Yes, the current SPS white paper is a good starting point, but it will need to be expanded to meet the baseline requirements in the regulation. To save you some time skimming the entire article, I'll point you to the 12 points in Title 2 Article 6 - the lawyers will probably help to draft the final wordings, but to save legal fees it's better to read and think about the answers beforehand...
It's about a page worth of reading, and lays them out one after another.
(There is also a Template in Annex 1.)
A few other meaty things I haven't seen well-described in the current SPS white paper:
- description of risks
- description of the underlying technology
- climate/environmental information
- transparency for key individuals
- a handful of required statements, for example:
"This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The offeror of the crypto-asset is solely responsible for the content of this crypto-asset white paper"
Some of that stuff is kind of annoying but easy to do. Others take more thought.
It also need to be more current - most of it reads like the DAO "will be set up" - but obviously we are well past that point and lots of SPS proposals later so I'd say that more of the "meat" needs to be updated.