Rule · BLOCKER

ANNEX_III.D

Rights and obligations of holders (redemption at par value, no interest)

Citation: Annex III, Part D in conjunction with Art. 49(4), Art. 50(1) MiCAR
Canonical form: Anhang III Teil D i.V.m. Art. 49 Abs. 4, Art. 50 Abs. 1 MiCAR
Runs for: Annex III · e-money tokens
Severity if open: BLOCKER
Section key: rights_and_obligations
Minimum words: 80
Listed terms (English): rights, redemption, at par, no interest, holder
Listed terms (German): rechte, rückzahlung, zu par, keine zinsen, inhaber
Package version: 1.2.1, built from source that may include unreleased changes
Source: rules/annex_iii.py

How the status is set

Missing: section rights_and_obligations is absent or empty, or holds only placeholder text such as TBD or TBC.
Review: the section has fewer than 80 words, or a listed term does not appear (case-insensitive substring match).
Pass: none of the above. A pass means the check matched, nothing more.

Legal basis

Annex III, Part D in conjunction with Art. 49(4), Art. 50(1) MiCAR

https://eur-lex.europa.eu/eli/reg/2023/1114/oj/eng

Not re-verified since these pages were introduced (2026-10-20): EUR-Lex was unreachable from the build environment. The citation is the rule's own, unchanged.

Synthetic examples

Each example is linted when this page is generated. The build fails if a result differs.

MissingSection absent

The section key is missing or empty.

{
  "title": "Synthetic rule example",
  "type": "emt",
  "sections": {}
}

ReviewThin section

Every listed term appears, but the section is shorter than 80 words.

{
  "title": "Synthetic rule example",
  "type": "emt",
  "sections": {
    "rights_and_obligations": "rights redemption at par no interest holder"
  }
}

PassSection that matches

This text passes and shows what the check measures: listed terms and length. It is not model disclosure wording and does not meet MiCAR.

{
  "title": "Synthetic rule example",
  "type": "emt",
  "sections": {
    "rights_and_obligations": "Synthetic example naming rights, redemption, at par, no interest, holder. This synthetic sentence only adds length and states no fact about any issuer or token. This synthetic sentence only adds length and states no fact about any issuer or token. This synthetic sentence only adds length and states no fact about any issuer or token. This synthetic sentence only adds length and states no fact about any issuer or token. This synthetic sentence only adds length and states no fact about any issuer or token."
  }
}

Limitations

Reads one section key, rights_and_obligations. Text elsewhere in the draft is not considered.
Matches words and counts length. It does not test accuracy, consistency with other sections or the point-level items of the cited Part.
Status and severity are fixed by the rule. A draft cannot waive or downgrade them.
The Annex III rules have not yet been run against a real EMT white paper.

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