1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Holders of non-custodial wallet cannot be less than retail holders (EBA rule v22920_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

Holders of non-custodial wallet cannot be less than retail holders.

All the values are in the number column (0010) of Q 01.00.

How the Line4 Check report words itShow

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

holders of non-custodial wallet >= of which retail holders

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Compare the values in your file. If the first is smaller than it may be, one of them is wrong: check both before you change either.
  3. 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  4. 04It runs only when your filing indicators mark Q 01.00 as reported.
  5. 05This 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

  • 0040holders of non-custodial wallet
  • 0050of which retail holders

Column

  • 0010Number

A worked example

The first of its checks, with simple numbers.

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

Retail holders can then be at most 1,200.

1,200Passes
1,300Fails

A file that reports 1,200 passes. One that reports 1,300 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,r0040,c0010,} >= {Q_01.00,r0050,c0010,}

Every MiCA rule, by template

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