As dozens of firms secure coveted EU crypto registrations and hundreds remain locked out, Serenity biometric platform joins the regulatory winners’ circle.
In the seven months since Europe’s Markets in Crypto-Assets (MiCA) regulation took full effect, the battlefield has become brutally clear: you’re either registered, or you’re out.
By July 2025, just 53 entities had secured full MiCA authorizations—14 e-money token (EMT) issuers and 39 crypto-asset service providers (CASPs) across the entire European Union. Over 120 enforcement actions had targeted non-compliant projects. More than 250 crypto startups postponed European launches due to regulatory delays. And Tether, the world’s largest stablecoin, was delisted from major EU exchanges for failing to meet reserve requirements.
Now, Serenity—a Dubai-based biometric authentication and tokenization infrastructure company—has secured white paper notification through the Malta Financial Services Authority (MFSA) and publication in the ESMA Interim MiCA Register.
The achievement positions Serenity’s $SERSH token among the first wave of projects to complete MiCA’s notification process.
White Paper Notification vs. Full Authorization: What Serenity Actually Achieved
Here’s what matters: Serenity didn’t need a license. And that’s precisely the point.
Under MiCA Title II, offerors of “Other Crypto-Assets” (OCAs)—tokens that aren’t stablecoins or asset-referenced tokens—must notify their white paper to competent authorities at least 20 working days before publication. The authority has five working days to review for completeness. But crucially, no prior approval is required.
Once notified, the white paper can be published on the issuer’s website, and the token can be lawfully offered across all 27 EU member states. The notification is then recorded in ESMA’s central register, creating a public record of compliance.
This differs dramatically from the authorization required for CASPs (crypto-asset service providers), which face extensive capital requirements, ongoing supervision, and multi-month application processes. It also differs from Asset-Referenced Tokens (ARTs), which require prior approval of their white papers before publication.
Serenity’s pathway—notification without prior approval—represents the most accessible MiCA compliance route for token issuers. Yet even this lighter-touch process has proven a bottleneck, with most projects failing to achieve even basic notification status.
The Strategic Value of Being First: Registration as Competitive Moat
“MiCA establishes the first truly harmonized crypto regulation globally,” said Venket Naga, Serenity’s CEO. “For Serenity, MiCA compliance is more than a legal requirement—it’s a competitive advantage”.
The numbers support his thesis. While Silicon Valley startups obsess over growth hacks and viral adoption, Europe’s crypto market has transformed into a regulatory fortress where compliance timelines determine winners and losers before products even launch.
European crypto exchanges reported a 22% increase in compliance costs in 2025. Stablecoin issuers saw regulatory expenses surge 35%. Over 65% of exchanges adjusted compliance strategies, while 70% of crypto custodians expanded legal teams.
For startups without venture capital war chests or institutional backing, these numbers are fatal. The white paper alone must contain comprehensive information about the crypto-asset, including characteristics, risks, intended use, associated rights, and detailed disclosures ensuring investor transparency.
Serenity cleared these hurdles through its affiliated issuer Quant ID Systems Inc., supervised by MFSA—demonstrating the organizational sophistication and legal firepower required even for MiCA’s simplest compliance pathway.
The $SERSH Utility Play: Why Token Classification Matters Under MiCA
Serenity positions $SERSH as a utility token—the access key to its vertically integrated ecosystem comprising sAxess biometric hardware, S-Box secure modules, the patent-pending DeDaSP survivability protocol, RWS tokenization engine, and DePIN-based private-cloud infrastructure.
This classification is crucial because MiCA creates three distinct token categories, each with radically different compliance burdens:
- •E-Money Tokens (EMTs): Stablecoins pegged 1:1 to fiat currencies, requiring notification but facing strict reserve requirements and supervision
- •Asset-Referenced Tokens (ARTs): “Flatcoins” pegged to baskets of assets or commodities, requiring prior approval of white papers and €350,000+ capital reserves
- •Other Crypto-Assets (OCAs): Everything else, including utility tokens, governance tokens, and non-stablecoin cryptocurrencies—requiring only notification, not approval
By structuring $SERSH as a utility token under OCA classification, Serenity avoids prior approval requirements and capital reserve mandates that sink most stablecoin projects—while still gaining lawful offering rights across all 27 EU member states.
Malta’s Strategic Position: First In, Still Registering
Serenity’s choice of Malta as its regulatory jurisdiction reflects strategic calculation. Despite recent ESMA scrutiny over pre-MiCA crypto licensing practices, Malta continues processing new notifications and maintains its reputation as Europe’s crypto pioneer.
The country holds 5 of the EU’s 53 fully authorized entities—a disproportionate share for a nation of 500,000 people. More importantly, Malta’s Malta Financial Services Authority (MFSA) has institutional knowledge dating to 2018, when it became the first EU jurisdiction to comprehensively regulate crypto-assets under its Virtual Financial Assets Act.
This regulatory head start translates to faster processing times and clearer guidance for token issuers navigating MiCA’s notification requirements.
The ESMA Register: Public Record as Market Signal
Once notified and published, Serenity’s $SERSH white paper appears in ESMA’s central register of crypto-asset white papers. This public listing serves multiple functions beyond legal compliance.
First, it signals institutional legitimacy to potential enterprise clients—governments, banks, and Web3 companies seeking secure digital asset infrastructure. Second, it enables pan-European marketing without country-by-country regulatory approval. Third, it creates a compliance moat against competitors who lack the legal sophistication or capital to navigate even basic notification requirements.
ESMA’s register also includes machine-readable white paper formats and standardized data fields enabling classification by token type. This transparency requirement disadvantages projects that thrived in regulatory ambiguity while benefiting well-capitalized issuers like Serenity with legitimate business models.
The Notification Process: Simple in Theory, Complex in Practice
MiCA’s notification process appears straightforward on paper: submit white paper 20 working days before publication, wait five working days for completeness review, then publish. In reality, the documentation burden creates significant barriers.
Issuers must submit the white paper itself plus a justification explaining why the crypto-asset is not an asset-referenced token, e-money token, or excluded financial instrument. They must provide a list of all EU member states where the token will be offered or listed. Marketing communications must comply with Article 7 requirements and be available for regulatory review.
The white paper must follow standardized templates specified in ESMA regulatory technical standards, include comprehensive risk disclosures, and remain accessible on the issuer’s website for as long as tokens are held by the public.
For projects accustomed to issuing tokens via Medium posts and Twitter threads, these requirements represent an insurmountable compliance barrier. For institutionally-backed infrastructure companies like Serenity, they represent defensible market positioning.
First-Wave Advantage: The 12-Month Window
With MiCA white paper notification secured, Serenity can now lawfully offer and market $SERSH across all EU member states under a single harmonized framework while competitors navigate regulatory uncertainty.
The strategic value is measurable. Crypto.com, upon receiving in-principle MiCA authorization as a CASP, immediately highlighted its ability to “provide its full range of services throughout the EU under streamlined regulations” and called the approval “a testament to our commitment to responsible growth”.
Regulatory compliance has become the primary market differentiator in European crypto markets, more valuable than technology innovation, user experience, or network effects.
The Ecosystem Bet: When Tokens Unlock Infrastructure Access
$SERSH’s utility model—token-gated access to biometric hardware, DePIN infrastructure, and tokenization engines—mirrors the emerging playbook of MiCA-era crypto projects: build compliance first, then monetize infrastructure access through tokens rather than pure speculation.
This aligns with MiCA’s core philosophy. The regulation aims to eliminate regulatory fragmentation, establish consumer protections, prevent market manipulation, and create clear rules for issuers and service providers.
Serenity’s vertically integrated ecosystem targeting governments, enterprises, banks, and Web3 companies positions $SERSH as infrastructure access rather than speculative asset.