Regulatory Disclosures

Asset disclosures &
compliance information

Detailed disclosures for each supported asset — covering MiCA whitepaper status, environmental characteristics, and operational policies. Published in accordance with our obligations under the EU regulatory framework.

01 Whitepapers & MiCA Status 02 Environmental Characteristics 03 Pricing Methodology 04 Post-Transaction Data 05 Exchange Limits 06 Conflicts of Interest
Section 01

Whitepapers & MiCA status

Under Regulation (EU) 2023/1114 (MiCA), certain crypto-asset issuers are required to publish a compliant whitepaper before making a public offer or seeking admission to trading within the EU. The disclosure obligations depend on asset classification. The information below reflects the current status for each asset supported by BitSpider.

Bitcoin Ethereum
Bitcoin & Ethereum
BTC · ETH
No issuer whitepaper required

BTC and ETH have no official MiCA whitepaper and are not subject to issuer whitepaper obligations. Both assets are fully decentralised with no identifiable issuer — the entities that originally created them have no ongoing legal control over the networks.

Under MiCA, whitepaper and disclosure obligations for such assets may fall on the Crypto-Asset Service Provider (CASP) listing them within the EU, rather than on any issuer. BitSpider, as a CASP, monitors the evolving guidance from ESMA and competent authorities on applicable CASP-level obligations for these assets.

Do your own research: Bitcoin Whitepaper  ·  Ethereum Whitepaper
POL TRON
Polygon & TRON
POL · TRX
No MiCA-specific whitepaper published

No publicly known MiCA-specific whitepaper has been published for POL or TRX. A MiCA-compliant whitepaper would only be formally required if there is a public offer in the EU or admission to trading under MiCA rules — obligations that fall on the issuer rather than on BitSpider as a CASP.

Both projects maintain their own technical and project documentation, which may be relevant context for clients. BitSpider will update this section as regulatory guidance evolves.

Do your own research: Polygon (POL) Documentation  ·  TRON Whitepaper
USDC
USD Coin
USDC — Issued by Circle Internet Financial
MiCA compliance documentation required (EMT)

USDC is widely understood to qualify as an E-Money Token (EMT) under MiCA. EMTs are tokens that purport to maintain a stable value by referencing the value of one official currency. As a USD-pegged stablecoin, USDC falls within this classification.

Under MiCA, EMT issuers must obtain authorisation as an e-money institution and publish a MiCA-compliant whitepaper prior to any offer to the public or admission to trading in the EU. Compliance documentation is therefore required for EU-facing issuance. Circle Internet Financial has been engaged in regulatory processes across jurisdictions and clients should review Circle's most current regulatory disclosures and whitepaper filings.

BitSpider does not issue USDC. Our role as a CASP is limited to facilitating exchange. We monitor ongoing ESMA guidance and EMT-specific CASP obligations closely.

Do your own research: Circle USDC Documentation  ·  USDC MiCA Whitepaper  ·  MiCA Regulation (EU) 2023/1114
Section 02

Environmental characteristics

MiCA requires CASPs to disclose the environmental and climate-related impact of the crypto-assets they support. The information below summarises the consensus mechanism and known energy profile for each supported asset.

Bitcoin
Bitcoin
BTC
⚡ Proof of Work

Bitcoin uses Proof of Work (PoW) — the original blockchain consensus mechanism. Miners compete to solve cryptographic puzzles using specialised ASIC hardware. The miner who solves the puzzle first earns the block reward and transaction fees.

PoW is intentionally energy-intensive by design: the computational cost is what makes the network secure and resistant to attack. Bitcoin's annualised energy consumption is estimated at 100–150 TWh per year, comparable to medium-sized nations. The energy mix increasingly includes renewables and stranded energy sources, though the proportion varies significantly by region.

No planned transition to a lower-energy consensus mechanism exists on Bitcoin's roadmap.

ConsensusProof of Work (SHA-256)
Est. energy use~100–150 TWh / year
HardwareASIC miners
Ethereum
Ethereum
ETH
⚡ Previously PoW ✓ Now Proof of Stake

Ethereum originally launched on Proof of Work before completing "The Merge" in September 2022 — a full transition to Proof of Stake (PoS). This reduced Ethereum's energy consumption by an estimated 99.95%.

Under PoS, validators are chosen to propose and attest blocks in proportion to the amount of ETH they have staked (minimum 32 ETH). There is no competitive mining; security is provided by the economic stake at risk of slashing. The network now consumes approximately ~0.01 TWh per year — roughly equivalent to a small town.

ConsensusProof of Stake (since Sept 2022)
Energy reduction~99.95% vs. PoW
Est. energy use~0.01 TWh / year
POL
Polygon
POL (formerly MATIC)
✓ Proof of Stake

Polygon (now POL) uses a Delegated Proof of Stake (DPoS) mechanism. A set of validators stake POL tokens to participate in block production; token holders can delegate their stake to validators. The network does not use energy-intensive mining.

Polygon has committed to a carbon-neutral and green blockchain roadmap, and has published sustainability reports. Energy usage is a small fraction of PoW chains, comparable to Ethereum post-Merge. The POL token is the native asset of the Polygon PoS chain and is used for gas fees and staking.

ConsensusDelegated Proof of Stake
Energy profileLow — no mining hardware
SustainabilityCarbon-neutral commitment
TRX
TRON
TRX
✓ Delegated Proof of Stake

TRON uses Delegated Proof of Stake (DPoS), where 27 elected "Super Representatives" (SRs) produce blocks in rotation. TRX holders vote for SRs using staked TRX. The system is energy-efficient compared to PoW as there is no competitive computation.

TRON's energy consumption is minimal relative to PoW networks. The network uses a resource model (Energy and Bandwidth) that abstracts transaction costs — users freeze TRX to obtain resources rather than pay gas in a traditional sense. TRX's environmental footprint is considered low by industry standards.

ConsensusDelegated Proof of Stake
Block producers27 Super Representatives
Energy profileLow — no mining hardware
USDC
USD Coin
USDC — Multi-chain stablecoin
✓ Underlying chain dependent

USDC is a stablecoin, not a standalone blockchain. Its environmental characteristics are determined entirely by the underlying blockchain on which it is issued and transacted. Circle issues USDC natively on multiple networks including Ethereum, Solana, Avalanche, and others.

BitSpider supports USDC on the Ethereum, Polygon and TRON networks. Ethereum operates on Proof of Stake following The Merge (September 2022); Polygon and TRON both operate Delegated Proof of Stake. The environmental footprint of a USDC transaction through BitSpider is therefore that of the network selected, and in each case is low — none of the three uses mining hardware.

Clients transacting USDC on other networks should refer to the environmental profile of the relevant underlying chain. There is no independent energy footprint attributable to USDC itself — it inherits the characteristics of whatever chain it runs on.

Token typeE-money token (EMT)
Networks supportedEthereum · Polygon · TRON
Energy profileLow (inherits ETH PoS)
Section 03

Pricing methodology

How BitSpider constructs and applies exchange rates to client transactions, published in accordance with Article 77(2) of Regulation (EU) 2023/1114.

BitSpider deals as principal on its own account. It is the counterparty to every client transaction. It is not an agent, a broker or an executing venue, and it does not route client orders to any third party.

How the price is determined. When a client requests an exchange:

  1. BitSpider obtains the mid price for the relevant asset pair from Kraken, its principal liquidity provider, taken at the moment the request is received — the mid being the midpoint of the best bid and the best offer on that venue at that timestamp. Where the Kraken market for the pair is unavailable, or the spread on it is abnormally wide such that the mid is not a reliable reference, the reference rate is taken from Tatum, the fallback source, and the source used is recorded against the transaction.
  2. BitSpider applies its dealing spread to that reference price. The spread is BitSpider's remuneration and varies with the asset, the size of the transaction and prevailing market liquidity.
  3. The client is returned a firm, all-in price — the exact amount of one asset against the exact amount of the other, with the exchange rate applied and the net amount stated.
  4. That price is locked at the moment of quotation.

Between quotation and settlement the market risk is borne by BitSpider, not by the client. Whatever the market does in that interval, the client receives exactly what was shown on screen before confirming.

There is no separate commission. Because BitSpider deals as principal, its remuneration is the margin (spread) contained in the quoted price. No brokerage, commission, account or subscription fee is charged. Any charge levied in addition to the price — such as a blockchain network fee — is itemised separately and shown before the client confirms.

Non-discrimination. The method is applied uniformly. The same reference source and the same spread scale apply to every client of the same classification and transaction size. BitSpider does not vary its pricing by reference to the identity of the client.

The exchange rate applied, the service fee in both absolute and percentage terms, and the net amount receivable are displayed on screen before the client confirms any transaction, together with the confirmation that the rate and all applicable fees have been shown. The client may cancel at that point without charge.
Section 04

Post-transaction data

Information published and provided following execution, in accordance with Article 77(3) of Regulation (EU) 2023/1114.

What the client receives. Immediately on execution the client receives a confirmation recording the asset pair exchanged, the exact amounts sent and received, the exchange rate applied, the service fee in absolute and percentage terms, any blockchain network fee itemised separately, the receiving wallet address or bank account, the blockchain network used, and the transaction reference. The confirmation reproduces the figures shown at quotation.

Where the record is kept. Every transaction is recorded in the client's account on the BitSpider platform and remains available to the client there. Records are retained in accordance with BitSpider's Record-Keeping Policy and with the record-keeping obligations applying to crypto-asset service providers.

Aggregate transaction data. BitSpider publishes details of the transactions it concludes in the exercise of its exchange services, comprising the volumes and prices of those transactions, in aggregated form. Data is published on this page and refreshed periodically. Individual client transactions are not identified.

Publication status. Aggregate transaction volumes and prices will be published in this section. BitSpider does not operate a trading platform and does not maintain an order book; the transactions reported are those concluded by BitSpider as principal with its own clients.
Section 05

Exchange limits

Limits applicable to the amount that may be exchanged, published in accordance with Article 77(2) of Regulation (EU) 2023/1114.

The limits that apply are shown to the client before confirmation. Each quotation states the amount to be exchanged and the amount receivable, and a request that exceeds an applicable limit is not accepted at the point of quotation. Except as published here or set out in the client's own commercial terms, no fixed transaction limits apply.

Client-specific limits. Where a limit derives from a client's risk classification or from the activity that client declared at onboarding, rather than from the asset itself, it is set out in that client's commercial terms and applied at the point of quotation. Such limits are agreed during onboarding and communicated to the client.

Corporate clients only. BitSpider provides its services exclusively to legal persons acting in the course of a trade, business, craft or profession. It does not accept natural persons as clients.

Publication status. Minimum and maximum transaction values, stated by asset where they differ, will be published in this section. Clients are notified of any change to a limit applying to them before it takes effect.
Section 06

Conflicts of interest

The general nature and sources of conflicts of interest arising in BitSpider's business, and the steps taken to prevent, identify, manage and disclose them — published in accordance with Article 72(2) of Regulation (EU) 2023/1114.

1. BitSpider is the client's counterparty

BitSpider deals as principal on its own account, and its remuneration is the margin contained in the price it quotes. A wider margin favours BitSpider and disadvantages the client. Mitigation. Every price is quoted as a firm, all-in figure and locked before the client confirms, so the client sees the whole cost in advance and can verify it against the market at that moment. No charge is applied that has not been shown. Pricing is governed by the Non-Discriminatory Commercial Policy and dealing margins are reviewed by the compliance function.

2. Group and counterparty relationships

Certain counterparties and service providers may be connected to the wider group, and liquidity is sourced from a small number of external providers. Mitigation. Related-party arrangements are on arm's-length terms, entered in the conflicts of interest register and reviewed. Liquidity providers are counterparties to BitSpider's own book; client orders are never routed to or executed by them. Providers are subject to due diligence under the Outsourcing Policy and are recorded in the vendor register.

3. Personal interests of directors and staff

Personnel may hold crypto-assets personally or hold roles outside BitSpider. Mitigation. Personal account dealing restrictions apply. Outside interests and directorships are declared on appointment and on any change, and recorded in the register. Any person with a personal interest is excluded from deciding the matter. Remuneration is not linked to dealing margin or transaction volume.

4. Order handling and client information

BitSpider sees a client's trading intention before hedging its own position. Mitigation. The client's price is fixed at quotation, so any subsequent market movement falls on BitSpider and cannot change what the client pays. Trading on the basis of client information is prohibited under the Market Abuse Policy. Client information is restricted to those who need it.

Residual conflicts. Where a conflict cannot be prevented or managed such that the risk of damage to a client's interests is avoided, BitSpider discloses the conflict to the affected client, in a durable medium and in sufficient detail for that client to take an informed decision, before providing the service.

Governance. This disclosure mirrors §10 of BitSpider's Conflicts of Interest Policy and §9 of its Terms of Use. A conflicts of interest register is maintained by the compliance function, reviewed at least annually, and reported to the Management Board.

Contact. Concerns about a conflict of interest may be raised at compliance@bitspider.com. A client who is dissatisfied may also use the complaints procedure, which sets out the escalation route to Finantsinspektsioon.