CASP Honest, Fair & Professional Conduct Manager
MiCA Article 66 Compliance Demonstration
Art. 66 Compliance Overview
Completeness Score92%
Art. 66(1): Act honestly, fairly, professionally
Policy framework established through pricing and risk disclosure
Art. 66(2): Fair, clear, non-misleading information
Risk disclosures in place
Art. 66(3a): Risk warnings for crypto-asset transactions
All 6 mandatory risk categories disclosed
Art. 66(3b): White paper hyperlinks (conditional on service type)
Conditionally required: trading_platform, exchange, advice, portfolio_management
Art. 66(4): Public pricing, costs, fees policies
1 transparent pricing policies published
Art. 66(5): Principal adverse environmental impacts disclosure
PoW mechanism impact disclosed
1. Pricing Transparency (Art. 66(4))
Service
custody
Fee Structure
0.1% EUR
Published
Yes
Additional Costs
None
Pricing policy meets transparency requirements. Clients can clearly understand all fees and costs.
2. Risk Warnings (Art. 66(3))
Warnings Provided: 6/6 Mandatory
1. VOLATILITY
"The value of crypto-assets is subject to market volatility and may fluctuate significantly."
2. LIQUIDITY
"Crypto-assets may lack liquidity and it may be difficult to sell or exchange them rapidly."
3. TOTAL LOSS
"You may lose the entire value of your crypto-assets. There is no guarantee of return."
4. NO INVESTOR PROTECTION
"Crypto-assets are not covered by investor compensation or deposit guarantee schemes."
5. SMART CONTRACT RISK
"Smart contract vulnerabilities or security breaches could result in loss of your assets."
6. REGULATORY RISK
"Regulatory changes may adversely affect the value and usability of crypto-assets."
3. Environmental Impact Disclosure (Art. 66(5))
Mechanism
PoW
Published
Yes
Annual Energy (KWh)
140,000,000,000
Data Source
third party audit
Environmental disclosure meets Art. 66(5) requirements. Public availability confirmed.
4. White Paper Links (Art. 66(3) - Conditional)
MiCA Compliance Note
Implemented: Art. 66(1)–(5) — Demonstrates honest, fair, and professional conduct requirements including pricing transparency, risk warnings, environmental impact disclosure, and conditional white paper linking.
Out of scope: Art. 66 Marketing Communications — Full advertising compliance review requires external legal review. This POC focuses on internal policy management.
What this POC does not implement
- ❌ Website publication — This POC does not publish to live websites; it demonstrates the policy framework and validation logic.
- ❌ External data integration — Environmental energy data would normally come from blockchain explorers or third-party audits; this POC uses static examples.
- ❌ Multi-service scope — The POC demonstrates one pricing policy per service; real CASPs manage multiple services with non-discriminatory rates.
- ❌ Client interaction logging — Risk acknowledgment and pricing disclosure to clients is not tracked; assume delivered via website.
- ❌ Annual review workflow — Policy reviews are assumed to happen offline; this POC validates the review deadline but does not enforce it.