this skill is the workflow only.
• Read the coin's entry in shared/data/stablecoins/coins/*.json (or shared/data/stablecoins/coins.generated.json for a canonical runtime view). Treat the runtime stablecoin re-export as import-only; mica edits belong in the per-coin JSON and must match shared/lib/stablecoins/schema.ts.
• Treat existing jurisdiction free text (regulator, license e.g. "EMI (MiCA)", "ACPR") as a starting hypothesis, not truth — verify against a register.

Schema

The mica object (exact field names): status (authorized | pending | transitional | non-compliant | out-of-scope), tokenType (EMT | ART), authorizationType (emi | credit-institution), competentAuthority, authorizedEntity, significant (boolean), references ({ label, url }[]). All but status are optional.

HARD RULES (Zod-enforced — check:stablecoin-data fails otherwise): every status except out-of-scope requires at least one references link; and out-of-scope rows must not carry tokenType, authorizationType, competentAuthority, or authorizedEntity.

Workflow

1. Read current state: jurisdiction, pegMechanism / pegged currency, any existing mica, and whether the coin is plausibly in EU scope at all.

2. Research the registers with WebSearch / WebFetch (browser fallback on 403 — claude-in-chrome/Playwright in Claude Code, agent-browser in Codex), in order of weight:

• ESMA register of authorized entities
• EBA registers of EMT/ART issuers (and the EBA "significant" list for significant)
• national NCA registers: ACPR REGAFI, BaFin, DNB / AFM, MFSA, CBI, Bank of Lithuania
• issuer disclosures (whitepapers, authorization announcements)
• EU venue delisting / restriction notices (evidence for non-compliant)

3. Map token → legal issuer entity → authorization on a register. This is manual, not API-able; confirm the entity matches the issuer of this token, not a same-name affiliate.

4. Assign status per the criteria table in docs/mica-tracker.md. Set tokenType: EMT = single official currency (most EUR/USD fiat-backed coins); ART = basket/commodity/other value (rare). When uncertain between two statuses, pick the more conservative one and explain why.

5. Present the proposed mica object with sources, access date, and confidence. If research-only, stop here. Otherwise, after approval, edit the per-coin JSON — placing mica immediately after jurisdiction (after genius if both are present) — then regenerate and validate:

export PATH="$PWD/node_modules/.bin:$PATH"
tsx scripts/maintenance/generate-stablecoin-per-coin-asset.ts
node scripts/build-data/build-client-registry.mjs
npm run check:stablecoin-data

For full additions, follow Phase 7 in docs/process/adding-a-stablecoin.md.

Status (defer to the spec table)

• authorized — in-effect EMI or credit-institution authorization for this token, on a register. Requires a references link; set authorizationType.
• pending — application filed with an NCA, decision outstanding.
• transitional — traded on EU venues under a member-state CASP grandfathering window, no issuer authorization yet.
• non-compliant — in EU scope, no authorization and no transitional cover; delisted/restricted on EU venues.
• out-of-scope — not offered to the public or admitted to trading in the EU.

Guardrails

• Never fabricate an authorization; no authorized without a register link naming the issuer entity.
• Leave mica undefined for unassessed or clearly non-EU coins — "not assessed" (no row) differs from out-of-scope (explicitly reviewed). Do not stamp out-of-scope on coins you have not reviewed.
• Grandfathering covers CASPs/venues, not issuers: EMT/ART issuer rules have applied since 30 Jun 2024 with no issuance grandfathering. Do not imply issuers are grandfathered.
• Set tokenType / authorizationType / significant only when a source supports them — omit rather than guess.
• This is an informational, sourced tracking surface, not legal advice.

Batch Mode

When processing multiple coins, work one at a time and present findings for 3-5 coins per approval round, then apply and continue — mirror reserve-research. For a broad MiCA + GENIUS pass across many coins, use the saved compliance-research workflow (research → adversarial verify → reconcile), as in genius-research.