Transaction Execution and Order Handling Policy

Purpose

Kriptomat is committed to executing client orders with fairness, transparency, and efficiency. This policy outlines how client orders are submitted, validated, routed, and executed, in full alignment with the Markets in Crypto-Assets Regulation (MiCAR) and industry best practices.

This is a public extract of Kriptomat’s internal policy, provided to ensure transparency for clients and stakeholders.#

Scope

This policy applies to:

• All client instructions to buy, sell, or exchange crypto-assets via Kriptomat’s platform.
• All services, channels, and automated systems used to process those transactions.
• All employees and contractors involved in the transaction lifecycle.

Core Principles

Best Execution

Kriptomat takes all sufficient steps to ensure the best possible result for clients, based on:

• Price
• Transaction cost
• Speed
• Likelihood of execution
• Liquidity depth
• Settlement reliability

Client Verification

Only verified users who meet our KYC/AML standards and who have successfully completed appropriateness or suitability assessments, are permitted to place orders.

Order Handling

Orders are submitted via our web or mobile platform and processed by our secure Order Handling System (OHS). Each order is:

• Time-stamped and acknowledged
• Validated for account and balance status
• Routed securely via API to Liquidity Providers
• Rejected with notification if it fails any criteria

Orders are either fully executed or cancelled; partial execution is not permitted unless explicitly allowed in future product features.

Liquidity Providers

We work with external Liquidity Providers to execute trades. We periodically review execution arrangements and liquidity provider performance to ensure consistent best execution..

Transparency for Clients

• Pricing: Clients see the full price (including spreads) before confirming any transaction.
• Limits: Minimum and maximum trade sizes are disclosed in our interface.
• Execution Confirmations: Once executed, clients receive full transaction details, including timestamp, fees, and asset movement.
• No partial fills: Orders must be filled completely, or they are cancelled.

Order Types

Instant – order is handled at the market price available at the moment the order is placed with most accurate price estimation.

Set price – the order is executed at the fixed price selected by the user, when and if selected price is reached. Live market price estimate is displayed to the user for guidance.

Recurring order (DCA) – the order is executed at time intervals set by the user, in the amount of euro selected by the user, without reference to the specific asset price at the future time of purchase. The following applies to this type of order: 

• Execution price is not known at the time the standing instruction is set up. The execution price for each individual order is determined at the time of the scheduled trigger, based on the prevailing market price and applicable spread at that moment.
• Best execution apply to each individual execution event. The Company takes all sufficient steps to obtain the best possible result for the Client at the time of each scheduled execution. The Company is not required to seek a specific price outcome beyond obtaining the best available market price at the time of routing.
• The Client may cancel or modify a standing recurring instruction at any time before the next scheduled execution trigger. Once a scheduled execution has been initiated, it follows the same order handling and finality rules as a standard market order.

If special instructions (e.g. limit pricing) cannot be met, the order is cancelled and the client is notified.

Order Finality

An order is considered final and irrevocable at the following points, depending on order type:

• Instant orders: The order becomes final upon submission and acceptance by the OHS. Once accepted and routed to the Liquidity Provider, the order cannot be cancelled by the Client.
• Set price orders: The order becomes final when the trigger price is matched and the order is routed to the Liquidity Provider for execution. Prior to the trigger price being reached, the Client may cancel the pending instruction through the platform interface.
• Recurring orders (DCA): Each individual scheduled execution becomes final at the moment the trigger fires and the order is routed to the Liquidity Provider. The standing recurring instruction itself may be cancelled or modified by the Client at any time before the next scheduled trigger.

Conflicts of Interest

Kriptomat:

• Discloses any relevant relationships with liquidity providers.
• Uses automated systems to prevent manual price manipulation or order interference.
• Prohibits insider trading, front-running, or other abusive behaviour and prohibits employees from accessing or using confidential order flow information for personal gain.

Monitoring & Oversight

Our operations, compliance, and IT teams continuously monitor:

• Platform stability
• Spread anomalies
• Execution quality
• Compliance with MiCAR

Incidents or anomalies are and may be reported to local regulators (FIU, EFSRA) if required or needed.

Need Help?

For more information or concerns about your transaction execution, please contact our support team at [email protected]