Source: OJ L, 2025/885, 20.8.2025

Article 5 Reporting of suspicious orders or transactions

Summary What does Article 5 of the RTS on market abuse say?

This article governs how persons professionally arranging or executing transactions in crypto-assets must assess, prepare, submit, and handle Suspicious Transaction and Order Reports (STORs).

Building directly on the detection and monitoring framework established in Articles 2 and 3, this article moves from surveillance to action — setting out the practical requirements for actually filing a report with the competent authority.

It covers the quality standards for a STOR, the mechanics of submission, and critically, the obligation to keep the entire reporting process strictly confidential from the subject of the report.

Important points:

Establish and maintain arrangements, systems and procedures — including an appropriate level of human analysis — to assess whether orders, transactions or DLT activity may indicate market abuse, for the purpose of submitting a STOR.
Submit STORs using the prescribed Annex template, completed clearly and accurately, via the electronic means specified by the competent authority on its website, with STORs based on facts and all available information. Competent authorities are required to ensure those electronic means maintain completeness, integrity, and confidentiality during transmission.
Strictly maintain confidentiality of the entire STOR process — the subject of the report and any non-essential internal parties must not be informed of alerts generated, the assessment, the preparation of the STOR, or its submission or intended submission.

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

1. Persons professionally arranging or executing transactions in crypto-assets shall establish and maintain effective arrangements, systems and procedures that enable them to assess, for the purpose of submitting a STOR, whether with reference to an order, a transaction or other aspects of the DLT there might be circumstances indicating that market abuse has been committed, is being committed or is likely to be committed. Those arrangements, systems and procedures shall include an appropriate level of human analysis.
1. Persons professionally arranging or executing transactions in crypto-assets shall report a STOR:
  1. by using the STOR template set out in the Annex and completing the information fields relevant to the reported orders, transactions or other aspects of functioning of the DLT in a clear and accurate manner, including any supporting documents or attachments;
  2. using the electronic means specified by that competent authority.
2. For the purposes of point (b) of the first subparagraph, the competent authority shall specify on its website the electronic means to be used, and shall ensure that those electronic means ensure that the completeness, integrity, and confidentiality of the information are maintained during the transmission.
3. The STOR referred to in the first subparagraph shall be based on facts and analysis, considering all the information available to the persons professionally arranging or executing transactions in crypto-assets.
1. Persons professionally arranging or executing transactions in crypto-assets shall ensure and maintain the confidentiality of the information laid down in the report on suspicious orders or transactions and ensure that the person in respect of which the STOR was submitted and anyone who is not required to know about the submission of a STOR by virtue of their function or position within the reporting person is not informed of:
  1. the generation of the alerts referred to in Article 3(1), point (b);
  2. the assessment that may lead to the submission of a STOR;
  3. the fact that the reporting person will complete the STOR without sending requests of information to the person in respect of which the STOR may be submitted to complete certain fields;
  4. the submission of a STOR to the competent authority, or the intention to submit one.

Relevant recitals

Recital 2 Appropriate monitoring systems and human analysis

To ensure that prevention and detection of market abuse is effective, appropriate systems should be in place to monitor orders, transactions and other aspects of functioning of the DLT, in accordance with the scale, size and nature of the business activity of the person professionally arranging or executing transactions. Such systems should provide for human analysis carried out by appropriately trained staff based on objective information at the disposal of the reporting entity. The entity should collect additional personal data, only to ensure appropriate human analysis. To allow for further analysis of potential insider dealing or market manipulation or attempted insider dealing or market manipulation, the systems for monitoring market abuse should be capable of producing alerts in line with specified parameters. The access to such alerts should be recorded to ensure that they are only used for detecting market abuse. The whole process is likely to require some level of automation.

Recital 5 Harmonised STOR content, template and timing

To facilitate and promote a consistent approach and practices across the Union in relation to the prevention, detection and sanctioning of market abuse, it is necessary to lay down detailed provisions harmonising the content of, the template for and the timing of the reporting of suspicious orders and transactions and other aspects of the functioning of DLT.

Recital 7 Trading rules, order book replay and single STOR template

Crypto asset service providers operating a trading platform should have appropriate trading rules that contribute to the prevention of market abuse. Those entities should also have facilities to replay the order book in order to analyse the trading activity.

A single and harmonised template for electronically submitting a suspicious transaction and order report (‘STOR’) should facilitate the efficient sharing of information on suspicious orders and transactions between competent authorities in cross-border investigations.

Recital 9 Attachments to and DLT behaviour in STORs

To facilitate the submission of a STOR, the template should allow for the attachment of documents and materials that are necessary to support the notification made, including in the form of an annex that lists the suspicious orders or transactions and detailing their prices and volumes. In addition, the STOR template should allow for the reporting of suspicious behaviours connected to the functioning of the DLT.

Recital 11 Use internal and public ledger information

The analysis of orders, transactions or other aspects of the functioning of the DLT should factor in not only the internal information of the person professionally arranging or executing transactions in crypto-assets, but all the information publicly available, including information about transactions embedded in a public ledger system.

Table of contents

Springlex and this text is meant purely as a documentation tool and has no legal effect. No liability is assumed for its content. The authentic version of this act is the one published in the Official Journal of the European Union.