MiCA Article 92 market-abuse surveillance — what CASPs must do
Under Article 92 of MiCA (Regulation (EU) 2023/1114), every crypto-asset service provider must have systems and procedures to prevent, detect and report market abuse. With full authorisation due by 1 July 2026, supervisors expect a demonstrably working surveillance system — not a policy document. This guide covers the behaviours you must monitor, the reporting obligation, and what a credible system looks like.
What Article 92 requires
CASPs operating a trading platform — and, more broadly, any CASP handling client orders and trades — must establish and maintain effective arrangements, systems and procedures to prevent and detect market abuse, and to report suspicious orders and transactions to their national competent authority. MiCA deliberately mirrors the Market Abuse Regulation (MAR) that governs traditional markets, so the detection bar is comparable to a regulated exchange's.
The behaviours you have to detect
| Pattern | What it looks like on the tape |
|---|---|
| Wash trading | The same beneficial owner on both sides of a trade — no real change of ownership. |
| Spoofing | Large orders placed away from the touch and cancelled before execution to mislead. |
| Layering | Multiple non-bona-fide orders at several price levels, then cancelled. |
| Marking the close | A participant dominating volume in the closing window to move the reference price. |
| Momentum ignition / ramping | Aggressive buying to start a price move, then reversing into the crowd. |
| Insider dealing & unlawful disclosure | Trading or tipping ahead of inside information about a crypto-asset. |
The reporting obligation (STOR)
When your monitoring flags activity that might constitute market abuse, your compliance officer assesses it and, if suspicion is confirmed, files a Suspicious Transaction and Order Report (STOR) with the competent authority without delay. A working system therefore needs not just detection but triage and a draftable, auditable report trail — supervisors will ask to see both the alerts you raised and the ones you dismissed, with reasons.
What a credible system needs
- Ingestion of your full order and trade tape (placements, cancellations, executions);
- Explainable detection rules mapped to MiCA Art 92 / MAR Art 12 behaviours;
- Alert triage with severity and analyst disposition;
- STOR drafting and an audit trail a supervisor can inspect;
- Evidence the system actually runs — a clean monitoring run is itself proof of an operating Article 92 system.
Scan your tape for market abuse — free
Run the free surveillance scan →This guide is general information, not legal advice. Confirm the current requirement against MiCA (Regulation (EU) 2023/1114), the relevant RTS, and your national competent authority before you rely on it.