Source: OJ L, 2025/416, 14.3.2025

Current language: EN

Article 9 Identification codes for orders in crypto-assets


Summary What does Article 9 of the RTS on trading platform order book records say?

This article deals with order identification, setting out how crypto-asset service providers operating a trading platform must assign and manage identification codes for orders.

It covers the core requirement of unique order codes, but also extends to more complex scenarios involving strategy orders with implied functionality (SOIFs) and routed orders.

The article builds on the broader record-keeping framework established across Articles 2 to 15, adding a layer of traceability and consistency to how individual orders are tracked throughout their lifecycle on the platform.

Important points:

  • Assign a unique identification code to every order — including rejected ones — that remains valid from receipt until removal from the order book, unique per order book, trading day, and crypto-asset.
  • For strategy orders with implied functionality (SOIFs), maintain their details and use a shared strategy linked order identification code across all orders connected to the same strategy upon execution.
  • Orders subject to a routing strategy must be flagged as 'routed' and retain the same identification code for their entire lifetime, even if any remaining quantity is re-posted on the order book.

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 maintain an individual identification code for each order as specified in field 19 of Table 2 of the Annex. The identification code shall be unique per following:

      1. order book;

      2. trading day; and

      3. crypto-asset.

    2. The code shall be valid starting from the receipt of the order by the operator of the trading platform for crypto-assets until the removal of the order from the order book. The identification code shall apply to rejected orders irrespective of the ground for their rejection.

    1. The operator of the trading platform for crypto-assets shall maintain the relevant details of strategy orders with implied functionality (‘SOIF’) that are disseminated to the public as specified in field 31 of Table 2 of the Annex. The order status referred to in that field shall specify whether the order is an implicit order.

    1. Upon execution of a SOIF, its details shall be maintained by the operator of the trading platform for crypto-assets as specified in the relevant fields in Table 2 of the Annex.

    1. Upon execution of a SOIF, a strategy linked order identification code shall be indicated using the same identification code for all orders connected to the particular strategy. The strategy linked order identification code shall be specified in accordance with field 44 of Table 2 of the Annex.

    1. Orders submitted to a trading platform for crypto-assets allowing for a routing strategy shall be identified by that trading platform for crypto-assets as ‘routed’ as specified in field 31 of Table 2 of the Annex when they are routed to another trading platform for crypto-assets. Orders submitted to a trading platform for crypto-assets allowing for a routing strategy shall retain the same identification code for their lifetime, regardless of whether any remaining quantity is re-posted on the order book.

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