Source: OJ L, 2025/416, 14.3.2025

Article 4 Identifiers for legal entities and crypto-assets

Summary What does Article 4 of the RTS on trading platform order book records say?

This article sets out the identification standards that crypto-asset service providers operating a trading platform must follow when recording legal entities and crypto-assets in their order books.

It acts as a companion to Article 3, which covers the identification of natural persons, together forming the complete identification framework for order book records.

The article defers to external technical standards for the specifics of both entity and asset identification, and adds a concrete compliance requirement for the use of the Legal Entity Identifier (LEI), tying it to an internationally recognised standard and a central database.

Important points:

Use the prescribed entity identifiers and asset identifiers, as defined in the referenced Commission Delegated Regulation, when recording legal entities and crypto-assets in order book records.
Where an LEI is used to identify a legal entity, ensure it complies with ISO 17442 and is registered in the Global LEI database maintained by the Central Operating Unit appointed by the Regulatory Oversight Committee.
The LEI recorded must refer to the specific entity concerned, not simply be a valid code in the database.

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

1. Crypto-asset service providers operating a trading platform for crypto-assets shall identify legal entities in order book records by using the entity identifier in accordance with Article 14 of Commission Delegated Regulation establishing technical standards adopted pursuant to Article 68(10), first subparagraph, point (b).
1. Crypto-asset service providers operating a trading platform for crypto-assets shall identify crypto-assets in order book records by using the asset identifiers in accordance with Article 15 of Commission Delegated Regulation establishing technical standards adopted pursuant to Article 68(10), first subparagraph, point (b).
1. Where using the Legal Entity Identifier (LEI) to identify legal entities in accordance with paragraph 1, the crypto-asset service provider operating a trading platform for crypto-assets shall ensure that the length and construction of the LEI code recorded in the order book records is compliant with the ISO 17442 standard and that the LEI code is included in the Global LEI database maintained by the Central Operating Unit appointed by the Regulatory Oversight Committee, and refers to the entity concerned.

Relevant recitals

Recital 2 Standardised crypto-asset identifiers for supervisory monitoring

To properly monitor the integrity and stability of the markets in crypto-assets, competent authorities need reliable, consistent and standardised information on the crypto-assets that are traded. Such information should allow them to identify the individual crypto-asset being traded according to internationally established principles. In addition, they should be able to retrieve the main characteristics of the crypto-assets, including their technology-specific features. Crypto-asset service providers should therefore use an appropriate asset identifier to identify crypto-assets in the order and transactions records that they provide to competent authorities. In light of that objective, the use of the Digital Token Identifier (DTI) managed by the Digital Token Identifier Foundation, or alternative eligible identifiers is provided for in Commission Delegated Regulation establishing technical standards adopted pursuant to Article 68(10), first subparagraph, point (b) to identify crypto assets that are the subject of an order or transaction to be recorded by the crypto-asset service provider. In light of those considerations and to ensure a consistent supervisory approach, it is appropriate to provide for the use of asset identifiers in this Regulation under the same conditions as in Commission Delegated Regulation establishing technical standards adopted pursuant to Article 68(10), first subparagraph, point (b).

Recital 7 Identification of legal entity clients using standard identifiers

To facilitate market surveillance and allow comparability of the records, clients that are legal entities should be identified with an identifier that is compatible with the internationally established criteria for the development of robust identification systems for the monitoring of financial markets. With a view to ensuring a consistent supervisory approach, the entity identifiers provided for in Commission Delegated Regulation establishing technical standards adopted pursuant to Article 68(10), first subparagraph, point (b), it is appropriate to provide for the use of entity identifiers in this Regulation under the same conditions as in that Regulation.

Table of contents

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