Commission Delegated Regulation (EU) 2025/1140 of 27 February 2025 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying records to be kept of all crypto-asset services, activities, orders and transactions undertaken

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	2025/1140	10.6.2025

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 [^ntr1-L_202501140EN.000101-E0001], and in particular Article 68(10), third subparagraph, thereof,

Whereas:

• (1) The records crypto-asset service providers are required to keep should be adapted to their type of business and the range of crypto-asset services, activities, orders, and transactions they undertake.

• (2) Crypto-asset service providers should be free to determine the manner in which they keep records of relevant data relating to all orders and transactions in crypto-assets. However, consistent and comparable records on services, activities, orders and transactions are essential for competent authorities to fulfil their supervisory tasks and to take enforcement measures. In particular, competent authorities should be able to perform the same analysis on all record datasets, regardless of which crypto-asset service provider produced the record. Crypto-asset service providers should therefore provide consistent details of the records on services, activities, orders and transactions by using uniform standards where a competent authority requests such information pursuant to Article 94 of Regulation (EU) 2023/1114. For the same reasons, it is necessary to specify that the records should be maintained in a medium allowing effective supervision by competent authorities.

• (3) In order to leverage from the knowledge and application of Regulation (EU) No 600/2014 of the European Parliament and of the Council [^ntr2-L_202501140EN.000101-E0002], to ensure consistent reporting standards across financial sector and to minimise the reporting burden for crypto-asset service providers, data should be recorded in accordance with the standards referred to in that Regulation. In order to ensure consistency between this Delegated Regulation and Commission Delegated Regulation (EU) 2025/416 [^ntr3-L_202501140EN.000101-E0003], the same standards should apply when the records are also required in accordance with that Delegated Regulation.

• (4) To ensure that competent authorities can properly supervise services provided by crypto-asset service providers, it is necessary that crypto-asset service providers keep a record of the policy arrangements and procedures put in place to comply with Regulation (EU) 2023/1114.

• (5) Market abuse, including market manipulation, may be carried out through various means, including through algorithmic trading. Therefore, in order to ensure effective market surveillance, where investment decisions are made by a person other than the client or by a computer algorithm, that person or algorithm should be identified in the order and transaction records using unique, robust and consistent identifiers. For the same reasons, it is important to lay down that where more than one person in a crypto-asset service provider makes the investment decision, the person with primary responsibility for the decision is to be identified in the record.

• (6) To ensure unique, consistent and robust identification of natural persons in order and transaction records, those natural persons should be identified by a concatenation of the country of their nationality followed by identifiers assigned by the country of nationality of those persons. Where those identifiers are not available, natural persons should be identified by identifiers created from a concatenation of their date of birth and name.

• (7) It is necessary that certain personal data are recorded by crypto-asset service providers to identify their clients or other natural persons relevant for orders or transactions in crypto-assets, as these data are fundamental to ensure efficient supervision by competent authorities, including in the area of market abuse. For all instances of identifying natural persons, this is to be done by following the level of prioritization of the different identifiers detailed in Annex II of Commission Delegated Regulation (EU) 2017/590 [^ntr4-L_202501140EN.000101-E0004].

• (8) It is possible that natural persons who need to be identified for recordkeeping purposes are residents of a country other than the one of their nationality. The country of residence of natural persons can affect several obligations under Regulation (EU) 2023/1114, and is therefore an important data element for ensuring effective supervision by competent authorities. Whenever their country of residence is different from that person’s nationality, this should be indicated by providing the country code of the country of residence of that natural person.

• (9) To facilitate market surveillance and to allow for the comparability of the records to be kept by crypto-asset service providers, clients of crypto-asset service providers that are legal entities should be identified with a code that is compatible with the internationally established criteria for the development of robust identification systems for the monitoring of financial markets. Such code should be unique, neutral, reliable, open source, scalable, accessible, available for free or at a reasonable cost, and subject to an appropriate governance framework. These criteria were also used by the competent authorities for assessing the most appropriate identifiers in previous technical standards on supervisory data [^ntr5-L_202501140EN.000101-E0005] [^ntr6-L_202501140EN.000101-E0006], to ensure consistency and comparability of data on financial transactions, and therefore should also be applicable in the context of this Regulation.

• (10) LEI is a widely recognised, financially and operationally accessible international identifier used in financial markets. LEI is an international identifier that ensures access to the underlying data at all times, allowing for comparability and aggregation of information at Union level, improving the quality and timeliness of aggregated data and reducing the reporting burden for crypto-asset service providers. Therefore, crypto-asset services providers should, where available, record the LEI of clients that are legal persons on whose behalf they carry out orders and execute transactions. However, there are other legal entity identifiers that may be appropriate for use in the context of this Regulation. Directive (EU) 2017/1132 of the European Parliament and of the Council [^ntr7-L_202501140EN.000101-E0007] requires companies subject to that Directive to have a European Unique identifier (‘EUID’), which unequivocally identifies companies and as such is an appropriate tool for the identification of entities in the EU. Within a period of 18 months after the entry into force of this Regulation, the Commission and ESMA will work closely to facilitate the use of EUID as a tool to identify clients that are legal entities for the purpose of this Regulation. Following the completion of this work, the Commission should assess the readiness to use EUID for the purposes of Article 14. Additionally, to ensure openness to other identifiers which may be fit for supervisory purposes and support the integrity of the market, this Regulation sets out criteria that should be met by those alternative identifiers. To enable the market to use such eligible alternative identifiers, ESMA should approve their use where they meet the criteria set out in this Regulation.

• (11) A unique method for the identification and classification of parties compliant with the above-mentioned criteria and instruments that follow these principles directly supports efforts to achieve data-driven market monitoring by competent authorities.

• (12) Manual or algorithmic abusive behaviours can also occur when a crypto-asset service provider determines the trading platform for crypto-asset to access or the crypto-asset service provider to which the orders are to be transmitted or any other conditions related to the execution of the order. Therefore, to ensure effective market surveillance, a person or computer algorithm within the crypto-asset service provider performing such activities should be identified in the order and transaction records. For the same reasons, where both a person and computer algorithm are involved, or more than one person or algorithm is involved, the crypto-asset service provider should determine, on a consistent basis following predetermined criteria, which person or algorithm is primarily responsible for those activities.

• (13) To ensure that competent authorities have access to information that is relevant, accurate and complete, the details relating to the order to be transmitted between crypto asset service providers should be specified.

• (14) Given the cross-border nature of crypto assets trading, in order to avoid data gaps where a crypto-asset service provider transmits orders or executes transactions via an entity to which Regulation (EU) 2023/1114 does not apply, the crypto-asset service provider should record the transmission of those orders or the execution of those transactions as if it had transmitted those orders or executed those transactions itself. Such information may be of particular importance for the performance of adequate market monitoring and market abuse supervision by the competent authority.

• (15) To properly monitor the integrity and stability of the markets in crypto-assets, competent authorities need reliable, consistent and standardised information on the crypto-assets that are traded. Such information should enable them to identify the individual crypto-asset being traded according to internationally established principles. In addition, competent authorities should be able to retrieve the main characteristics of the crypto-assets traded, including their technology-specific features. Crypto-asset service providers should therefore use an internationally agreed digital token identifier to identify crypto-assets in the order and transactions records that they provide to competent authorities. The Digital Token Identifier (DTI) managed by the Digital Token Identifier Foundation is an internationally agreed identifier that guarantees reliable, consistent, standardised and available information and allows for comparability and aggregation of information at the level of the European Union, improving the quality and timeliness of aggregated data and reducing the reporting burden for crypto-asset service providers. Therefore, crypto-asset service providers should be able to use the DTI to identify crypto-assets. However, to ensure openness to other token identifiers which may be fit for supervisory purposes and support the integrity of the market, it is necessary to lay down criteria that should be met by those alternative identifiers. To enable the market to use eligible alternative identifiers, ESMA should approve their use where they meet the criteria set out in this Regulation.

• (16) To be able to properly monitor the integrity and stability of the markets in crypto-assets, competent authorities need reliable, consistent and standardised information on the crypto-assets that are traded. Such information should enable them to classify the individual crypto-asset being traded according to internationally established principles. Such classification should also enable authorities to connect data on white papers with data on transactions and orders in the same crypto asset. The ISO code for the Classification of Financial Instruments (CFI) is an international standard used for classifying financial instruments. However, crypto-assets that are not financial instruments cannot currently be described using the CFI code. The ISO CFI is being revised to accommodate the classification of crypto-assets, but this revision will not be finalized before the application of this Regulation. Therefore, until such revision is completed, an interim classification indicating the type of crypto-assets (crypto-assets other than asset-referenced tokens and e-money tokens, asset-referenced tokens, and e-money tokens) should be used.

• (17) To ensure efficient and effective market monitoring by competent authorities, transaction records should reflect whether the transaction was executed wholly or partly through a branch of the crypto-asset service provider located in another Member State or in a third country. The inclusion of data detailing the activity of each branch in the records kept by the crypto-asset service providers, should not lead to a disproportionate administrative burden for the crypto-asset service provider, but would enable competent authorities to supervise the services provided by crypto-asset service providers more efficiently and to enhance the visibility on how those services are provided within the different Member States.

• (18) In line with the principle of data minimisation, crypto-asset service providers should only keep information that is necessary and sufficient to enable competent authorities to carry out a comprehensive assessment of the crypto-asset service provider’s compliance with the relevant requirements of Regulation (EU) 2023/1114 and with that Regulation’s provisions on market abuse. When processing personal data included in the records, crypto-asset service providers and competent authorities should comply with the relevant provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council [^ntr8-L_202501140EN.000101-E0008].

• (19) In order to ensure certain and efficient identification of crypto-asset service providers responsible for executing orders or transactions, those providers should ensure that they are identified in the records maintained pursuant to their record-keeping obligations using validated, issued, and duly renewed legal entity identifiers (LEIs). Pursuant to Article 62 in Regulation (EU) 2023/1114, crypto-asset service providers are required to obtain a legal entity identifier in order to be authorised. Furthermore, to enable the competent authorities to fulfil their supervisory tasks and take enforcement measures in accordance with Article 68(10) of Regulation (EU) 2023/1114, such identifier should be verified, up-to-date and included in the records to be maintained in accordance with this Regulation.

• (20) The European Data Protection Supervisor was consulted in accordance with Article 42(1) of Regulation (EU) 2018/1725 of the European Parliament and of the Council [^ntr9-L_202501140EN.000101-E0009] and delivered an opinion on 28 August 2024.

• (21) This Regulation is based on the draft regulatory technical standards submitted to the Commission by the European Securities and Markets Authority (‘ESMA’).

• (22) ESMA has conducted open public consultations on the draft regulatory technical standards upon which this Regulation is based, analysed the potential related costs and benefits and requested the advice of the Securities and Markets Stakeholder Group established in accordance with Article 37 of Regulation (EU) No 1095/2010 of the European Parliament and of the Council [^ntr10-L_202501140EN.000101-E0010],

HAS ADOPTED THIS REGULATION:

SECTION 1 Retention of records and general provision on records

Article 1

Definitions

For the purposes of this Regulation, the following definitions shall apply:

• (1) ‘transaction’ means the conclusion of an acquisition or disposal of crypto-assets other than the crypto-assets referred to in Article 2(3) and (4) of Regulation (EU) 2023/1114;

• (2) ‘undertaking a transaction’ means executing a transaction or transmitting an order for crypto-assets on behalf of a client;

• (3) ‘executing a transaction’ means providing any of the following services or performing any of the following activities that result in a transaction:

• (a) reception and transmission of orders for crypto-assets on behalf of clients;

• (b) execution of orders on behalf of clients;

• (c) exchange of crypto-assets for funds or for other crypto-assets;

• (d) making an investment decision in accordance with a discretionary mandate given by a client;

• (e) transfer of crypto-assets to or from accounts.

Article 2

Retention of records

• (a) competent authorities are able to access those records readily and to reconstitute each key stage of the processing of each crypto-asset service, activity, order or transaction;

• (b) it is possible to easily ascertain any corrections or other amendments to the records, and the contents of the records prior to such corrections or amendments;

• (c) it is not possible to manipulate or alter the records;

• (d) it allows for the exploitation of the data by means of an ICT or any other efficient system, where it is not possible to easily analyse the data due to its volume and nature;

• (e) the crypto-asset service provider's record-keeping arrangements comply with the record keeping requirements under this Regulation irrespective of the technology used.

SECTION 2 Record keeping relating to specific crypto-asset services and to activities of crypto-asset service providers

Article 3

Record-keeping of the crypto-asset service provider’s policies and procedures

Article 4

Record-keeping of documents setting out the crypto-asset service provider’s and the client’s rights and obligations

Article 5

Record-keeping in relation to the safekeeping of clients’ crypto-assets and funds

• (a) records that readily identify the balances of crypto-assets and funds held for each client;

• (b) where clients’ funds are held by crypto-asset service providers in accordance with Article 70(2) and (3) of Regulation (EU) 2023/1114, details of the accounts in which those funds are held and the relevant agreements between the crypto-assets service provider with the credit institutions or central banks with which the clients’ funds are placed;

• (c) details of the accounts opened with third parties holding crypto-assets for the crypto-assets service provider and of the outsourcing agreements with those third parties;

• (d) details of third parties carrying out any tasks outsourced in accordance with Article 73 of Regulation (EU) 2023/1114 and details of the outsourced tasks;

• (e) names and functions of persons responsible for the safekeeping of clients’ crypto-assets and funds within the crypto-asset service provider;

• (f) agreements that establish client ownership over crypto-assets and funds.

SECTION 3 Record-keeping of orders and transactions

Article 6

Record-keeping of orders

Article 7

Record keeping of transactions

Article 8

Identification of person or computer algorithm within the crypto-asset service provider making the investment decision

Article 9

Designation to identify natural persons

• (a) the date of birth of the person in the format YYYYMMDD;

• (b) the five first characters of the first name of the person;

• (c) the five first characters of the surname of the person.

Article 10

Identification of a person or computer algorithm determining conditions for the execution of a transaction

Article 11

Recording of reception and transmission of orders

Article 12

Recording of orders and transactions executed via trading platforms or service providers to which Regulation (EU) 2023/1114 does not apply

Article 13

Recording of reception and transmission of orders to entities to which Regulation (EU) 2023/1114 does not apply

Article 14

Identification of clients that are legal entities

• (a) is unique;

• (b) is neutral;

• (c) is reliable;

• (d) is open source;

• (e) is scalable;

• (f) is accessible;

• (g) is available for free or at a reasonable cost;

• (h) is subject to an appropriate governance framework.

Article 15

Identification of crypto-assets

When providing information to competent authorities under Articles 6 and 7, a crypto-asset service provider shall identify the crypto-assets that are the subject of the recorded order or transaction, or used as a means of payment, by using a digital token identifier that is compliant with the ISO 24165 standard or an equivalent unique identifier approved by ESMA at Union level, which meets all of the following characteristics:

• (a) is unique;

• (b) is neutral;

• (c) is reliable;

• (d) is open source;

• (e) is scalable;

• (f) is accessible;

• (g) is available at a reasonable cost basis; and

• (h) is subject to an appropriate governance framework.

Article 16

Recording of transactions undertaken by branches

• (a) whether the branch received the order from a client or whether the branch made an investment decision for a client in accordance with a discretionary mandate given to it by the client;

• (b) whether the branch has supervisory responsibility for the person taking the investment decision concerned;

• (c) whether the branch has supervisory responsibility for the person determining the conditions for execution of the transaction;

• (d) whether the transaction was fully or partially undertaken on a trading platform for crypto-assets located outside the Union using the branch’s membership of that trading platform for crypto-assets.

Article 17

Identification of the crypto-asset service provider undertaking orders and transactions

Article 18

Entry into force

This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels, 27 February 2025.

For the Commission

The President

Ursula VON DER LEYEN

[^ntr1-L_202501140EN.000101-E0001]: OJ L 150, 9.6.2023, p. 40, ELI: http://data.europa.eu/eli/reg/2023/1114/oj.

[^ntr2-L_202501140EN.000101-E0002]: Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Regulation (EU) No 648/2012 (OJ L 173, 12.6.2014, p. 84, ELI: http://data.europa.eu/eli/reg/2014/600/oj).

[^ntr3-L_202501140EN.000101-E0003]: 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).

[^ntr4-L_202501140EN.000101-E0004]: Commission Delegated Regulation (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities (OJ L 87, 31.3.2017, p. 449, ELI: http://data.europa.eu/eli/reg_del/2017/590/oj).

[^ntr5-L_202501140EN.000101-E0005]: Commission Implementing Regulation (EU) 2019/363 of 13 December 2018 laying down implementing technical standards with regard to the format and frequency of reports on the details of securities financing transactions (SFTs) to trade repositories in accordance with Regulation (EU) 2015/2365 of the European Parliament and of the Council and amending Commission Implementing Regulation (EU) No 1247/2012 with regard to the use of reporting codes in the reporting of derivative contracts (OJ L 81, 22.3.2019, p. 85, ELI: http://data.europa.eu/eli/reg_impl/2019/363/oj).

[^ntr6-L_202501140EN.000101-E0006]: Commission Implementing Regulation (EU) No 1247/2012 of 19 December 2012 laying down implementing technical standards with regard to the format and frequency of trade reports to trade repositories according to Regulation (EU) No 648/2012 of the European Parliament and of the Council on OTC derivatives, central counterparties and trade repositories (OJ L 352, 21.12.2012, p. 20, ELI: http://data.europa.eu/eli/reg_impl/2012/1247/oj).

[^ntr7-L_202501140EN.000101-E0007]: Directive (EU) 2017/1132 of the European Parliament and of the Council of 14 June 2017 relating to certain aspects of company law (OJ L 169, 30.6.2017, p. 46, ELI: http://data.europa.eu/eli/dir/2017/1132/oj).

[^ntr8-L_202501140EN.000101-E0008]: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj).

[^ntr9-L_202501140EN.000101-E0009]: Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI: http://data.europa.eu/eli/reg/2018/1725/oj).

[^ntr10-L_202501140EN.000101-E0010]: Regulation (EU) No 1095/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European Supervisory Authority (European Securities and Markets Authority), amending Decision No 716/2009/EC and repealing Commission Decision 2009/77/EC (OJ L 331, 15.12.2010, p. 84, ELI: http://data.europa.eu/eli/reg/2010/1095/oj).

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	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	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
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	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 handling
Complaints	The records kept in accordance with Article 1(2)(f) of Commission Delegated Regulation (EU) 2025/294[^ntr1-L_202501140EN.001201-E0001].
Conflicts of interest and personal transactions	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
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	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	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	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	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	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	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