Subject Matter
Application of a new exception to PDMRs’ general prohibition to trade during the close period
Question
Does Article 19(12a) of MAR require issuers to expressly allow their PDMRs to trade during a closed period in the case of transactions or trade activities that do not relate to active investment decisions, that result exclusively from external factors or actions of third parties, or that are based on predetermined terms?
Subject Matter
Status of entities providing crypto-asset services as part of the grandfathering regime
Question
Are Crypto-asset service providers that provided their services in accordance with applicable law before 30 December 2024 and which are authorised to continue to do so under the law of a Member State in accordance with Article 143 of MiCA, considered to be crypto-asset service providers under the terms of MICA during the transitional period until they are authorised?
Level 1 Regulation
Subject Matter
Custody agreements in the exercise of rights attached to crypto-assets
Question
Would the ‘terms of service’ or any type of non-negotiated standard user agreement between a client and a crypto-asset service provider (CASP) providing custody services constitute a ‘valid agreement’ that ‘expressly provides otherwise’ per the clause in the second subparagraph of Article 75(4) of MiCA?

If so, can this agreement stipulate that a CASP providing custody services may be unable to facilitate the exercise of client rights with respect to a crypto-asset in the event of any modifications to those rights?
Level 1 Regulation