Article 66 of the EU Markets in Crypto-Assets Regulation requires crypto-asset service providers to act honestly, fairly and professionally in the best interests of clients and prospective clients. It links that standard to fair communications, risk warnings, white-paper access and public pricing policies. The obligation is broader than adding a disclaimer to a promotional page. Regulation (EU) 2023/1114 on markets in crypto-assets
Follow the evidence
Trace how the event could reach markets, then inspect a competing explanation.
Compare explanations
Switch lenses to see what each account explains—and what remains uncertain.
A CASP can test compliance by following each route from advertisement to account opening, order preview, confirmation and withdrawal. Names, risks and fee terminology should remain consistent. A cost disclosed only after a client commits funds may undermine the usefulness of an otherwise detailed pricing page. Marketing review should document the target audience, factual support, risk balance, approval owner and expiry date. Claims about safety, yield, speed or liquidity can become misleading when market conditions or product mechanics change. The review should therefore be repeatable, not a one-time sign-off at launch. The best-interests standard does not eliminate client responsibility or token-price risk. It also does not mean every product must be suitable for every person. It establishes how the provider must communicate and behave. Service-specific suitability or appropriateness requirements may add further duties depending on the activity.
A CASP can test compliance by following each route from advertisement to account opening, order preview, confirmation and withdrawal. Names, risks and fee terminology should remain consistent. A cost disclosed only after a client commits funds may undermine the usefulness of an otherwise detailed pricing page. Marketing review should document the target audience, factual support, risk balance, approval owner and expiry date. Claims about safety, yield, speed or liquidity can become misleading when market conditions or product mechanics change. The review should therefore be repeatable, not a one-time sign-off at launch. The best-interests standard does not eliminate client responsibility or token-price risk. It also does not mean every product must be suitable for every person. It establishes how the provider must communicate and behave. Service-specific suitability or appropriateness requirements may add further duties depending on the activity.
Before using a service, identify the authorised entity, save the fee policy and compare it with the order screen and account statement. Check whether promotional performance excludes fees or uses a period that flatters the result. A visible risk warning should address the service actually offered, not generic volatility alone. Clients should open the linked white paper from the provider’s page and verify the asset identity. Similar tickers and wrapped versions can have different issuers, rights and technical risks. If the provider cannot connect the marketing name to a specific asset and disclosure, the information chain is incomplete. Article 66 offers a practical reading rule: promotional prominence should be matched by equally usable facts about risk and cost. A glossy interface, authorised status or white-paper link cannot guarantee returns. The value of the rule is that it makes the communication process testable against a defined client-interest obligation.
Information must be fair, clear and identifiable as marketing
MiCA says client information, including marketing communications, must be fair, clear and not misleading. Marketing must be identifiable as such. Providers must not deliberately or negligently mislead clients about real or perceived advantages of crypto-assets. This covers presentation and omissions as well as technically accurate sentences viewed in isolation. Regulation (EU) 2023/1114 on markets in crypto-assets
Providers must warn clients about transaction risks. When operating a trading platform, exchanging assets, giving advice or managing portfolios, they must also give clients links to relevant crypto-asset white papers. A white paper is a disclosure document; providing the link does not turn the asset into an approved or guaranteed investment.
Article 66 also requires policies on pricing, costs and fees to be available prominently on the provider’s website. The requirement concerns the policy, not merely a single headline commission. Spreads, custody charges, withdrawal fees, conversion costs and third-party expenses may all affect the client’s economic result.
The customer journey should match the published policy
A CASP can test compliance by following each route from advertisement to account opening, order preview, confirmation and withdrawal. Names, risks and fee terminology should remain consistent. A cost disclosed only after a client commits funds may undermine the usefulness of an otherwise detailed pricing page.
Marketing review should document the target audience, factual support, risk balance, approval owner and expiry date. Claims about safety, yield, speed or liquidity can become misleading when market conditions or product mechanics change. The review should therefore be repeatable, not a one-time sign-off at launch.
The best-interests standard does not eliminate client responsibility or token-price risk. It also does not mean every product must be suitable for every person. It establishes how the provider must communicate and behave. Service-specific suitability or appropriateness requirements may add further duties depending on the activity.
Compare the promise, the legal entity and the actual charge
Before using a service, identify the authorised entity, save the fee policy and compare it with the order screen and account statement. Check whether promotional performance excludes fees or uses a period that flatters the result. A visible risk warning should address the service actually offered, not generic volatility alone.
Clients should open the linked white paper from the provider’s page and verify the asset identity. Similar tickers and wrapped versions can have different issuers, rights and technical risks. If the provider cannot connect the marketing name to a specific asset and disclosure, the information chain is incomplete.
Article 66 offers a practical reading rule: promotional prominence should be matched by equally usable facts about risk and cost. A glossy interface, authorised status or white-paper link cannot guarantee returns. The value of the rule is that it makes the communication process testable against a defined client-interest obligation.
