1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Total number of holders must equal the sum of its two parts (EBA rule v22918_m)

A warning in the asset-referenced and e-money tokens return (MiCA), on template Q 01.00, s_01.00: number of holders - at reference date.

The rule in plain words

Total number of holders must equal holders of custodial wallet plus holders of non-custodial wallet.

How the Line4 Check report words itShow

Word for word as the report shows it when the rule fails.

Total number of holders = holders of custodial wallet + holders of non-custodial wallet

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Add up the parts in your file and compare the result with the total.
  3. 03If they differ, a part is missing, a value sits in the wrong row, or the total is out of date.
  4. 04EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  5. 05It runs only when your filing indicators mark Q 01.00 as reported.
  6. 06This is a warning. It does not stop the filing on its own, but your authority may ask you to explain it.

The cells it reads

S_01.00: number of holders - at reference date (Q 01.00)

Rows

  • 0010Total number of holders
  • 0020holders of custodial wallet
  • 0040holders of non-custodial wallet

Column

  • 0010Number

A worked example

The first of its checks, with simple numbers.

Illustrative values
holders of custodial wallet1,200
holders of non-custodial wallet800
Together2,000
What the rule then expects

Total number of holders must then be 2,000.

2,000Passes
2,100Fails

A file that reports 2,000 passes. One that reports 2,100 fails, by 100.

The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.

Show the rule as writtenShow

EBA's formula. Cells are written as {template, row, column, sheet}.

{Q_01.00,r0010,c0010,} = {Q_01.00,r0020,c0010,} + {Q_01.00,r0040,c0010,}

Every MiCA rule, by template

Checks like this one, run at the point of submission, are the first step to real-time supervision.