ANNEX
SECTION 1
Records of services and activities: list of records to be kept by crypto-asset service providers according to the nature of their services and activities
Type of record
Summary of content
Communication with clients
Marketing communications
Each marketing communication issued by the crypto-asset service provider (except in oral form) or on its behalf.
Information to clients
Information other than marketing communication provided by the crypto-asset service provider, or on its behalf, to the client about the crypto-asset service provider, its services and activities, crypto-assets, and the applicable costs and related charges.
Records of communication with clients
Records of telephone conversations or electronic communications relating to transactions or to the reception, transmission and execution of client orders, including where such conversations or communications do not result in the conclusion of a transaction or in the provision of the services of reception and transmission of orders or execution of order.
Rights and obligations of the crypto-asset service provider and the client
Client agreements
Any document agreed between the crypto-asset service provider and the client that set out the rights and obligations of the parties.
Consent of the client
Any communication between the crypto-asset service provider and the client or any document evidencing that the client consented to the provision of services and to the terms upon which the crypto-asset service provider will provide such services to the client.
Market abuse
Market abuse
Records of instances where circumstances indicate that market abuse has been committed, is being committed, or is likely to be committed. Such records shall contain the identification of the persons or computer algorithms involved. For persons professionally arranging or executing transactions in crypto-assets, the records shall contain the information documenting the analysis carried out with regard to orders, transactions, and aspects of the functioning of distributed ledger technology that could constitute market abuse, referred to in Article 3 of Commission Delegated Regulation establishing technical standards adopted pursuant to Article 92(2) of Regulation (EU) 2023/1114).
Safekeeping of clients’ crypto-assets and funds
Clients’ crypto-assets and means of access to crypto-assets held by the crypto-asset service provider
The records enabling the crypto-asset service provider to safeguard the ownership rights of clients and to prevent the use of clients’ crypto-assets for their own account, as required by Article 70(1) of Regulation (EU) 2023/1114.
Clients’ funds held by a crypto-asset service provider
The records enabling the crypto-asset service provider to safeguard the ownership rights of clients and to prevent the use of clients’ funds for their own account as required by Article 70(2) of Regulation (EU) 2023/1114.
Any document, records, or evidence demonstrating that the crypto-asset service provider complies with its obligations under Article 70(3) of Regulation (EU) 2023/1114.
Complaints handling
Complaints
The records kept in accordance with Article 1(2)(f) of Commission Delegated Regulation (EU) 2025/294 ( 1 ) .
Conflicts of interest and personal transactions
Conflicts of interest
The information referred to in Article 6(5) of Commission Delegated Regulation establishing technical standards adopted pursuant to Article 72(5) of Regulation (EU) 2023/1114.
Personal transaction
The records of a personal transaction as referred to in Article 2(4) of Commission Delegated Regulation establishing technical standards adopted pursuant to Article 72(5) of Regulation (EU) 2023/1114, specifying the date and time of the transaction, the conditions, its volume, the counterparty and any authorisation or prohibition in connection with that transaction, in accordance with that Delegated Regulation.
Outsourcing
Outsourcing agreements
Records of the written agreements referred to in Article 73(3) of Regulation (EU) 2023/1114.
Outsourced services and activities
Records of any service or activity outsourced to a third party together, including:
(a)
the name, registered office, operating address, and regulatory status of the third party to which the service or activity, or any part of the service or activity, was outsourced;
(b)
the name, function, and contact details of the person in charge of the service or activity, or part of the service or activity, at the third party to which the service or activity, or any part of the service or activity that was outsourced;
(c)
the name and function of the person in charge of the service or activity, or part of the service or activity, at the crypto-asset service provider.
Custody and administration of crypto-assets on behalf of clients
Register of positions
Records of the registers of positions referred to in Article 75(2) and (4) of Regulation (EU) 2023/1114.
Statement of positions
Records of the statement of positions referred to in Article 75(5) of Regulation 2023/1114.
Communications with clients
Records of any communication with the client referred to in Article 75(5), second subparagraph, of Regulation 2023/1114, including the response received by the client or lack thereof.
Use of other crypto-asset service providers
Where clients’ crypto-assets or means of access to crypto-assets are in custody or controlled in accordance with Article 75(9) of Regulation (EU) 2023/1114:
(a)
records from the third party crypto-asset service provider evidencing the positions of the clients;
(b)
records of communications evidencing that the crypto-asset service provider complied with Article 75(9), second subparagraph, of Regulation (EU) 2023/1114.
Operation of a trading platform for crypto-assets
Operating rules
A copy of the operating rules referred to in Article 76(1) of Regulation (EU) 2023/1114, including deficiencies detected and the measures taken to remedy them.
Assessment of suitability of the crypto-asset
Records of the assessment referred to in Article 76(2) of Regulation (EU) 2023/1114 and its outcome.
In-built anonymisation function
Records of cases where crypto-assets have an in-built anonymisation function.
Consent of the client to matched principal trading
Records of clients’ consent to the crypto-asset service provider engaging in matched principal trading on the platform for crypto-assets that it operates, as referred to in Article 76(6) of Regulation (EU) 2023/1114.
Exchange of crypto-assets for funds or other crypto-assets
Price and limits
(1)
Records of the price of the crypto-assets or of the method for determining the price of the crypto-assets proposed to exchange for funds or other crypto-assets, and any applicable limits determined by the crypto-asset service provider on the amount to be exchanged, as referred to in Article 77(2) of Regulation (EU) 2023/1114.
(2)
Such records shall contain the following information in respect of each price, method for determining the price, and applicable limit applicable:
(a)
the identification of the crypto-asset;
(b)
whether the crypto-asset can be exchanged for funds or crypto-assets or both;
(c)
the price of the crypto-asset;
(d)
the amount of crypto-assets exchanged for another crypto-asset.
Placing of crypto-assets
Information to clients or prospective clients
Records of the communications referred to in Article 79(1) of Regulation (EU) 2023/1114 and of the consent received from the offeror or person seeking admission to trading or any third party acting on its behalf.
Placing operations
Records of any placing operation of the crypto-asset service provider, kept in accordance with the requirement for the crypto-asset service provider to have in place a centralised procedure to identify all its placing operations as provided in Commission Delegated Regulation establishing technical standards adopted pursuant to Article 72(5) of Regulation (EU) 2023/1114.
Advice and portfolio management
Information to clients
Records of any communication made in accordance with Article 81(2), (4) and (9) of Regulation (EU) 2023/1114.
Assessment of suitability
Records of all information collected from each client and assessed to conduct the suitability assessment referred to in Article 81(1) of Regulation (EU) 2023/1114, and all internal documents relating to such suitability assessment.
Records of clients who did not provide the information required by Article 81(8) of Regulation (EU) 2023/1114.
Investment advice
Records of the time and date on which advice on crypto-assets was rendered, records of the crypto-assets that were recommended, and the suitability report provided to the client in accordance with Article 81(13) of Regulation (EU) 2023/1114.
Periodic statement for portfolio management services
Records of any periodic statement provided to the client in accordance with Article 81(14) of Regulation (EU) 2023/1114.
Inducements
1.
Records of any minor non-monetary benefit received by the crypto-asset service provider in accordance with Article 81(3), second subparagraph, of Regulation (EU) 2023/1114. Such records shall contain the following information:
(a)
the nature of the minor non-monetary benefit and the date on which it was received;
(b)
the client and service or activity received;
(c)
how such minor non-monetary benefit complies with Article 81(3), second subparagraph, of Regulation (EU) 2023/1114.
2.
Records of any inducements received by the crypto-asset service provider in accordance with Article 81(6) of Regulation (EU) 2023/1114. Such records shall contain the following information:
(a)
the nature, amount and date the inducement was received;
(b)
the client and service or activity in relation to which it was received;
(c)
how such inducement complies with Article 81(6), first subparagraph, of Regulation (EU) 2023/1114;
(d)
any communication made in accordance with Article 81(6), second subparagraph, of Regulation (EU) 2023/1114.
Transfer services
Records to be kept by the crypto-asset service provider of the originator
Records of:
(a)
all instructions received;
(b)
all information listed in Article 14(1), (2) and (3) of Regulation (EU) 2023/1113;
(c)
the means of verification referred to in Article 14(6) of Regulation (EU) 2023/1113;
(d)
any suspension or rejection of any instruction to carry out the transfer of crypto-assets and the reason for such suspension or rejection.
Records to be kept by the crypto-asset service provider of the beneficiary
Records of:
(a)
all information listed in Article 14(1), (2) and (3), of Regulation (EU) 2023/1113;
(b)
the means of verification referred to in Article 16(3) of Regulation (EU) 2023/1113;
(c)
any return, suspension, or rejection of the transfer of crypto-assets and the reason for such return, suspension, or rejection;
(d)
any measures taken in accordance with Article 17(2) of Regulation (EU) 2023/1113, together with the identification of the crypto-asset service providers concerned.
Records to be kept by intermediary crypto-asset service providers
Records of:
(a)
all information listed in Article 14(1), (2) and (3), of Regulation (EU) 2023/1113;
(b)
any return, suspension, or rejection of the transfer of crypto-assets and the reason for such return, suspension, or rejection;
(c)
any measures taken in accordance with Article 21(2) of Regulation (EU) 2023/1113, together with the identification of the crypto-asset service providers concerned.
SECTION 2
Records of orders
Table 1
Legend for Table 2 of this Section and for Table 3 of Section 3
Symbol
Data type
Definition
{ALPHANUM-n}
Up to n alphanumerical characters
Free text field
{CFI_CODE}
6 characters
ISO 10962 CFI code
{COUNTRYCODE_2}
2 alphanumerical characters
2 letter country code, as defined by ISO 3166-1 alpha-2 country code
{CURRENCYCODE_3}
3 alphanumerical characters
3 letter currency code, as defined by ISO 4217 currency codes
{DATE_TIME_FORMAT}
ISO 8601 date and time format
Date and time in the following format:
YYYY-MM-DDThh:mm:ss.ddddddZ.
—
‘YYYY’ is the year;
—
‘MM’ is the month;
—
‘DD’ is the day;
—
‘T’ – means that the letter ‘T’ shall be used;
—
‘hh’ is the hour;
—
‘mm’ is the minute;
—
‘ss.dddddd’ is the second and its fraction of a second;
—
Z is UTC time.
Dates and times shall be recorded in UTC.
{DATEFORMAT}
ISO 8601 date format
Dates shall be formatted in the following format: YYYY-MM-DD.
{DECIMAL-n/m}
Decimal number of up to n digits in total of which up to m digits can be fraction digits
Numerical field for both positive and negative values.
—
decimal separator is ‘.’ (full stop);
—
negative numbers are prefixed with ‘-’ (minus); values are rounded and not truncated.
{DTI}
9 alphanumerical characters
Digital token identifier as defined in ISO 24165 standard
{DTI_SHORT_NAME}
n alphanumeric characters
DTI short name as registered according to the ISO 24165-2 data elements for registration of the DTI
{INTEGER-n}
Integer number of up to n digits in total
Numerical field for both positive and negative integer values.
{ISIN}
12 alphanumerical characters
ISIN code, as defined in ISO 6166
{LEI}
20 alphanumerical characters
Legal entity identifier as defined in ISO 17442
{MIC}
4 alphanumerical characters
Market identifier as defined in ISO 10383
{NATIONAL_ID}
35 alphanumerical characters
The identifier is derived in accordance with Article 9 and Annex II of Delegated Regulation (EU) 2017/590
Table 2
Details of orders to be kept
Field Number
Field Name
Field description
Details on the order data to be provided to the competent authority
Section A – Identification of the relevant parties
1
Client identification code
Code used to identify the client of the crypto-assets service provider which submitted the order.
Where the client is a legal entity, the LEI code of the client or the alternative identifiers referred to in Article 14(3) shall be used.
Where the client is not a legal entity, the {NATIONAL_ID} shall be used.
In case of pending allocations, the flag PNAL shall be used.
This field shall be ‘NOAP’ where the crypto-asset service provider has a direct interest to buy or sell.
{LEI}
{NATIONAL_ID}
{ALPHANUM-20}
{PNAL}
‘NOAP’
2
Investment decision within the CASP
Code used to identify the person or the algorithm within the crypto assets service provider who is taking the investment decision.
Where a natural person within the crypto-asset service provider takes the investment decision the person who is responsible or has primary responsibility for the investment decision shall be identified with the {NATIONAL_ID}.
Where an algorithm that automatically determines individual parameters of orders, including initiating the order or determining its timing, price or quantity, took the investment decision, the field shall be populated with a code assigned according to Article 8.
This field shall be left blank where the investment decision was not made by a person or algorithm within the crypto asset service provider.
{NATIONAL_ID} – Natural persons
{ALPHANUM-50} – Algorithms
3
Execution within firm
Code used to identify the person or algorithm within the crypto-asset service provider determining the conditions for the execution of the transaction resulting from the order.
Where a natural person determines the conditions for the execution of the transaction, the person shall be identified by {NATIONAL_ID}.
Where an algorithm that automatically determines individual parameters of orders, including initiating the order or determining its timing, price, or quantity, is responsible for the execution of the transaction, this field shall be populated with a code assigned by the crypto asset service provider, in accordance with Article 10.
Where more than one person or a combination of persons and algorithms are involved in the execution of the transaction, the crypto asset service provider shall determine the trader or algorithm primarily responsible and populate this field with the identity of that trader or algorithm.
{NATIONAL_ID} – Natural persons
{ALPHANUM-50} – Algorithms
Section B – Trading capacity and liquidity provision
4
Trading capacity
Indicates whether the crypto-asset service provider undertaking the transaction is carrying out matched principal trading or exchanges crypto-assets for funds.
Where the order submission does not result from the crypto-asset service provider carrying out matched principal trading or exchanging crypto-assets for funds or other crypto-assets, the field shall indicate that the transaction was carried out under any other capacity.
‘DEAL’ – Exchange crypto-assets for funds or other crypto-assets
‘MTCH’ – Matched principal
‘AOTC’ – Any other capacity
Section C – Date and time
5
Date and Time
The date and time for each event listed in Section G and J.
{DATE_TIME_FORMAT}
Section D – Validity period and order restrictions
6
Validity period
Good-For-Day: the order expires at the end of the trading day on which it was entered in the order book.
Good-Till-Cancelled: the order will remain active in the order book and be executable until it is actually cancelled.
Good-Till-Time: the order expires at the latest at a pre-determined time within the current trading session.
Good-Till-Date: the order expires at the end of a specified date.
Good-Till-Specified Date and Time: the order expires at a specified date and time.
Good After Time: the order is only active after a pre-determined time within the current trading session.
Good After Date: the order is only active from the beginning of a pre-determined date.
Good After Specified Date and Time: the order is only active from a pre-determined time on a pre-determined date.
Immediate-Or-Cancel: an order which is executed upon its entering into the order book (for the quantity that can be executed) and which does not remain in the order book for the remaining quantity (if any) that has not been executed.
Fill-Or-Kill: an order which is executed upon its entering into the order book provided that it can be fully filled: in the event the order can only be partially executed, then it is automatically rejected and cannot therefore be executed.
Other: any additional indications that are unique for specific business models, trading platforms or systems.
‘DAVY’ – Good-For-Day
‘GTCV’ – Good-Till-Cancelled
‘GTTV’ – Good-Till-Time
‘GTDV’ – Good-Till-Date
‘GTSV’ – Good-Till-Specified Date and Time
‘GATV’ – Good After Time
‘GADV’ – Good After Date
‘GASV’ – Good After Specified Date and Time
‘IOCV’ – Immediate-Or-Cancel
‘FOKV’ – Fill-Or-Kill
or
{ALPHANUM-4} character’ not already in use for the trading venue’s own classification.
7
Order restriction
Good For Closing Price Crossing Session: where an order qualifies for the closing price crossing session.
Valid For Auction: the order is only active and can only be executed at auction phases (which can be pre-defined by the CASP client who submitted the order, e.g. opening and/closing auctions and/or intraday auction).
Valid For Continuous Trading only: the order is only active during continuous trading.
Other: any additional indications that are unique for specific business models, trading platforms or systems.
‘SESR’ – Good For Closing Price Crossing Session
‘VFAR’ – Valid For Auction
‘VFCR’ – Valid For Continuous Trading only
{ALPHANUM-4} character’ not already in use for the trading venue’s own classification.
This field shall be populated with multiple flags separated by a comma where more than one flag is applicable.
8
Validity period and time
This field refers to the time stamp reflecting the time on which the order becomes active or it is ultimately removed from the order book:
Good for day: the date of entry with the timestamp immediately prior to midnight;
Good till time: the date of entry and the time to that specified in the order;
Good till date: will be the specified date of expiry with the timestamp immediately prior to midnight;
Good till specified date and time: the specified date and time of expiry;
Good after time: the date of entry and the specified time at which the order becomes active;
Good after date: the specified date with the timestamp immediately after midnight;
Good after specified date and time: the specified date and time at which the order becomes active;
Good till Cancel: the ultimate date and time the order is automatically removed by market operations;
Other: timestamp for any additional validity type.
{DATE_TIME_FORMAT}
Section E – Identification of the order
9
Segment MIC code
Identification of the trading platform for crypto-asset where the order was submitted.
Where the trading platform for crypto-asset uses segment MICs, the segment MIC shall be used.
Where the trading platform for crypto-asset does not use segment MICs, the operating MIC shall be used.
This field shall only be populated for orders to be executed on a trading platform for crypto-assets.
{MIC}
10
Crypto-asset identification code
Unique and unambiguous identifier of the crypto-asset.
{DTI}
{ALPHANUM-20}
11
Crypto-asset classification
Taxonomy used to classify the crypto-asset
or
A complete and accurate CFI code shall be provided where available.
ART
EMT
OT
{CFI_CODE}
12
Order identification code
An alphanumerical code assigned by the operator of the trading platform for crypto-assets to the individual order.
{ALPHANUM-50}
Section F – Events affecting the order
13
New order, order cancellation
New order: submission of a new order to the CASP operating the trading platform for crypto-assets.
Cancelled at the initiative of the client of the CASP: where the client decides upon its own initiative to cancel the order it has previously entered.
‘NEWO’ – New order
‘CAME’ – Cancelled at the initiative of the client of the CASP
Section G – Type of order
14
Order type
Identifies the type of order submitted to the trading platform for crypto-asset as per the trading platform for crypto-asset specifications.
{ALPHANUM-50}
15
Order type classification
Classification of the order according to two generic order types.
LIMIT order: where the order is tradable;
STOP order: where the order becomes tradable only upon the realisation of a pre-determined price event.
The letters ‘LMTO’ for limit or the letters ‘STOP’ for stop
Section H – Prices
16
Limit price
The maximum price at which a buy order can trade or the minimum price at which a sell order can trade.
The spread price for a strategy order, which can be negative or positive.
This field shall be ‘NOAP’ for orders that do not have a limit price or for unpriced orders.
Where the price is reported in monetary terms, the price shall be provided in the major currency unit.
Where the crypto-asset is traded based on a currency pair, the price shall express the quantity of the quote currency for one unit of the base currency.
Where the price is expressed in sub-components of that crypto-asset, the price shall nonetheless be recorded in decimal notation of the price expressed in units of that crypto-asset.
{DECIMAL-18/13} in case the price is expressed as monetary value.
{DECIMAL-11/10} in case the price is expressed as a percentage or yield.
{DECIMAL-18/17} in case the price is expressed as basis points
‘NOAP’
17
Additional limit Price
Any other limit price which may apply to the order. This field shall be left ‘NOAP’ where there is no limit price.
Where the price is reported in monetary terms, the price shall be provided in the major currency unit.
Where the crypto-asset is traded based on a currency pair, the price shall express the quantity of the quote currency for one unit of the base currency.
Where the price is expressed in sub-components of that crypto-asset, the price shall nonetheless be recorded in decimal notation of the price expressed in units of that crypto-asset.
{DECIMAL-18/13} where the price is expressed as a monetary value.
{DECIMAL-11/10} where the price is expressed as a percentage or yield.
{DECIMAL-18/17} in case the price is expressed as basis points
‘NOAP’
18
Stop price
The price that must be reached for the order to become active.
For stop orders triggered by events independent of the price of the crypto-asset, this field shall be populated with a stop price equal to zero.
This field shall be ‘NOAP’ where not relevant.
Where the price is reported in monetary terms, the shall be provided in the major currency unit.
Where the crypto-asset is traded based on a currency pair, the price shall express the quantity of the quote currency for one unit of the base currency.
Where the price is expressed in sub-components of that crypto-asset, the price shall be nonetheless recorded in decimal notation of the price expressed in units of that crypto-asset.
{DECIMAL-18/13} where the price is expressed as a monetary value.
{DECIMAL-11/10} where the price is expressed as a percentage or yield.
{DECIMAL-18/17} in case the price is expressed as basis points
‘NOAP’
19
Pegged limit price
The maximum price at which a pegged order to buy can trade or the minimum price at which a pegged order to sell can trade.
This field shall be ‘NOAP’ if not relevant.
Where the price is reported in monetary terms, the price shall be provided in the major currency unit.
Where the crypto-asset is traded based on a currency pair, the price shall express the quantity of the quote currency for one unit of the base currency.
Where the price is expressed in sub-components of that crypto-asset, the price shall be nonetheless recorded in decimal notation of the price expressed in units of that crypto-asset.
{DECIMAL-18/13} where the price is expressed as a monetary value.
{DECIMAL-11/10} where the price is expressed as a percentage or yield.
{DECIMAL-18/17} in case the price is expressed as basis points
‘NOAP’
20
Transaction price
Traded price of the transaction excluding, where applicable, commission, other fees and accrued interest.
A price that is recorded in monetary terms shall be provided in the major currency unit.
Where a price is not applicable, the field shall be populated with the value ‘NOAP’.
Where the crypto-asset is traded based on a currency pair, the price shall express the quantity of the quote currency for one unit of the base currency.
{DECIMAL-18/13} where the price is expressed as a monetary value.
‘NOAP’
21
Price currency
Currency in which the trading price for the crypto-asset related to the order is expressed (applicable where the price is expressed as monetary value).
Where the crypto-asset is traded in electronic money/e-money token, the Digital Token Identifier or the alternative identifier referred to in Article 15 shall be used.
Where the price of the crypto-asset is expressed in monetary terms and it is expressed in a currency pair, the currency pair in which the price for the crypto-asset related to the order is expressed shall be reported. The first currency code shall be that of the base currency and the second currency code shall be that of the quote currency. The quote currency determines the price of one unit of the base currency. The ISO currency code and the DTI short name as registered according to the ISO 24165-2 data elements for registration of the DTI or alternative identifier shall be used to represent the fiat currency and the crypto-asset, respectively, in the currency pair.
{CURRENCYCODE_3}
{DTI}
{ALPHANUM-20}
{CURRENCYCODE_3} should be used for fiat currencies in a currency pair
{DTI_SHORT_NAME} should be used for crypto assets in a currency pair
‘NOAP’
22
Price notation
Indicates whether the price is expressed in monetary value, in percentage, in yield, or in basis points.
‘MONE’ – Monetary value
‘PERC’ – Percentage
‘YIEL’ – Yield
‘BAPO’ – Basis points
Section I – Order instructions
23
Buy-sell indicator
To show whether the order is to buy or sell.
‘BUYI’ – buy
‘SELL’ – sell
24
Order status
To identify orders that are active/inactive/suspended:
Active – non-quote orders that are tradable.
Inactive – non-quote orders that are not tradable.
‘ACTI’ – active
or
‘INAC’ – inactive
25
Quantity notation
Indicates whether the quantity reported is expressed in number of units, as a nominal value, or as a monetary value, or crypto-assets units.
‘UNIT’ – Number of units
‘NOML’ – Nominal value
‘MONE’ – Monetary value
‘CRYP’ – Crypto-asset
26
Quantity currency
Currency in which the quantity is expressed. The currency shall refer to the crypto-asset units, even where the transaction is denominated in sub-components of that crypto-asset.
This field only needs to be populated where the quantity is expressed as a nominal or monetary value or crypto-assets units.
{CURRENCYCODE_3}
{DTI}
{ALPHANUM-20}
27
Initial quantity
The number of units of the crypto-asset in the order. Where the order pertains to a fraction of a crypto-asset, indicate the quantity in decimal notation of the unit.
The nominal or monetary value of the crypto-asset.
{DECIMAL-18/17} in case the quantity is expressed as number of units
{DECIMAL-18/5} in case the quantity is expressed as monetary or nominal value
28
Remaining quantity
The total quantity that remains in the order book after a partial execution or in the case of any other event affecting the order.
On a partial fill order event, this shall be the total remaining volume after that partial execution. On an order entry, this shall equal the initial quantity.
{DECIMAL-18/17} in case the quantity is expressed as a number of units
{DECIMAL-18/5} where the quantity is expressed as monetary or nominal value
29
Traded quantity
Where there is a partial or full execution, this field shall be populated with the executed quantity.
{DECIMAL-18/17} in case the quantity is expressed as a number of units
{DECIMAL-18/5} where the quantity is expressed as monetary or nominal value
30
Minimum Acceptable Quantity (MAQ)
The minimum acceptable quantity for an order to be filled, which can consist of multiple partial executions and is normally only for non-persistent order types.
This field shall be ‘NOAP’ where not relevant.
{DECIMAL-18/17} in case the quantity is expressed as a number of units
{DECIMAL-18/5} where the quantity is expressed as monetary or nominal value
‘NOAP’
31
Minimum executable size (MES)
The minimum execution size of any individual potential execution.
This field shall be left blank where not relevant.
{DECIMAL-18/17} in case the quantity is expressed as a number of units
{DECIMAL-18/5} where the quantity is expressed as monetary or nominal value
32
MES first execution only
Specifies whether the MES is relevant only for the first execution.
This field can be left blank where Field 29 is left blank.
‘true’
‘false’
33
Passive only indicator
Indicates whether the order is submitted to the trading platform for crypto-asset with a characteristic/flag, such that the order shall not immediately be executed against any contra visible orders.
‘true’
‘false’
34
Passive or aggressive indicator
On partial fill and fill order events, indicates whether the order was already resting on the order book and providing liquidity (passive) or the order initiated the trade and thus took liquidity (aggressive).
This field shall be left blank where not relevant
‘PASV’ – passive or
‘AGRE’ – aggressive.
35
Self-Execution Prevention
Indicates whether the order has been entered with self-execution prevention criteria, so that it would not execute with an order on the opposite side of the book entered by the same member or participant.
‘true’
‘false’
36
Trading platform for crypto-asset transaction identification code
For orders executed on trading platforms for crypto-assets, alphanumerical code assigned by the trading platform for crypto-assets to the transaction pursuant to Article 14 of Commission Delegated Regulation (EU) 2025/416 ( 2 ) .
The code shall be unique, consistent, and persistent per ISO10383 segment MIC and per trading day.
The components of the transaction identification code shall not disclose the identity of the counterparties to the transaction for which the code is maintained.
For transactions executed by means of transmission on behalf of clients to an entity providing crypto-asset services outside of the Union, this information shall be recorded where retrievable.
{ALPHANUM-52}
Section J – Indicative auction price and volume
37
Indicative auction price
The price at which each auction is due to uncross in respect to the crypto-asset for which one or more orders have been placed.
{DECIMAL-18/5} in case the price is expressed as monetary or nominal value.
Where price reported in monetary terms, it shall be provided in the major currency unit.
{DECIMAL-11/10} in case the price is expressed as a percentage or yield
38
Indicative auction volume
The volume (number of units of crypto-asset) that can be executed at the indicative auction price in Field 50 where the auction ended at that precise moment of time.
{DECIMAL-18/17} in case the quantity is expressed as number of units
{DECIMAL-18/5} in case the quantity is expressed as monetary or nominal value
Section K – Order transmission
39
Transmitting crypto-asset service provider
In case of transmission of an order under Article 11, the LEI code of the transmitting crypto-asset service provider.
{LEI}
40
Transmission of an order indicator
‘true’ shall be populated by the transmitting firm within the transmitting firm’s report where the conditions for transmission specified in Article 11 were not satisfied
‘false’ – in all other circumstances
‘true’
‘false’
Section L – Country of residence of the client
41
Identification of the country of residence
Shall be populated where a client is a resident of a country other than the one of its nationality, as described in Article 9(5).
{COUNTRYCODE_2}
‘NOAP’
SECTION 3
Records of transactions
For the legend, please refer to Section 2, Table 1.
Table 3
Details of transactions to be kept
Field no
Field
Content to be recorded
Details on transaction data to be provided to the competent authority
1
Transaction status
Indication as to whether the transaction is new or a cancellation.
‘NEWT’ – New
‘CANC’ – Cancellation
2
Transaction Record Number
Identification number that is unique to the executing firm for each record.
{ALPHANUM-52}
3
Trading platform for crypto-asset transaction identification code
This is a number generated by the trading platform for crypto-assets and disseminated to both the buying and the selling parties in accordance with Article 14 of Delegated Regulation (EU) 2025/416 supplementing Regulation (EU) 2023/1114. Where relevant, the transaction hash or other identification alphanumerical string which is automatically generated on the DLT that enables to uniquely identify a specific transaction.
{ALPHANUM-52}
4
Executing entity identification code
Code used to identify the entity executing the transaction.
{LEI}
{ALPHANUM-20}
5
CASP covered by Regulation (EU) 2023/1114.
Indicates whether the entity identified in Field 4 is a crypto-asset service provider to which Regulation (EU) 2023/1114 applies.
‘true’ – yes
‘false’ – no
6
Buyer identification code
Code used to identify the acquirer of the crypto-asset.
Where the buyer is a legal entity, the LEI code of the acquirer or the alternative identifiers referred to in Article 14(3) shall be used.
Where the buyer is a natural person, the identifier specified in Article 9.
Where the order was transmitted for execution on behalf of clients to a firm performing crypto-asset services outside of the Union, the MIC code of the platform or the LEI or equivalent identifiers referred to in Article 14 of the firm shall be used.
Where the crypto-asset service provider executes the transaction on a trading platform located in a third country, the LEI of the buyer, the alternative identifier referred to in Article 14(3) or the National ID shall be recorded.
‘INTC’ shall be used to designate an aggregate client account within the crypto-asset service provider to report a transfer into or out of that account with an associated allocation to the individual client(s) out of or into that account respectively.
{LEI}
{ALPHANUM-20}
{MIC}
{NATIONAL_ID}
‘INTC’
7
Country of the branch of the crypto-asset service provider for the buyer
Where the buyer is a client, this field shall identify the country of the branch that received the order from the client or made an investment decision for a client in accordance with a discretionary mandate given to it by the client as required by Article 16.
Where this activity was not conducted by a branch, this field should be populated with the country code of the home Member State of the crypto-asset service provider or the country code of the Member State where the crypto-asset service provider has established its registered office.
{COUNTRYCODE_2}
8
Buyer – first name(s)
Full first name(s) of the buyer. In case of more than one first name, all names shall be included in this field, separated by a comma.
{ALPHANUM-140}
9
Buyer – surname(s)
Full surname(s) of the buyer. In case of more than one surname, all surnames shall be included in this field, separated by a comma.
{ALPHANUM-140}
10
Buyer – date of birth
Date of birth of the buyer.
{DATEFORMAT}
11
Buyer decision maker code
Code used to identify the person who makes the decision to acquire the crypto-asset.
Where the decision is made by a crypto-asset service provider, this field shall be populated with the identity of the crypto-asset service provider rather than of the individual making the investment decision.
Where the decision-maker is a legal entity, the LEI code or the alternative identifiers referred to in Article 14(3) of the decision-maker shall be used.
Where the decision-maker is not a legal entity, the identifier specified in Article 9 shall be used.
{LEI}
{ALPHANUM-20}
{NATIONAL_ID}
12
Buy decision maker – First Name(s)
Full first name(s) of the decision-maker for the buyer. In case of more than one first name, all names shall be included in this field, separated by a comma.
{ALPHANUM-140}
13
Buy decision maker – Surname(s)
Full surname(s) of the decision-maker for the buyer. In case of more than one surname, all surnames shall be included in this field, separated by a comma.
{ALPHANUM-140}
14
Buy decision maker – Date of birth
Date of birth of the decision-maker for the buyer.
{DATEFORMAT}
15
Seller identification code
Code used to identify the disposer of the crypto-asset.
Where the seller is a legal entity, the LEI code of the disposer or the alternative identifiers referred to in Article 14(3) shall be used.
Where the seller is not a legal entity, the identifier specified in Article 9 shall be used.
Where the order was transmitted for execution on behalf of the client to a crypto-asset service provider providing services outside of the Union, the MIC code of the platform or the LEI of that crypto-asset service provider shall be used.
Where the crypto-asset service provider executes the transaction on a trading platform located in a third country, the LEI, the alternative identifier referred to in Article 14(3) or the National ID of the seller shall be provided.
‘INTC’ shall be used to designate an aggregate client account within the CASP to record a transfer into or out of that account with an associated allocation to the individual client(s) out of or into that account respectively.
{LEI}
{ALPHANUM-20}
{MIC}
{NATIONAL_ID}
‘INTC’
16
Country of the branch for the seller
Where the seller is a client, this field shall identify the country of the branch that received the order from the client or made an investment decision for a client in accordance with a discretionary mandate given to it by the client as required by Article 16.
Where this activity was not conducted by a branch, this field shall be populated with the country code of the home Member State of the crypto-asset service provider or the country code of the country where the crypto-asset service provider has established its head office or registered office (in the case of third-country firms).
{COUNTRYCODE_2}
17
Seller – first name(s)
Full first name(s) of the seller. In case of more than one first name, all names shall be included in this field, separated by a comma.
{ALPHANUM-140}
18
Seller – surname(s)
Full surname(s) of the seller. In case of more than one surname, all surnames shall be included in this field, separated by a comma.
{ALPHANUM-140}
19
Seller – date of birth
Date of birth of the seller.
{DATEFORMAT}
20
Seller decision maker code
Code used to identify the person who makes the decision to sell the crypto-asset.
Where the decision is made by a crypto-asset service provider, this field shall be populated with the identity of the CASP rather than of the individual making the investment decision.
Where the decision maker is a legal entity, the LEI code or the alternative identifier referred to in Article 14(3) of the decision maker shall be used. Where the decision maker is a non-legal entity, the identifier specified in Article 9 shall be used.
{LEI}
{ALPHANUM-20}
{NATIONAL_ID}
21
Sell decision maker – First Name(s)
Full first name(s) of the decision maker for the seller. In case of more than one first name, all names shall be included in this field, separated by a comma.
{ALPHANUM-140}
22
Sell decision maker – Surname(s)
Full surname(s) of the decision maker for the seller. In case of more than one surname, all surnames shall be included in this field, separated by a comma.
{ALPHANUM-140}
23
Sell decision maker – Date of birth
Date of birth of the decision maker for the seller.
{DATEFORMAT}
24
Transmission of order indicator
‘true’ shall be populated by the transmitting firm within the transmitting firm’s report where the conditions for transmission specified in Article 11 were not satisfied
‘false’ – in all other circumstances
‘true’
‘false’
25
Transmitting firm identification code for the buyer
Code used to identify the firm transmitting the order.
This shall be populated by the receiving firm within the receiving firm’s report with the identification code provided by the transmitting firm.
{LEI}
{ALPHANUM-20}
26
Transmitting firm identification code for the seller
Code used to identify the firm transmitting the order.
This shall be populated by the receiving firm within the receiving firm’s report with the identification code provided by the transmitting firm
{LEI}
{ALPHANUM-20}
27
Trading date time
Date and time when the transaction was executed.
For transactions not executed on a trading venue, the date and time shall be when the parties agree to the content of the following fields: quantity, price, currencies in Fields 31, 34 and 44, instrument identification code, instrument classification and underlying instrument code, where applicable. For transactions not executed on a trading venue, the time recorded shall be at least to the nearest second.
Where the transaction results from an order transmitted by the executing firm on behalf of a client to a third party where the conditions for transmission set out in Article 11 were not satisfied, this shall be the date and time of the transaction rather than the time of the order transmission.
{DATE_TIME_FORMAT}
28
Trading capacity
Indicates whether the CASP undertaking the transaction is carrying out matched principal trading, or exchange of crypto-assets for funds.
Where the transaction does not result from the executing firm carrying out matched principal trading or through exchange of crypto-assets for funds, the field shall indicate that the transaction was carried out under any other capacity.
‘DEAL’ – Exchange of crypto-assets for funds or other crypto-assets
‘MTCH’ – Matched principal
‘AOTC’ – Any other capacity
29
Quantity
The number of units of the crypto-assets or the monetary value of the crypto asset.
Where the price is expressed in sub-components of that crypto-asset, it shall be nonetheless recorded in decimal notation of the price expressed in units of that crypto-asset.
The information reported in this field shall be consistent with the values provided in Fields 31 and 32.
{DECIMAL-18/17} in case the quantity is expressed as number of units
{DECIMAL-18/5} in case the quantity is expressed as monetary or nominal value
30
Quantity currency
Currency in which the quantity is expressed.
Only applicable where the quantity is expressed as nominal or monetary value.
The quantity shall refer to the crypto-asset units, even where the transaction is denominated in sub-components of that crypto-asset.
Where the crypto-asset is traded in electronic money/e-money token, the Digital Token Identifier code or the alternative identifier referred to in Article 15 shall be used.
{CURRENCYCODE_3}
{DTI}
{ALPHANUM-20}
31
Price
Traded price of the transaction excluding, where applicable, commission, any other fee and accrued interest.
Where the crypto-asset is traded based on a currency pair, the price shall express the quantity of the quote currency for one unit of the base currency.
Where the price is expressed in sub-components of that crypto-asset, the price shall be nonetheless recorded in decimal notation of the price expressed in units of that crypto-asset.
Where the price is recorded in monetary terms, the price shall be provided in the major currency unit.
Where price is not applicable, the value shall be ‘NOAP’.
The information recorded in this field shall be consistent with the values provided in Field 30.
{DECIMAL-18/13} in case the price is expressed as monetary value
{DECIMAL-11/10} in case the price is expressed as percentage or yield
{DECIMAL-18/17} in case the price is expressed as basis points
‘NOAP’ in case the price is not applicable
32
Price Currency
Currency in which the price is expressed (applicable where the price is expressed as a monetary value).
Where the price of the crypto-asset is expressed in monetary terms and is expressed in a currency pair, the currency pair in which the price for the crypto-asset related to the order is expressed shall be reported. The first currency code shall be that of the base currency and the second currency code shall be that of the quote currency. The quote currency determines the price of one unit of the base currency. The ISO currency code and the DTI short name as registered in accordance with the ISO 24165-2 data elements for registration of the DTI or the alternative identifier referred to in Article 15 shall be used to represent the fiat currency and the crypto asset respectively in the currency pair.
{CURRENCYCODE_3}
{DTI}
{ALPHANUM-20}
{CURRENCYCODE_3} should be used for fiat currencies in a currency pair
{DTI_SHORT_NAME} should be used for crypto assets in a currency pair
‘NOAP’
33
Trading platform for crypto-asset
Identification of the trading platform for crypto-asset where the transaction was executed.
Use the ISO 10383 segment MIC for transactions executed on a trading platform for crypto-assets. Where the segment MIC does not exist, use the operating MIC.
Use MIC code ‘XOFF’ for crypto-assets admitted to trading, or traded on a trading platform for crypto-assets or for which a request for admission was made, where the transaction on that crypto-asset was not executed on a trading platform for crypto-assets.
Use MIC code ‘XXXX’ for crypto-assets that are not admitted to trading or traded on a trading platform for crypto-assets, or for which no request for admission has been made.
{MIC}
34
Country of the branch membership
Code used to identify the country of a branch of the crypto-asset service provider whose trading platform for crypto-asset membership was used to execute the transaction.
Where a branch’s trading platform for crypto-asset membership was not used, this field shall be populated with the country code of the home Member State of the crypto-asset service provider or the country code of the country where the firm has established its head office or registered office (in the case of third-country firms).
This field shall only be populated for the market side of a transaction executed on a trading platform for crypto-assets.
{COUNTRYCODE_2}
35
Up-front payment
Monetary value of any up-front payment received or paid by the seller.
Where the seller receives the up-front payment, the value populated shall be positive. Where the seller pays the up-front payment, the value populated shall be negative.
{DECIMAL-18/5}
36
Up-front payment currency
Currency of the up-front payment.
{CURRENCYCODE_3}
{DTI}
{ALPHANUM-20}
37
Complex trade component id
Identifier, internal to the crypto-asset service provider, to identify all the transaction records related to the same execution of a combination of crypto-assets. The code must be unique at the level of the firm for the group of transaction records related to the execution.
{ALPHANUM-35}
38
Crypto-asset identification code
Code used to identify the crypto-asset.
This field applies to crypto-assets for which a request for admission to trading has been made, that are admitted to trading or traded on a trading platform for crypto-assets.
{DTI}
{ALPHANUM-20}
39
Crypto-asset full name
Full name of the crypto-asset.
{ALPHANUM-350}
40
Crypto-asset classification
Taxonomy used to classify the crypto-asset.
or
A complete and accurate CFI code shall be provided where available.
ART
EMT
OT
{CFI_CODE}
41
Investment decision within the crypto-asset service provider
Code used to identify the person or algorithm within the crypto-asset service provider taking the investment decision. The code shall remain the same for each set of code or trading strategy that constitutes the algorithm and shall be used consistently when referring to the algorithm or version of the algorithm once assigned to it.
For natural persons, the identifier specified in Article 9 shall be used
where the investment decision was made by an algorithm that automatically determines individual parameters of orders, including the decision to initiate the order or determining its timing, price or quantity, the field shall be populated as set out in Article 8.
This field only applies for investment decision within the firm.
Where the transaction is for a transmitted order that has met the conditions for transmission set out in Article 11, this field shall be populated by the receiving firm within the receiving firm’s record using the information received from the transmitting firm.
{NATIONAL_ID} – Natural persons
{ALPHANUM-50} – Algorithms
42
Country of the branch responsible for the person making the investment decision
Code used to identify the country of the branch of the crypto-asset service provider for the person taking the investment decision, as set out in Article 16.
Where the person taking the investment decision was not supervised by a branch, this field shall be populated with the country code of the home Member State of the crypto-asset service provider or the country code of the Member State where the crypto-asset service provider has established its registered office.
Where the transaction is for a transmitted order that has met the conditions for transmission set out in Article 11, this field shall be populated by the receiving firm within the receiving firm’s record using the information received from the transmitting firm.
This field is not applicable where the investment decision was made by an algorithm that automatically determines individual parameters of orders, including as whether to initiate the order or determining its timing, price, or quantity.
{COUNTRYCODE_2}
43
Execution within firm
Code used to identify the person or algorithm that automatically determines individual parameters within the crypto-asset service provider for the execution of orders, including the decision to initiate the order or determining its timing, price, or quantity.
For natural persons, the identifier specified in Article 9 shall be used. Where the execution was made by an algorithm that automatically determines individual parameters of orders, including the decision to initiate the order or determining its timing, price, or quantity, the field shall be populated as set out in Article 8.
{NATIONAL_ID} – Natural persons
{ALPHANUM-50} – Algorithms
CLIENT – Client
44
Country of the branch supervising the person determining the conditions for execution
Code used to identify the country of the branch of the crypto-asset service provider for the person determining the execution of the transaction, as set out in Article 16.
Where the person responsible was not supervised by a branch, this field shall be populated with the country code of the home Member State of the crypto-asset service provider, or the country code of the country where the crypto-asset service provider has established its registered office.
This field is not applicable where the execution was made by an algorithm that automatically determines individual parameters of orders, including the decision to initiate the order, or determining its timing, price or quantity.
{COUNTRYCODE_2}
45
Short selling indicator
Designation to identify any sale of a crypto-asset which the seller does not own at the time of entering into the agreement to sell, including such a sale where at the time of entering into the agreement to sell the seller has borrowed or agreed to borrow the share or debt instrument for delivery at settlement.
‘true’
‘false’
SECTION 4
On-chain data
Table 4
Details of on-chain data to be kept
Field no
Field
Content to be recorded
Details to be provided to the competent authority
1
Transaction hash
Identifier enabling the unique identification of a specific transaction occurring on the network.
{ALPHANUM-140}
2
Wallet addresses
Code uniquely identifying the wallet, belonging to the buyer/seller, to which the crypto-asset is transferred.
{ALPHANUM-140}
3
Smart Contract Addresses
Code uniquely identifying the smart contract address.
{ALPHANUM-140}
4
Timestamp
Timestamp of the creation of the block.
{DATE_TIME_FORMAT}
5
Quantity/ Current Total Supply
Ratio between the transferred quantity and the current floating amount of the asset.
6
Token ID
Digital Token Identifier
{DTI}
7
Network fee
Fees which are requested to cover the costs for the creation of a new block.
8
Fee limit
This is the maximum amount of ‘network fees’ that an on-chain user is willing to pay for the executions of a specific transaction.
9
Data size
This field is connected to Field 8. On-chain transaction can contain ‘attachments’ in a specific data field that affect the ‘network fees’ required to process the transaction.
10
To
The unique identifiers for buyer and seller are usually generated by the DLT protocol on the basis of the buyer/seller wallet addresses.
{ALPHANUM-140}
11
From
The unique identifier for seller usually generated by the DLT protocol on the basis of the seller wallet addresses.
{ALPHANUM-140}
12
Currency
Currency code
{CURRENCYCODE_3}
{DTI}
13
Transaction Record Number
Identification number reported in Field 2 of Section 3 that is unique to the executing firm for each record to ensure that a link can be made between the on-chain report and the off-chain one.
{ALPHANUM-140}
( 1 ) Commission Delegated Regulation (EU) 2025/294 of 1 October 2024 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the requirements, templates and procedures for the handling of complaints by the crypto-asset service providers ( OJ L, 2025/294, 13.2.2025, ELI: http://data.europa.eu/eli/reg_del/2025/294/oj ).
( 2 ) Commission Delegated Regulation (EU) 2025/416 of 29 November 2024 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the content and format of order book records for crypto-asset service providers operating a trading platform for crypto-assets ( OJ L, 2025/416, 14.3.2025, ELI: http://data.europa.eu/eli/reg_del/2025/416/oj ).
