Transparency
At RIV Digital, transparency is an operational principle.
In this section
RIV-Digital S.r.l. is authorized by CONSOB, after consulting the Bank of Italy, as a crypto-asset service provider (CONSOB Resolution no. 24030 of June 10, 2026 – Proceeding 187956/25) for the services referred to in Art. 3, paragraph 1, no. 16, letters c), d), and f) of Regulation (EU) 2023/1114 (LEI: 815600DCB0E8882D2314). The Company’s data is entered in the register of crypto-asset service providers maintained by ESMA pursuant to Art. 109 MiCAR.
Prices, costs, and fees
The cost of each exchange transaction from fiat currency to crypto-assets, from crypto-assets to fiat currency, and from crypto-assets to crypto-assets is calculated according to a clear, objective, and published methodology, rather than through a single fixed rate.
How the price is calculated
The final price of an exchange transaction (Pf) is determined by the RIV-PQM proprietary pricing engine according to the following formula, based on predetermined, automatic, and non-discretionary criteria:
Pf = MRP + Spread + Markup + Service Fee
In the event of a crypto-asset purchase by the client (Ask side), the three components are added to the MRP. In the event of a sale (Bid side), the same components are subtracted from the MRP, following a symmetrical logic: the price received by the client is therefore lower than the MRP.
Price components and their relative range
| Component | Range | How it is determined |
|---|---|---|
| MRP (Market Reference Price) | Not applicable | Weighted median of prices observed on at least three independent sources (currently the order books of Tier-1 exchanges Binance, Coinbase, and Kraken), with weights proportional to the immediately tradable liquidity on the pair. It is the reference market price and constitutes the calculation base for the percentages applied to the other components. |
| Spread | from 0.00% to 3.00% of the MRP (base value under ordinary conditions: not exceeding 1.50%) | Component covering the price and execution risk assumed by the Company as a direct counterparty. It is calculated automatically by the pricing engine and is not subject to negotiation or discretionary choice. |
| Markup | from 0.00% to 4.00% of the MRP | Component intended solely for the reimbursement of costs actually incurred by the Company for the execution of the transaction. It does not contain any service remuneration component. |
| Service Fee | according to the tiered fee schedule published below | Service fee, displayed separately in the quote, determined automatically based on the applicable volume tier. |
Factors determining the placement of the Spread within the range
The Spread is placed within the range based exclusively on the following quantitative parameters, detected automatically at the time of the quote:
| Factor | Effect on Spread |
|---|---|
| Realized volatility of the asset, measured over moving windows of 30, 60, and 120 seconds on the same market sources used for the MRP | Under ordinary conditions, the Spread remains within the base value of 1.50%. Upon exceeding the high volatility threshold, currently set at σ > 7% on the relevant window, an automatic increase is applied according to predefined thresholds. |
| Order book depth and available liquidity on the pair at Tier-1 sources | As available liquidity decreases, the Spread is automatically increased to reflect the greater risk of sourcing or disposing of the asset. |
| Order size relative to available market depth | If the requested volume exceeds 5% of the Average Minute Depth, a progressive Impact Factor is applied, with a linear increase in the Spread up to a maximum of +20 basis points. |
| Estimated settlement time on the reference blockchain, detected by the Company's nodes and infrastructure providers | Longer confirmation times and network congestion result in an increase in the Spread, within the maximum limit of 3.00%. |
| Client class | No impact. RIV Digital addresses a single category of clientele (retail clients) and does not differentiate the Spread based on the client. The only element of economic differentiation between clients is the volume tier applied to the Service Fee. |
The Markup is placed within the range exclusively based on the costs actually incurred for the individual transaction: network fees (gas fees) of the blockchain used, banking costs related to SEPA and SEPA Instant transfers, infrastructure security costs, technical settlement, and reconciliation. None of these items are subject to discretionary assessment: they are acquired as source data and allocated to the individual transaction according to objective, uniform, and ex-post verifiable internal criteria.
All variations applied to the price based on volatility and volume are tracked on audit logs and are verifiable ex-post. The price is communicated to the client before confirmation through a binding quote (RFQ) valid for 30 seconds: once confirmed by the client within this period, the quote cannot be unilaterally modified by the Company, and any subsequent changes in market conditions or hedging costs remain the exclusive responsibility of RIV Digital.
Fee Schedule
The Service Fee is structured by volume tiers, as indicated in the following table.
| Volume tier per single transaction | Service Fee | Notes |
|---|---|---|
| up to €500 | 1.90% | Basic Retail |
| from €500 to €5,000 | 1.40% | Intermediate Retail |
| from €5,000 to €50,000 | 0.90% | High volume / business |
Calculation examples
| Example | MRP | Spread | Markup | Service Fee | All-in cost / Net |
|---|---|---|---|---|---|
| 1) Purchase of €500 of BTC (fiat → crypto) | €500.00 | 2.00% (€10.00) | 1.50% (€7.50) | 1.40% (€7.00) | Total charged to the client: €524.50 (~ 4.9%) |
| 2) Purchase of €10,000 of USDC (fiat → crypto) | €10,000.00 | 1.00% (€100.00) | 0.50% (€50.00) | 0.90% (€90.00) | Total charged to the client: €10,240.00 (~ 2.4%) |
| 3) Sale of €30,000 of ETH (crypto → fiat) | €30,000.00 | 1.50% (€450.00) | 1.00% (€300.00) | 0.90% (€270.00) | Amount transferred to the client: €28,980.00 (~ 3.4%) |
Any additional costs
The components described above—Spread, Markup, and Service Fee—constitute the total costs applied by the Company for the provision of the exchange service.
The network fees (gas fees) of the blockchain used and the banking costs related to SEPA and SEPA Instant transfers do not constitute an additional cost for the client: they are already fully included in the Markup component displayed in the quote (RFQ) and are not charged a second time.
Only the following charge remains the responsibility of the client, as a third-party item not retained by the Company:
- fees applied by the beneficiary bank or correspondent banks in the event of fiat currency transfers to accounts held at foreign banks not belonging to the SEPA area. These fees are applied directly by the banking institutions involved, are neither determined nor retained by RIV Digital, and are communicated to the client, in their estimated amount, during the quoting process (RFQ) before the transaction is confirmed.
There are no costs for opening, maintaining, or closing the relationship with RIV Digital. The complaint management service is free of charge.
Operational limits
A maximum limit per single transaction and a cumulative limit for the total transactions carried out by the client apply to exchange operations.
- Limit per single transaction: €50,000. The limit is applied to each exchange transaction, regardless of the direction (fiat/crypto, crypto/crypto).
- Cumulative limit: €2,500,000 per month per client. In addition to the maximum limit of €50,000 per single transaction, a cumulative limit applies which includes the total of all transactions carried out by the client in the reference period indicated in the internal procedures. This limit is set at €2,500,000 per month per client. Any changes will be communicated with at least 15 days’ notice.
The limit may be modified by the Company based on risk assessments (e.g., market volatility, client rating, AML evidence). Changes are communicated to clients with at least 15 days’ notice via (i) in-app notification, (ii) email to the declared address, and (iii) publication on this Transparency Hub, and apply to transactions following the effective date.
Conditions for finality of transactions
An exchange order is considered final only upon the joint occurrence of all the conditions indicated below:
- Acceptance by the client of the quote (RFQ) within the 30-second validity period from receipt; beyond this period, the quote expires and a new RFQ must be requested.
- Availability of sufficient funds (fiat or crypto) in the client’s account for the execution of the transaction, including the Spread, Markup, Service Fee, and any pass-through components.
- Positive outcome of real-time AML/KYC checks on the transaction (sanctions/PEP screening, on-chain KYT on counterparties, Travel Rule where applicable).
- Technical consistency of the network and the selected fees.
Examples of NON-final orders: quote expired beyond 30 seconds; insufficient funds; AML/KYT alert resulting in a hold or block; on-chain counterparty not compatible with the Travel Rule; unsupported blockchain network. In such cases, the transaction is automatically rejected and any funds credited are refunded to the sender within 24 hours.
Risk warnings
Investing in crypto-assets involves significant risks. Before operating, the client must read, understand, and accept the following warnings.
- Price volatility: the value of crypto-assets can undergo significant and rapid changes, even within a few hours, in relation to macroeconomic, technological, liquidity, and market sentiment factors.
- Possible total loss of capital: the client may lose the entire invested capital. No return is guaranteed.
- Absence of guarantees and compensation schemes: crypto-assets are not covered by the Interbank Deposit Protection Fund or other investor compensation schemes (SICAV) provided for traditional financial instruments.
- Technological and network risks: blockchain malfunctions, network congestion, delays in transaction confirmation, address errors (address/memo), interruption of cloud services, or cyber-attacks may prevent or delay the execution of transactions.
- Self-managed custody risks: RIV Digital operates on a non-custodial model. The private keys of the RIV Wallet or the client’s compatible wallet remain in their exclusive possession: the loss, theft, or compromise of the keys results in the permanent loss of the crypto-assets, with no possibility of recovery by RIV Digital.
- Liquidity risks: the availability of quotes and the possibility of executing transactions in certain crypto-assets may decrease under market stress conditions.
- Regulatory and tax risks: the regulatory framework for crypto-assets may evolve and lead to operational restrictions, tax obligations, or changes in the qualification of assets.
Complaint management
Clients may submit a complaint free of charge. RIV Digital handles every complaint according to the internal procedure adopted pursuant to Art. 71 MiCAR and communicates the outcome to the client within the timeframes indicated below.
Complaint management
To whom the complaint is addressed
Complaints are addressed to the Complaints Office of RIV-Digital S.r.l., established within the Legal & Compliance Function, which is outsourced to LX20 Law Firm S.r.l. STA. The person responsible for complaint management is Mr. Alessandro Negri della Torre, Esq., appointed pursuant to Article 2 of Delegated Regulation (EU) 2025/294, who operates with autonomy and impartiality and reports directly to the Company’s management body. Correspondence regarding the complaint should be addressed to: RIV-Digital S.r.l. – Complaints Office, for the attention of the Head of Complaint Management.
What constitutes a complaint
A complaint is any formal statement, submitted in writing, by which a client or potential client—or a person representing them—expresses dissatisfaction to the Company regarding one or more crypto-asset services provided, and which jointly meets the following admissibility requirements:
- it is formulated in writing and transmitted through one of the channels indicated below;
- it is addressed to RIV-Digital S.r.l.;
- it is submitted by the client or potential client, or by their legal representative or special proxy, attaching in such case the power of attorney or other document certifying their appointment;
- it alleges an actual or presumed irregularity or a breach by the Company—with respect to regulations, contractual provisions, or internal procedures—in the provision of the service;
- it contains a specific claim, including at least a potential indication of the economic prejudice complained of;
- it is drafted in Italian or English, the only two permitted languages.
What does not constitute a complaint
The following are not treated as complaints and will receive a response according to ordinary customer support procedures:
- expressions of dissatisfaction made orally, including by telephone, without written form;
- requests for information, opinions, or clarifications;
- requests for the sending or release of documentation;
- critical observations, suggestions, and reports not accompanied by a specific request for a remedy.
If the communication received does not meet the admissibility requirements, the client is informed in writing, with an indication of the reasons. If the complaint is admissible but incomplete, the Company will request the necessary integrations from the complainant, without prejudice to the registration of the complaint on the date of first receipt.
Information that the complaint must contain
The complaint may be submitted in free form, but it must contain all the information required by the template annexed to Delegated Regulation (EU) 2025/294. The use of the standard template downloadable below, which reproduces all such fields, is recommended:
| Template section | Information required |
|---|---|
| 1.a - Information on the complainant | Surname or name of the legal entity; first name; EUID or, if not available, national registration number or national identity document number; Legal Entity Identifier (LEI), if available; client reference, if available; address (street, house number, floor; for legal entities, registered office); postal code; city; country; telephone; email address. |
| 1.b - Contact details, if different | Surname or name; first name; address; postal code; city; country; telephone; email address. |
| 2.a and 2.b - Legal representative, if applicable | The same identification and contact data of the representative, together with the registration number and LEI if available. The power of attorney or other official document proving the appointment must be attached. |
| 3.a - Service reference | Full reference of the crypto-asset service to which the complaint relates: name of the provider, service reference number, or other relevant transaction references. |
| 3.b - Subject of the complaint | Description of the subject of the complaint, with documentation attached in support of the reported facts. |
| 3.c - Date of the facts | Date or dates of the facts giving rise to the complaint. |
| 3.d - Damage complained of | Description of the damage, loss, or prejudice caused, if relevant. |
| 3.e - Other information | Other relevant observations or information, if applicable. |
| Signature | Place, date, and signature of the complainant or their legal representative, with an indication of the attached documentation. |
How to submit a complaint
- Electronic form: by filling out the form available on this page, which reproduces the fields of the standard template.
- Certified Electronic Mail (PEC): riv-academy@pec.it
- Ordinary email: reclami@riv-digital.it
- Registered mail with return receipt: RIV-Digital S.r.l. – Complaints Office, Via Luigi Dalla Via 3/B, 36015 Schio (VI), Italy.
- Permitted languages: Italian and English. The response is provided in the same language used by the complainant.
Processing times
| Phase | Deadline |
|---|---|
| Acknowledgment of receipt of the complaint | Without delay and in any case within 7 calendar days of receipt, with an indication of the identification number assigned to the complaint, the expected deadline for the response, and the contact details of the person responsible for management. |
| Communication of the final outcome | As soon as possible and in any case within 60 days of receipt of the complaint. |
| Extension in exceptional cases | Only in exceptional and documented situations where the decision cannot be adopted within 60 days, the complainant is informed in writing, before the deadline, of the reasons for the delay and the new estimated deadline. |
Content of the response
The response is transmitted in writing, by the same means used by the complainant and, upon their express request, in paper form. It contains: a summary of the complaint; the outcome of the investigation and the relative reasons; an indication of whether the complaint is accepted, partially accepted, or rejected; any corrective measures adopted and the estimated implementation times; the remedies available in case of dissatisfaction; the contact details of the Legal & Compliance Function.
Available remedies
In the event of failure to respond within the deadlines or an unsatisfactory response, the client may contact the alternative dispute resolution (ADR) bodies competent under the applicable legislation and Article 122 of MiCAR, submit a report to the competent authority—CONSOB, Via G.B. Martini 3, 00198 Rome—and in any case bring the matter before the competent Judicial Authority.
Retention
Every complaint is recorded in a specific electronic register and kept, together with all related documentation, for at least ten years from the closing of the file.
Conflicts of interest
General nature of conflicts
Potentially relevant conflicts of interest in the Company’s activities may arise, but are not limited to:
- The Company’s membership in the RIV Capital Group, which includes entities operating as issuers of crypto-assets (RIV Capital Algo Fund Limited – issuer of RIV Coin) and providers of technological services (RIV Technologies FZE).
- Proprietary trading activity (Principal Desk) carried out by the Company as a direct counterparty to the client, with a potential misalignment of interests with respect to client orders.
- Personnel remuneration policies, which could incentivize behaviors not aligned with the interests of the clientele.
- Commercial relationships with third-party providers (banks, liquidity providers, custodians) and with individuals holding multiple roles within the Group.
Sources of conflicts
- Provision of services for crypto-assets issued by Group entities.
- Receipt or payment of incentives from third parties.
- Personal or professional relationships of members of the corporate bodies.
- Use of confidential information acquired in the exercise of the activity.
Mitigation measures
- Conflict of Interest Officer (COI Officer): appointed by the Board of Directors, with powers of direct access to information, reports at least annually to the Board and the Sole Auditor.
- Conflict of interest register: identification, evaluation, and traceability of every conflict detected.
- Segregation of roles: those who propose a transaction do not approve it; those who approve do not sign. Personnel dedicated to customer service are separate from those who manage proprietary inventory.
- Treatment of intra-group crypto-assets: same selection and admission procedures applied to any third-party issuer; no preferential treatment; transparent disclosure to the client before any placement operation of assets issued by the Group.
- Dedicated training: specific modules for personnel involved in activities with potential conflict (in particular before the placement of intra-group crypto-assets).
- Remuneration policy: structured to avoid incentives misaligned with the interests of the clientele.
- Communication to clients: where the conflict cannot be neutralized through organizational safeguards, prior and complete communication is given to the client.
Crypto-asset white papers
For crypto-asset exchange and placement services, each asset traded is accompanied by its relative white paper. Hyperlinks to the published white papers are available below and are updated every time a new crypto-asset is admitted.
| Crypto-asset | MiCAR Qualification | Issuer | White paper |
|---|---|---|---|
| USDC (USD Coin) | E-money token (EMT) | Circle Internet Financial Europe SAS | MiCAR White Paper |
Environmental sustainability indicators
| Crypto-asset | Consensus mechanism | Annual energy consumption (kWh) (mandatory) | GHG emissions (tCO₂eq) (suppl.) | Source / methodology |
|---|---|---|---|---|
| USDC (Ethereum) | Proof-of-Stake | ~ 210,000 kWh/year | ~ 72 tCO₂eq/year | CCRI – Ethereum Merge Impact Report |
Executed transactions
Pursuant to Art. 77, paragraph 4, of Regulation (EU) 2023/1114, RIV Digital publishes information relating to executed exchange transactions. The data is made available in tabular format and includes, for each transaction: trading pair, price, volume, and execution time.
The publication of data will be active from the start of operations.
| ID | Execution date and time (CET) | Pair | Price | Volume | Notional value (EUR) |
|---|---|---|---|---|---|
| — | — | — | — | — | — |
RIV-Digital S.r.l.
Sede legale: Via Luigi Dalla Via 3 B, 36015, Schio
Registro delle Imprese di Vicenza – REA VI-414981
Codice Fiscale/P. IVA: 05421350280
Capitale sociale: € 300.000,00 interamente versato
LEI: 815600DCB0E8882D2314
- Via Luigi Dalla Via 3 B, 36015, Schio, Vicenza, Italy
- +39 345 6166057
- Info@riv-digital.it
- PEC: riv-academy@pec.it.
RIV-Digital S.r.l. — Authorized by CONSOB as a crypto-asset service provider (Resolution no. 24030 of June 10, 2026).
Activity subject to the supervision of CONSOB (Italian Companies and Exchange Commission), Via G. B. Martini 3, 00198 Rome – www.consob.it.
© Copyright 2026 RIV-Digital S.r.l. All Rights Reserved.