Source: OJ L, 2025/416, 14.3.2025

Article 3 Designation to identify natural persons

Summary What does Article 3 of the RTS on trading platform order book records say?

This article builds directly on Article 2, which requires crypto-asset service providers operating trading platforms to record identifying information about natural persons involved in orders.

Article 3 sets out the precise technical methodology for how those natural persons must actually be identified in order book records.

The approach is based on a standardised concatenation of a country code and a national client identifier, drawing on an existing framework from Delegated Regulation (EU) 2017/590.

The article also handles edge cases such as dual nationality, residency in a different country from nationality, and the specific formatting rules that apply when constructing identifiers.

Important points:

Identify natural persons in order book records using a two-letter ISO country code combined with a national client identifier, applying the highest priority identifier available under Delegated Regulation (EU) 2017/590.
Where a person holds multiple nationalities or resides in a country different from their nationality, apply specific rules to determine which country code and identifier to use.
Where the CONCAT method is used, construct the identifier from the person's date of birth (YYYYMMDD), followed by the first five characters of their first name, then the first five characters of their surname, all in upper case with no punctuation or spaces.

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

1. Crypto-asset service provider operating a trading platform for crypto-assets shall identify natural persons in the order book records by using the designation resulting from the concatenation of the ISO 3166-1 alpha-2 specified in ISO 3166 followed by the national client identifier as specified in Annex II of Delegated Regulation (EU) 2017/590 based on the nationality of the person. The two-letter country code shall correspond to the nationality of natural person.
1. The national client identifier referred to in paragraph 1 shall be assigned in accordance with the priority levels provided in Annex II of Delegated Regulation (EU) 2017/590 using the highest priority identifier that a person has regardless of whether that identifier is already known to the crypto-asset service provider operating a trading platform for crypto-assets.
1. Where a natural person is a national of more than one European Economic Area (EEA) country, the country code of the first nationality when sorted alphabetically by its ISO 3166-1 alpha-2 code and the identifier of that nationality assigned in accordance with paragraph 2 shall be used. Where a natural person has a non-EEA nationality, the highest priority identifier in accordance with the field referring to ‘all other countries’ provided in Annex II of Delegated Regulation (EU) 2017/590 shall be used. Where a natural person has an EEA and a non-EEA nationality, the country code of the EEA nationality and the highest priority identifier of that nationality assigned in accordance with paragraph 2 shall be used.
1. Where a natural person is a resident of a country other than the one of its nationality, crypto-asset service providers operating a trading platform for crypto-assets shall also identify that natural person based on the country of its residence as specified in field 50 of Table 2 of the Annex.
1. Prefixes to names shall be excluded and first names and surnames shorter than five characters shall be appended by ‘#’. All characters shall be in upper case. No apostrophes, accents, hyphens, punctuation marks or spaces shall be used.
1. Where the identifier assigned in accordance with paragraph 2 is based on CONCAT, the natural person shall be identified by the crypto-asset service provider operating a trading platform for crypto-assets using the concatenation of the following elements in the following order:
  1. the date of birth of that person in the format YYYYMMDD;
  2. the five first characters of the first name of that person;
  3. the five first characters of the surname of that person.

Relevant recitals

Recital 4 Standardised identification of natural persons in records

To ensure unique, consistent and robust identification of natural persons referred to in order records, those 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. The identification of natural persons should be conducted following the level of prioritisation of different identifiers detailed in Annex II of Commission Delegated Regulation (EU) 2017/590(²).

Recital 5 Recording country of residence of natural persons

It is possible that natural persons that need to be identified for record keeping are residents of a country other than the one of their nationality. Several obligations under Regulation (EU) 2023/1114 are linked to the country of residence of natural persons and collecting that information under this Regulation is therefore important to ensure effective supervision of transactions and orders by competent authorities.

Recital 6 Personal data recording subject to data minimisation

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 in crypto-assets, as these data are fundamental to ensure efficient supervision by competent authorities, including in the area of market abuse. In compliance with the principle of data minimisation set out in Regulation (EU) 2016/679 of the European Parliament and of the Council(³), crypto-asset service providers should keep only information that is necessary and sufficient to enable the competent authority to carry out a comprehensive assessment of the crypto-asset service provider’s compliance with the requirements of Regulation (EU) 2023/1114 and to monitor the trading activity relating to crypto-assets orders. 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.

Recital 9 Data minimisation for personal data in records

In compliance with the principle of data minimisation, the crypto-asset service provider should keep only information that is necessary and sufficient to enable the competent authority 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.

Table of contents

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