Source: OJ L, 2025/1140, 10.6.2025Current language: EN
- Markets in crypto-assets
Crypto-asset service provider
- RTS on record keeping
Article 15 Identification of crypto-assets
Summary What does Article 15 of the RTS on record keeping say?
This article sits alongside Article 14, which addresses how legal entity clients must be identified when reporting to competent authorities.
Article 15 applies the same logic to crypto-assets themselves: when crypto-asset service providers submit order or transaction information to competent authorities under Articles 6 and 7, they must use a standardised identifier for each crypto-asset involved.
The primary standard specified is ISO 24165, though an ESMA-approved equivalent at Union level is also accepted, provided it meets a defined set of quality characteristics.
Important points:
- When reporting to competent authorities under Articles 6 and 7, use a digital token identifier compliant with ISO 24165 to identify crypto-assets in recorded orders or transactions.
- An ESMA-approved alternative identifier is permitted, but only if it meets all eight listed characteristics, including being unique, neutral, reliable, open source, and subject to an appropriate governance framework.
- The obligation applies to crypto-assets that are the subject of the order or transaction, as well as those used as a means of payment.
Springlex's summary of the article, a reading aid, not a substitute for the legal text.
When providing information to competent authorities under Articles 6 and 7, a crypto-asset service provider shall identify the crypto-assets that are the subject of the recorded order or transaction, or used as a means of payment, by using a digital token identifier that is compliant with the ISO 24165 standard or an equivalent unique identifier approved by ESMA at Union level, which meets all of the following characteristics:
is unique;
is neutral;
is reliable;
is open source;
is scalable;
is accessible;
is available at a reasonable cost basis; and
is subject to an appropriate governance framework.
Relevant recitals
Recital 15 Digital token identifier for crypto-assets
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 enable them to identify the individual crypto-asset being traded according to internationally established principles. In addition, competent authorities should be able to retrieve the main characteristics of the crypto-assets traded, including their technology-specific features. Crypto-asset service providers should therefore use an internationally agreed digital token identifier to identify crypto-assets in the order and transactions records that they provide to competent authorities. The Digital Token Identifier (DTI) managed by the Digital Token Identifier Foundation is an internationally agreed identifier that guarantees reliable, consistent, standardised and available information and allows for comparability and aggregation of information at the level of the European Union, improving the quality and timeliness of aggregated data and reducing the reporting burden for crypto-asset service providers. Therefore, crypto-asset service providers should be able to use the DTI to identify crypto-assets. However, to ensure openness to other token identifiers which may be fit for supervisory purposes and support the integrity of the market, it is necessary to lay down criteria that should be met by those alternative identifiers. To enable the market to use eligible alternative identifiers, ESMA should approve their use where they meet the criteria set out in this Regulation.
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.
Definition
placing of crypto-assets
Definition
official currency
Definition
distributed ledger
Definition
reception and transmission of orders for crypto-assets on behalf of clients
Definition
exchange of crypto-assets for funds
Definition
consensus mechanism
Definition
operation of a trading platform for crypto-assets
Definition
e-money token
Definition
crypto-asset service
- providing custody and administration of crypto-assets on behalf of clients;
- operation of a trading platform for crypto-assets;
- exchange of crypto-assets for funds;
- exchange of crypto-assets for other crypto-assets;
- execution of orders for crypto-assets on behalf of clients;
- placing of crypto-assets;
- reception and transmission of orders for crypto-assets on behalf of clients;
- providing advice on crypto-assets;
- providing portfolio management on crypto-assets;
- providing transfer services for crypto-assets on behalf of clients;
Definition
offer to the public
Definition
providing advice on crypto-assets
Definition
offeror
Definition
execution of orders for crypto-assets on behalf of clients
Definition
crypto-asset service provider
Definition
crypto-asset
Definition
DLT network node
Definition
funds
Definition
client
Definition
asset-referenced token
Definition
issuer
Definition
exchange of crypto-assets for other crypto-assets
Definition
electronic money token
Definition
providing custody and administration of crypto-assets on behalf of clients
Definition
providing transfer services for crypto-assets on behalf of clients
Definition
distributed ledger technology
Definition
transaction
Definition
competent authority
- designated by each Member State in accordance with Article 93 concerning offerors, persons seeking admission to trading of crypto-assets other than asset-referenced tokens and e-money tokens, issuers of asset-referenced tokens, or crypto-asset service providers;
- designated by each Member State for the application of Directive 2009/110/EC concerning issuers of e-money tokens;