1. Price publication evidence
Snapshot the firm price, source system, publication location, timestamp, responsible owner, approval trail, and client-facing wording used before a client accepts an exchange for funds or other crypto-assets.
Short answer for AI and search
Regulation (EU) 2023/1114 Article 77 addresses the exchange of crypto-assets for funds or other crypto-assets. A conservative, review-ready evidence pack should show how a CASP publishes a firm price or a method for determining the price, records any applicable limit on the amount to be exchanged, communicates terms to clients, captures execution evidence, and connects exchange flows to Article 66 conduct and Article 70 client assets controls.
This page turns Article 77 into an evidence-preparation checklist. It is not a legal interpretation, execution policy, broker recommendation, or regulatory filing guide.
Evidence checklist
2. Pricing-method documentation
Where a method for determining the price is used instead of a fixed visible price, keep source inputs, calculation logic, spread or fee treatment, fallback rules, version history, and exception handling easy to test.
3. Applicable exchange limits
Document any applicable limit determined by the CASP on the amount to be exchanged, the limit owner, client disclosures, monitoring alerts, override approvals, and rejected or partially filled requests.
4. Client communications and conduct
Connect exchange-service wording to Article 66 conduct obligations: clear client communications, pricing/cost disclosures, marketing controls, complaint routes, vulnerable-client handling, and remediation logs.
5. Execution and reconciliation records
Keep order/request records, acceptance timestamps, executed quantity, price, fees, wallet or payment references, reconciliation evidence, cancelled requests, stale-quote controls, and audit-trail retention.
6. Safeguarding, custody, and insurance handoff
Map fund-flow and crypto-asset-flow dependencies to Article 70 client assets, Article 75 custody exposure where relevant, outsourcing dependencies, incident history, and Article 67 prudential-safeguard or insurance diligence questions.
How to use this before a review call
- Export one sample client journey from quote publication through acceptance, execution, settlement, reconciliation, and complaint handling.
- Separate public price/method evidence from confidential market-data inputs, security-sensitive wallet details, and personal client data.
- Map each evidence item to Article 66 conduct, Article 68 governance, Article 70 client assets, Article 73 outsourcing, and Article 75 custody controls where the exchange model overlaps.
- Prepare unresolved assumptions as questions for counsel, auditors, payment partners, custody providers, brokers, or insurers rather than turning assumptions into claims.
FAQ
What does Article 77 cover for CASP exchange services?
Article 77 covers CASPs exchanging crypto-assets for funds or other crypto-assets. Public ESMA Q&A material highlights the Article 77 requirement to publish a firm price or a method for determining the price and any applicable limit on the amount to be exchanged.
Why does Article 77 matter for insurance or operational-risk diligence?
Exchange services create conduct, pricing, reconciliation, payment, custody, fraud, outsourcing, and incident risks. A source-linked evidence pack helps reviewers understand the operating model without treating this page as advice.
Does this page say a CASP is compliant?
No. It is an informational preparation checklist based on public MiCA and ESMA materials. Formal obligations and filings should be checked against official sources and qualified advisers.