Source: OJ L, 2025/1264, 3.10.2025

Current language: EN

Article 4 Segregation of the liquidity management policy and procedures


Summary What does Article 4 of the RTS on liquidity management policy say?

This article acts as a scoping and separation rule that governs how the requirements established in Articles 2 and 3 must be applied in practice.

It makes clear that the liquidity management framework is not a one-size-fits-all exercise: issuers must apply those requirements individually for each token they issue, tailoring their approach to the specific assets referenced and their correlation with the corresponding reserve of assets.

On top of this, the article draws a firm boundary between token-related liquidity management and any other liquidity policies the issuer may operate for its wider business activities.

Important points:

  • Apply the liquidity risk requirements from Articles 2 and 3 separately for each asset-referenced token or e-money token issued, accounting for the specific assets referenced and their correlation with the relevant reserve of assets.
  • Ensure that the liquidity management policies and procedures for token issuance are kept entirely separate, in content and form, from those covering any other activities of the issuer.
  • The segregation requirement applies to all issuers of asset-referenced tokens or e-money tokens subject to this Regulation.

Springlex's summary of the article, a reading aid, not a substitute for the legal text.

    1. Issuers of asset-referenced tokens or e-money tokens shall apply the requirements set out in Articles 2 and 3 separately for each asset-referenced token or e-money token. The procedures for identifying, measuring, managing and reporting liquidity risk, the contingency policies and liquidity risk mitigation tools, the risk limits, the liquidity management tools and strategies referred to in those Articles shall be established, in content and form, taking into account the different assets referenced by the different asset-referenced token or e-money token and their correlation with the relevant segregated reserve of assets.

    1. The liquidity management policy and procedures specified in this Regulation shall be separate, in content and form, from the liquidity policy and procedures related to activities of the issuer other than those related to issuing of asset-referenced tokens or e-money tokens.

We're continuously improving our platform to serve you better.

Your feedback matters! Let us know how we can improve.

Found a bug?

Springflod is a Swedish boutique consultancy firm specialising in cyber security within the financial services sector.

We offer professional services concerning information security governance, risk and compliance.

Crafted with ❤️ by Springflod