This page explains how the Pharos MiCA Engineering Evidence Hub turns primary regulatory sources into bounded engineering notes. It separates what the source says, what Pharos interprets for implementation and what remains an open design or legal decision.
Every material statement belongs to one of three classes:
Regulatory source summary: a bounded paraphrase linked to the primary source. It preserves relevant conditions and does not claim to replace the source text.
Pharos implementation note: an engineering translation, pattern, risk or test proposed by Pharos Production.
Open design decision: an unresolved choice that depends on counsel-approved scope, system architecture, service profile, risk appetite or national competent-authority expectations.
If a paragraph blends two classes, split it. A reader should never have to guess whether a statement came from a regulation or from an engineering judgment.
Sources are used in this order:
Official Journal and consolidated legal text on EUR-Lex.
Adopted delegated and implementing regulations.
European Securities and Markets Authority (ESMA), European Banking Authority (EBA) and European Commission publications.
National competent-authority material for jurisdiction-specific implementation.
Pharos implementation experience and first-party artifacts, explicitly labeled.
Secondary commentary only to discover a primary source or frame an open question.
Secondary commentary is not used to overrule primary law. Search snippets, unsourced summaries and vendor claims do not establish an obligation.
Regulation (EU) 2023/1114 on markets in crypto-assets: core MiCA text. Retrieved 13 August 2026.
Commission Delegated Regulation (EU) 2025/294: complaints-handling requirements, templates and procedures. Retrieved 13 August 2026.
Commission Delegated Regulation (EU) 2025/299: continuity and regularity in crypto-asset services. Retrieved 13 August 2026.
Commission Delegated Regulation (EU) 2025/885: arrangements, systems and procedures for market-abuse prevention, detection and reporting. Retrieved 13 August 2026.
Commission Delegated Regulation (EU) 2025/1140: CASP records, orders, transactions and services. Retrieved 13 August 2026.
Draft: source-linked content prepared, but not approved for operational reliance.
Source checked: links, article references and stated dates were checked against the cited primary sources.
Engineering reviewed: a named technical reviewer has checked feasibility, boundaries and testability.
Legal-scope reviewed: qualified counsel has checked applicability and legal interpretation for the stated context.
Released: the record has named owners, review dates and change triggers.
Retired: the record is preserved for history but must not drive new work.
The initial public content remains a source-linked engineering draft unless a page explicitly names a later review state. "Source checked" does not mean legally approved.
A block belongs in this hub only when it does at least one useful job:
clarifies a source-to-control relationship.
exposes an exception, limitation, dependency or failure mode.
provides a reusable field, test or evidence artifact.
records a source change and its implementation consequence.
General explanations already covered on the canonical Pharos website are linked rather than copied. The hub is not a second services catalog.
Review a record when any of the following occurs:
a cited EU act is amended, corrected or supplemented.
ESMA, EBA, the European Commission or a relevant NCA publishes material that changes the interpretation.
the CASP adds or removes a service, jurisdiction, token type or custody model.
a vendor, data source or system of record changes.
an incident, complaint, failed control test or supervisory request exposes a missing assumption.
60 days pass during the pilot without another trigger.
Corrections are append-only. Record the date, affected page and control ID, previous statement, new statement, source, reason and reviewer. Do not silently replace a material legal anchor or engineering conclusion.
Version 0.1, 13 August 2026
Created the five-page pilot structure. Added worked controls for continuity, record-keeping, complaints, custody records and market-abuse surveillance. Added the architecture worksheet, implementation failure modes, source hierarchy and explicit legal boundary.
Editorial owner: Pharos Production
Default pilot review interval: 60 days
Correction channel: use the contact route on the canonical Pharos Production website.