Comparison matrix: Art. 88 MiCAR vs. Art. 17 MAR, and Transparency Directive OAM framework

MiCAR, MAR, and the Transparency Directive all deal with inside information disclosure architecture, but they do not use the same publication infrastructure. 

MiCAR relates to crypto-assets while MAR relates to financial instruments (including those in tokenized form). MiCAR replicates much of the MAR disclosure logic on speed, accessibility, completeness, no-marketing bundling, website posting, and delayed-disclosure notification, but it does not transplant the securities-market OAM infrastructure into crypto-asset market abuse law. Hence, one of the most important structural differences of both inside information disclosure regimes is that Art. 17 MAR expressly links public disclosure of inside information to the "officially appointed mechanism" (= OAM) under Art. 21 of the Transparency Directive, while Art. 88 MiCAR does not. 

The Transparency Directive is different again because it is not itself an inside-information rule. Its OAM architecture is a storage-and-access layer for regulated information disclosed by listed companies, with each Member State required to establish at least one such mechanism and ESMA providing the Union-level access point/list. Link to the respective ESMA register for OAMs: ESMA OAM Register: https://www.esma.europa.eu/publications-and-data/databases-and-registers -> click on "Corporate reporting (Transparency Directive)"

This means that OAMs are part of the MAR/Transparency Directive ecosystem for securities markets, but they are not built into MiCAR’s market-abuse disclosure rules for crypto-assets. In summary: MiCAR opted for a simpler, direct, multi-channel disclosure model for crypto-asset markets.

This is what DAAvern is being built for: A neutral, tamper-resistant disclosure reference layer that takes organizations from obligation to compliance – in a single workflow, with a permanent record at every stage.

Pure facts, on-chain verifiable. Reach out for further information.