Crypto versus TradFi information channels

TradFi Inside Information needs to be communicated Under Art. 17 MAR, a securities issuer must inform the public of inside information enabling fast, complete and correct assessment by the public. MAR disclosure is built around established information rails, including regulated disclosure channels and, where applicable, the officially appointed mechanisms (OAMs) under the Transparency Directive. E.g., the German OAM is the official corporate register "Unternehmensregister" by Bundesanzeiger. That model matches a typical TradFi investor expectation to find material information through professional market-data services, regulated announcements, and mainstream financial media.

Art. 88 MiCAR follows a similar disclosure logic as MAR. However, it does not replicate the Transparency Directive’s architecture of mandating OAMs. A crypto investor would not look up the "Unternehmensregister" for information. Instead, the relevant ITS - Implementing Technical Standards - expressly recognise that inside information may need to be disseminated through social media and web-based platforms „when they appear to be the media which are reasonably relied upon by the public“. 

The ITS further require any social-media or web-based disclosure to include a link back to the disclosing party’s website statement (publication on the own website remains required). This creates a dual-channel model: a compliant primary disclosure record on the website and a market-facing amplification layer across crypto-native channels that the relevant public actually uses in crypto markets. 

The typical crypto investor is used to DYOR (do your own research) and tends to rely on a mix of project websites, X, Telegram, Discord, and other online community sources rather than traditional financial information rails. Disclosures therefore need to use these channels to provide information where the market typically consumes information: across decentralized, web-native, and social media channels.

👉 Compliance consequences

Social media posts and web-based platforms are de facto "reasonably relied upon" in the crypto space, but its use for regulated communication also creates a major evidentiary problem: those platforms can delete accounts, remove individual posts, or alter visibility at any time, while the disclosing party remains responsible for demonstrating compliance for years afterwards. Parties obliged to proper disclosure need a durable compliance record for future supervisory review. 

💡 This created the call for a new inside-information disclosure services: to bridge the gap between unregulated and fragmented dissemination channels and long-term proof of compliance. A proper control layer must preserve the exact content disclosed, timestamp, distribution channels used, so the firm can later demonstrate that the disclosure was public, timely, and complete.

That is the gap DAAvern addresses!