EU - Non-discriminatory commercial policy and pricing policy for the crypto-asset exchange service

Last updated: March 10, 2026

Last updated: March 2026

1 Introduction and regulatory context

CROSSMINT EUROPE, S.L (hereinafter “Crossmint” or the “Entity”) is a crypto-asset service provider registered in the official register of the Spanish National Securities Market Commission (“CNMV”) under number [*], authorized, among other activities, to provide execution of orders related to crypto-assets on behalf of clients.

The regulatory framework applicable to companies providing crypto-asset services—particularly Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, amending Regulations (EU) No. 1093/2010 and (EU) No. 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 (hereinafter, “MiCA”), and Commission Delegated Regulation (EU) 2025/305 of 31 October 2024, supplementing Regulation (EU) 2023/1114 as regards regulatory technical standards specifying the information to be included in the application for authorization as a crypto-asset service provider—provides that entities offering crypto-asset services, when exchanging crypto-assets for funds or other crypto-assets (“Exchange”), must comply with a number of obligations.

These obligations include the establishment of a non-discriminatory commercial policy specifying the types of clients accepted and the conditions they must meet, the publication of a firm price for the exchange or the method used to calculate such price, as well as any applicable limits on the amount to be exchanged, and the execution of client orders at the published price at the moment the order is considered firm. In addition, providers must make transaction information publicly available, including volumes and prices.

With regard to the policies and procedures of crypto-asset service providers in relation to exchange services, given that one of the main foundations of the exchange service is the ability to set a price for each crypto-asset, the Entity has also included in this document a procedure for calculating and determining prices, which will be made available to clients.

Accordingly, in order to comply with the above-mentioned obligations, the Entity has prepared this document containing the Non-Discriminatory and Pricing Policy (hereinafter, the “Policy”).

2 Scope of application

This Policy is essential to ensure compliance with the legal and regulatory requirements applicable to the provision of crypto-asset exchange services, as well as to safeguard the security, transparency and protection of Crossmint’s clients’ rights.

Accordingly, this document establishes the guidelines for the pricing policy and the non-discriminatory commercial policy that will govern Crossmint’s operations.

The obligations set out in this Policy apply to all directors, officers, employees and, in particular, persons directly or indirectly involved in the provision of exchange services (hereinafter, the “Subject Persons”). This Policy applies to the determination of prices for the crypto-assets handled by Crossmint.

The Entity undertakes to provide its services in a non-discriminatory manner to clients who meet the conditions set out in this document. This includes:

  • Retail clients (natural persons).

  • Institutional clients and companies (legal entities).

  • Any other clients that Crossmint may include from time to time.

3 Conditions for accessing the services

Crossmint provides its crypto-asset services to all clients, both natural persons and legal entities. As a basis for the provision of Crossmint’s services in general, and prior to accessing them, the following common rules have been established and apply to all types of clients, without prejudice to the existence of specific requirements in certain cases, for example based on Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) risk considerations. These may result in limitations or restrictions for certain clients, as permitted under applicable AML/CFT regulations and Crossmint’s internal procedures in this area.

In this regard, crypto-asset service providers performing exchange of crypto-assets for funds or other crypto-assets must establish a non-discriminatory commercial policy that includes, in particular, aspects such as the types of clients with whom they accept to conduct transactions and the conditions that those clients must meet. In particular:

  • Crossmint provides its services to both natural persons of legal age and legal entities as clients. All clients must have successfully completed the required verification processes.

  • All users must pass AML/CFT screening procedures, in accordance with the client onboarding policy. This process includes identity verification (KYC) and any other due diligence measures applicable depending on the client’s risk profile.

  • Clients will be clearly informed in the terms and conditions of the services about all fees applicable to specific transactions before carrying out any operation.

  • Registration and access to crypto-asset services are provided free of charge. Notwithstanding the above, where Crossmint services are accessed through a partner platform or application, the relevant partner may apply an additional fee.

  • Crypto-asset services are offered exclusively through digital channels. This ensures an integrated and efficient user experience, allowing access to crypto-asset services at any time and from any location with internet access.

4 Pricing

In accordance with MiCA and regarding exchange activities, the Entity will inform its clients of:

  • The conditions under which an order becomes firm.

  • The firm price fixed before the transaction, which may not vary at execution; or, where applicable, the method for determining the price and any limits applicable to the amount to be exchanged as determined by the Entity.

With respect to the application of this Policy to the aforementioned services, the following considerations must also be taken into account:

  • The Entity has the freedom to set prices without the obligation to guarantee best execution. This allows it to offer competitive market prices or, in certain circumstances, prices that may penalize the client.

  • The Entity must use its own funds to cover exchange operations, thereby ensuring availability and speed in the execution of transactions.

  • The Entity has the freedom to set the commissions applicable to exchange transactions, allowing flexibility in the fee structure to adapt to market conditions and client needs, in accordance with its publicly available fee policies.

  • The Entity will publish information regarding executed transactions, including transaction volumes and prices.

5 Method for Determining the Price

Prices for the Exchange service are calculated as follows:

  • When a client wishes to carry out a transaction offered by the exchange service, they indicate which crypto-assets they want to buy, sell, or exchange, as well as the amount.

  • The Entity obtains the price in real time. This price is estimated by observing not only the current quotation of the crypto-asset but also the liquidity available at that moment.

  • The Entity adds the commission for the service and displays to the user the final price the user will pay for the crypto-asset, as well as the added commission. This price remains fixed for 10 seconds, after which it is updated again.

  • If the user accepts the transaction, the crypto-assets involved are credited at the fixed price.

  • In parallel, the Entity proceeds to buy and/or sell the necessary quantities of crypto-assets to ensure that it holds sufficient funds on its balance sheet to continue offering the service to other users.

Crossmint primarily offers asset exchanges in stablecoins, specifically USDC and EURC, which maintain a 1:1 peg with the U.S. dollar and the euro, respectively. For other crypto-assets that Crossmint may offer, Crossmint will use price oracles from services such as CoinGecko and CoinMarketCap, which provide APIs that aggregate market prices for individual assets across a wide range of platforms. These services are standard sources of asset price data in the industry.

6 Volatility risk mitigation

Crossmint adopts measures to mitigate risks arising from price volatility, including:

  • Limited time windows to confirm prices: The price shown to the client is subject to confirmation within a specified period (10 seconds).

  • Quantity limits: Depending on the crypto-asset and its liquidity, the Entity establishes maximum thresholds beyond which users cannot buy or sell.

  • Spread: A fee added to the price to compensate for price movements that may occur depending on market conditions and liquidity.

7 Transparency and execution of the transaction

Fees are determined transparently and communicated to the client in advance. Before carrying out a transaction, the client will receive:

  • The base price of the crypto-asset.

  • The applied commission and its breakdown (operational costs, profit, risk premium).

  • The final price, including all applicable components.

Once the client confirms the transaction details and the order, Crossmint proceeds with execution once the exchange order becomes firm.

An exchange order will be considered firm when:

  • The client has confirmed their intention to proceed with the exchange.

  • The necessary funds or crypto-assets are available in the client’s account.

  • All required verification requirements have been fulfilled.

Clients will be notified when their exchange order is considered firm, and Crossmint commits to providing continuous and transparent access to information regarding the status of their exchange orders.

8 Approval, entry into force, and update of the policy

This Policy must be approved by the Entity’s Board of Directors and will enter into force on the date of its approval.

The Policy will be updated and/or modified, at minimum, in the following cases:

  • When legal or regulatory changes occur that affect the Policy.

  • Upon proposal from Compliance or the Internal Audit Function, when they determine that certain sections could be improved to achieve the proposed objectives or to properly adapt to the characteristics of the services offered by the Entity at any given time.

  • Upon proposal from the Product Department.

  • Upon proposal from supervisory authorities.

In any case, the Compliance function is authorized to issue any internal circulars or procedures it considers necessary to develop the content of this Policy or clarify any doubts that may arise in its practical application.

This supporting documentation will be communicated to all Persons Subject to the Policy and will be duly archived by Compliance.

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