Source: OJ L, 2025/885, 20.8.2025

Article 6 Timing of STORs

Summary What does Article 6 of the RTS on market abuse say?

This article focuses on the timeliness and completeness of STOR submissions.

Building on the detection and assessment obligations established in earlier articles, Article 6 governs what happens once a reasonable suspicion of market abuse has been formed — namely, how quickly and thoroughly persons professionally arranging or executing transactions in crypto-assets must act.

It also addresses two practical scenarios that extend obligations beyond the initial report: historical suspicious activity identified only later, and the emergence of new information after a STOR has already been filed.

Important points:

Ensure arrangements, systems and procedures are in place to submit a STOR without delay once reasonable suspicion of market abuse is formed.
STORs can cover past transactions or orders where suspicion arises from subsequent events — but you must explain the delay in the report itself.
Submit any relevant additional information to the competent authority that emerges after a STOR has been filed, and comply with any requests for information or documents from that authority.

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 ensure that they have in place effective arrangements, systems and procedures for the submission of a STOR without delay, once reasonable suspicion of market abuse is formed.
1. The arrangements, systems and procedures referred to in paragraph 1 shall entail the possibility to report STORs in relation to transactions, orders or other aspects of the functioning of the DLT which occurred in the past, where suspicion has arisen in the light of subsequent events or information. In such cases, persons professionally arranging or executing transactions in crypto-assets shall explain in the STOR the delay between the suspected breach and the submission of the STOR according to the specific circumstances of the case.
1. Persons professionally arranging or executing transactions in crypto-assets shall submit to the competent authority any relevant additional information which they become aware of after the STOR has been submitted, and shall provide any information or document requested by the competent authority.

Relevant recitals

Recital 12 Submit STORs without delay upon suspicion

The STORs should be submitted to the competent authority without delay once a reasonable suspicion about the existence of market abuse has been formed. The analysis as to whether a given order or transaction is to be considered suspicious should be based on facts, not speculation or presumption and should be carried out as quickly as practicably possible. Delaying the submission of a report to incorporate further suspicious orders, transactions or other aspects of the functioning of the DLT or accumulating several STORs would be irreconcilable with the obligation to act without delay, where a reasonable suspicion has already been formed. In any case, persons professionally arranging or executing transactions in crypto-assets should assess on a case-by-case basis whether several orders, transactions or other aspects of the functioning of the DLT could be reported in a single STOR.

Recital 13 Late-formed suspicion and justification of delay

There might be circumstances where a reasonable suspicion of market abuse is formed after the suspected activity occurred, due to subsequent events or available information. That should not be a reason for not reporting the suspected activity to the competent authority. To demonstrate compliance with the reporting requirements in those specific circumstances, the person submitting the STOR should be able to justify the time discrepancy between the occurrence of the suspected activity and the formation of the reasonable suspicion of market abuse having been committed, being committed or likely to be committed.

Recital 14 Review prior analyses and non-reasonable cases

To assist persons professionally arranging or executing transactions in crypto-assets in exercising their judgement when considering subsequent suspicious orders or transactions, they should be able to recall and review the analysis of STORs which have been submitted, and of those suspicious orders, transactions and behaviours connected to the functioning of the DLT which were analysed, but in relation to which the competent authority concerned concluded that the grounds for suspicion were not reasonable.

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.