Source: OJ L, 2025/298, 13.2.2025

Current language: EN

Article 5 Data quality


Summary What does Article 5 of the RTS on non-EU currencies say?

This article focuses on the data quality and integrity obligations placed on issuers.

It requires issuers to have systems and procedures in place to ensure that transaction data reported to competent authorities is correct, complete, and submitted on time.

Complementing the reporting methodology set out in the earlier articles, this article adds an operational layer by requiring issuers to actively reconcile data received from crypto-asset service providers with data from other available sources, including on-chain distributed ledger data where applicable.

Important points:

  • Implement systems and procedures to ensure that data reported to competent authorities is correct, complete, and submitted within the required timeframe.
  • These systems must enable reconciliation of data received from crypto-asset service providers with data available from other sources, including distributed ledger transaction data.
  • The reconciliation obligation extends to both custodial-to-custodial and custodial-to-non-custodial wallet transactions, covering data from either the payee's or payer's crypto-asset service provider accordingly.

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

    1. The issuer shall have systems and procedures in place to ensure that the data submitted to the competent authority pursuant to Article 22(1), point (d), of Regulation (EU) 2023/1114 is correct, complete and submitted within the timeframe set out in Implementing Regulation (EU) 2024/2902.

    1. The systems and procedures referred to in paragraph 1 shall allow the issuer to reconcile the data received from the crypto-asset service provider of the payee, or, in the case of transactions from a custodial wallet to a non-custodial wallet, the data received from the crypto-asset service provider of the payer pursuant to Article 22(3) of (EU) Regulation 2023/1114 and Implementing Regulation (EU) 2024/2902 with the data available to the issuer from other sources, including, where applicable, transactional data available on the distributed ledger.

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