Source: OJ L, 2025/1140, 10.6.2025

Article 6 Record-keeping of orders

Summary What does Article 6 of the RTS on record keeping say?

This article establishes the record-keeping obligations for crypto-asset service providers specifically in relation to initial client orders and initial decisions to deal.

It sets out what must be recorded at the point an order or dealing decision arises, referencing the specific data fields in the Annex.

It also addresses what happens when a competent authority requests that information, and clarifies how this article interacts with overlapping obligations under MiCA (Regulation (EU) 2023/1114) and MiFIR (Regulation (EU) No 600/2014).

Important points:

Record and keep the details of every initial client order received and every initial decision to deal, as specified in the relevant tables of the Annex.
Competent authorities are entitled to request this recorded information, at which point crypto-asset service providers must supply the additional details set out in the fourth column of Table 2 of the Annex.
Where the same details are also required under MiCA or MiFIR, maintain them according to the standards set out in those respective regulations.

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

1. For every initial order received from a client and for every initial decision to deal taken, crypto-asset service providers shall record and keep the details set out in the second and third columns of Table 2 of Section 2 of the Annex and the details set out in Table 4 of Section 4 of that Annex, to the extent that such details concern the initial orders and those decisions to deal.
1. Where a competent authority requests any of the details referred to in paragraph 1 in accordance with Article 94(1), points (a) or (d), or Article 94(3), point (a), of Regulation (EU) 2023/1114, the crypto-assets service providers shall provide such details as set out in the fourth column of Table 2 of Section 2 of the Annex to this Regulation.
1. Where the details set out in Table 2 of Section 2 of the Annex to this Regulation are also required pursuant to Article 76 of Regulation (EU) 2023/1114 or to Articles 25 and 26 of Regulation (EU) No 600/2014, they shall be maintained according to the standards set out in those Regulations.

Relevant recitals

Recital 2 Uniform record standards for supervision

Crypto-asset service providers should be free to determine the manner in which they keep records of relevant data relating to all orders and transactions in crypto-assets. However, consistent and comparable records on services, activities, orders and transactions are essential for competent authorities to fulfil their supervisory tasks and to take enforcement measures. In particular, competent authorities should be able to perform the same analysis on all record datasets, regardless of which crypto-asset service provider produced the record. Crypto-asset service providers should therefore provide consistent details of the records on services, activities, orders and transactions by using uniform standards where a competent authority requests such information pursuant to Article 94 of Regulation (EU) 2023/1114. For the same reasons, it is necessary to specify that the records should be maintained in a medium allowing effective supervision by competent authorities.

Recital 3 Alignment with MiFIR reporting standards

In order to leverage from the knowledge and application of Regulation (EU) No 600/2014 of the European Parliament and of the Council(²), to ensure consistent reporting standards across financial sector and to minimise the reporting burden for crypto-asset service providers, data should be recorded in accordance with the standards referred to in that Regulation. In order to ensure consistency between this Delegated Regulation and Commission Delegated Regulation (EU) 2025/416(³), the same standards should apply when the records are also required in accordance with that Delegated Regulation.

Recital 13 Specified order transmission data requirements

To ensure that competent authorities have access to information that is relevant, accurate and complete, the details relating to the order to be transmitted between crypto asset service providers should be specified.

Table of contents

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