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?

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?

Do firms dealing on own account with regards to crypto-assets require a CASP license?

Is a small and non-interconnected investment firm (Art. 12 (1) IFR (Regulation (EU) 2019/2033)) that also holds a licence as a crowdfunding service provider according to Art. 12 ECSPR (Regulation (EU) 2020/1503) obligated to apply Art. 5-15 DORA or is it allowed to use the simplified ICT risk management framework of Art. 16 DORA?

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?