Dismissal of the internal order book and of limit and conditional orders, transition to the model for the execution of orders on behalf of clients pursuant to article 78 of MiCAR.

Preliminary Remarks

1.1 Young Platform S.p.A. (hereinafter “Young Platform” or the “Company”) issues this notice (the “Notice”) to inform its clients of the evolution of the operating model of the Young Platform Pro platform, accessible at pro.youngplatform.com, in accordance with the regulatory framework set out in Regulation (EU) 2023/1114 (MiCAR), Legislative Decree No. 129 of 8 November 2024 and the related delegated and implementing acts.

1.2 In particular, this Notice sets out: (a) the operating status of the Young Platform Pro platform up to 30 June 2026, based on the availability of an internal order book and on limit and conditional (stop) order types matched internally; (b) the structural changes to the operating model that take effect starting today, 1 July 2026, following the maintenance window of 30 June 2026 — 1 July 2026, aligning the Service with the new MiCAR framework; (c) the practical consequences of the changes for the Client in terms of available order types, management of open orders, price formation mechanics and execution of transactions.

1.3 This Notice is made available through the Company’s official channels and constitutes a service communication. It does not constitute a marketing communication nor an offer or solicitation to invest. It does not constitute investment advice, tax advice or a personalised recommendation.

Identification of the Provider

Name: Young Platform S.p.A. Registered office: Via Cigna 96/17, 10155 Turin (TO), Italy. Tax code, VAT number and registration number with the Turin Companies Register: 11931440017. Certified email (PEC): [email protected]. Institutional website: youngplatform.com
Authorised as a crypto-asset service provider (CASP) by Consob and Banca d’Italia on 30/06/2026 pursuant to article 16, paragraph 1, of Legislative Decree 129/2024 and article 63 of Regulation (EU) 2023/1114.

Definitions

For the purposes of this Notice, the following terms shall have the meanings set out below:

• “MiCAR”: Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets;
• “Crypto-asset”: a digital representation of value or of rights which can be transferred and stored electronically using distributed ledger technology or similar technology, within the meaning of article 3(1)(5) MiCAR;
• “Execution of Orders on Behalf of Clients”: the conclusion of agreements to buy, sell or subscribe for one or more crypto-assets, or to subscribe for one or more crypto-assets, on behalf of Clients, within the meaning of article 3(1)(18) MiCAR;
• “Young Platform Pro” or “Pro” or “Pro Platform” or “Journey Pro”: the platform owned by the Company, accessible at pro.youngplatform.com, through which the Execution of Orders on Behalf of Clients pursuant to article 78 MiCAR is provided, under the intermediation (Agent) operating model;
• “internal Order Book”: the internal electronic register of open and valid buy and sell orders, ranked by price and time of submission, used up until the go-live of the new operating model for the automatic matching of orders of different Clients on the Pro Platform;
• “External Execution Venue”: the authorised trading platform, multilateral trading system, systematic internaliser, qualified counterparty or any other venue to which the Company routes the Client’s order in the performance of the Service under article 78 MiCAR, in accordance with the Execution Policy adopted by the Company;
• “Smart Order Router” or “SOR”: the Company’s application module which, upon receipt of a Client’s order on the Pro Platform, performs the ex-ante qualification of the order under article 78 MiCAR and routes it to the selected External Execution Venue on the basis of the criteria set out in the Execution Policy;
• “Execution Policy”: the Best Execution Policy adopted by the Company pursuant to article 78 MiCAR (Best Execution), which sets out the criteria for selecting External Execution Venues and the execution factors (price, overall costs, speed, likelihood of execution and settlement, size and nature of the order);
• “Market Order” (market order): an instruction from the Client to buy or sell a crypto-asset at the best price available at the selected External Execution Venue, with immediate execution;
• “Limit Order” (limit order): an instruction from the Client to buy or sell a crypto-asset only where the execution price is equal to or better than a threshold price specified by the Client;
• “Conditional Order” (stop, stop-loss, stop-limit): an instruction from the Client that becomes active upon the occurrence of a specified price condition, subsequently transmitted as a market or limit order in accordance with the instructions given;
• “Open Order”: a buy or sell order submitted by a Client on the Pro Platform and not yet executed, expired or cancelled at the effective date of the changes referred to in this Notice.
• “Liquidity Viewer”: the application module of Young Platform Pro that displays, in graphical and aggregated form, the distribution of buy and sell orders available at the External Execution Venues to which the Company routes Clients’ orders pursuant to article 78 MiCAR. The Liquidity Viewer has an exclusively informational purpose and enables the Client to assess market conditions before submitting an order; it does not constitute an internal electronic order register nor a matching mechanism between orders of different Clients, and does not amount in any way to the operation of a multilateral trading system within the meaning of article 76 MiCAR.

Subject Matter of the Notice

4.1 This Notice concerns the following structural changes to the operating model of Young Platform Pro, taking effect on the effective date set out in Section 9:

(a) the dismissal of the internal Order Book of the Pro Platform, resulting in the exclusion of any internal matching mechanism between orders of different Clients on the Platform;

(b) the dismissal of the Limit Order types with Good Till Cancelled (GTC) time-in-force and of Conditional Orders (stop, stop-loss, stop-limit) currently available on the Pro Platform, with the consequent availability — at the go-live of the new operating model — of the sole Limit Order (limit order) with Fill or Kill (FOK) time-in-force, routed to the External Execution Venues selected by the Company under the Execution Policy;

(c) the regulatory requalification of the transactions executed on the Pro Platform as Execution of Orders on Behalf of Clients pursuant to Article 78 MiCAR, with the Company acting as intermediary (Agent) routing the received orders to External Execution Venues, in accordance with the Best Execution criteria defined by the Execution Policy;

(d) the unilateral cancellation of all Open Orders, including pending limit and conditional orders, immediately before the beginning of the technical maintenance window referred to in Section 9, in order to allow the update of the application infrastructure and the replacement of the internal Order Book with the Smart Order Router module.

Operating Status of Young Platform Pro as of 30 June

5.1 Up to the effective date referred to in Section 9, the Young Platform Pro platform operates under a technical-functional model characterised by the following elements:

(a) the presence of an internal Order Book on the Platform, in which buy and sell orders submitted by Clients are ranked by price and time of submission and matched internally under matching logics between orders of different Clients;

(b) the availability of a broad set of order types, including: Market Order (market order), Limit Order (limit order), Conditional Order (stop, stop-loss, stop-limit) and orders with time-in-force parameters (GTC — Good Till Cancelled, IOC — Immediate or Cancel, FOK — Fill or Kill), all managed within the Platform’s infrastructure;

(c) the formation of the execution price on the basis of the crossing between buy and sell orders submitted by Clients on the internal Order Book, subject to price-time priority rules applied by the Company’s systems.

5.2 From a regulatory perspective, the regime applicable to this operating model has been aligned with MiCAR and the national implementing provisions (Legislative Decree 129/2024). The operating model of the Pro Platform has undergone a structural requalification, as described in Section 6.

New Operating Model of Young Platform Pro from 1 July

6.1 Regulatory qualification of the service. Only the Execution of Orders on Behalf of Clients pursuant to Article 78 MiCAR is provided on the Pro Platform. The Company acts as intermediary (Agent) and does not qualify as the Client’s contractual counterparty, nor does it assume the market risk related to the transaction. The qualification of the service is recorded in the information systems and cannot be modified during the order lifecycle. No automatic conversion of an order qualified as execution into a Bilateral Exchange transaction pursuant to article 77 MiCAR is permitted. The operating model is described in the General Terms and Conditions — Crypto-asset Services.

6.2 Dismissal of the internal Order Book. The internal Order Book of the Platform is dismissed. The Company no longer implements any internal electronic order ranking by price and time, nor any matching or pairing mechanism between orders of different Clients. The Platform does not operate, in any form, a multilateral trading system within the meaning of Article 76 MiCAR. The price-time priority and the matching rules applicable to each transaction are those of the External Execution Venue to which the Client’s order is routed.

6.3 Smart Order Router and selection of External Execution Venues. The Client’s order submitted on the Pro Platform is received by the Smart Order Router module, which performs the ex-ante qualification of the order pursuant to Article 78 MiCAR and routes it to the selected External Execution Venue on the basis of the criteria set out in the Execution Policy adopted by the Company. The selection of the External Execution Venue is carried out on the basis of the Best Execution factors: price, overall costs, speed, likelihood of execution and settlement, size and nature of the order, and any other relevant parameter, in accordance with the Best Execution Policy.

6.4 Available order types. Starting from the effective date set out in Section 9 and until further notice, the Pro Platform allows the submission of a Limit Order (limit order) with Fill or Kill (FOK) time-in-force only, routed by the Smart Order Router to the selected External Execution Venue for immediate execution at the best available price. The FOK Limit Order is executed in full at the price specified by the Client where sufficient counterparty is available at the External Execution Venue for the entire quantity, or is cancelled in full without partial execution where such counterparty is not available. Market Order (market order), Limit Order (limit order) with Good Till Cancelled (GTC) time-in-force — i.e. orders that remain open in the book until execution or cancellation — and Conditional Order (stop, stop-loss, stop-limit) types will no longer be available on the Pro Platform from the effective date. In line with the General Terms and Conditions — Crypto-asset Services, the set of order types supported on the Pro Platform will be gradually extended in accordance with the technical and operational features of the External Execution Venues integrated by the Company under the Execution Policy, according to the following indicative roadmap: (i) Limit Order with Immediate or Cancel (IOC) time-in-force; (ii) conditional order types replicating the mechanics of stop limit orders. Any reintroduction of each type will be the subject of a dedicated notice published through the Company’s official channels.

6.5 Formation of the execution price. Unlike the model in place until 30 June — based on the crossing of orders on the internal Order Book — the execution price applied to the Client in the new operating model is the price of the Limit Order (limit order) specified by the Client upon submission, executed at the selected External Execution Venue. To the intermediation result obtained at the External Execution Venue, the brokerage commission previously notified to the Client is applied, in accordance with the fee schedule set out in the Fees and Pricing page. The Client is informed in advance that, with Fill or Kill (FOK) time-in-force, the order is executed in full at the specified price or cancelled in full where sufficient counterparty for the entire quantity is not available; in conditions of high volume, illiquidity, rapid movements or market volatility, the likelihood of full cancellation of the order may be significant.

6.6 Execution outside an authorised trading platform. Where the Execution Policy permits execution of the order outside an authorised trading platform, the Company obtains the Client’s express prior consent, recorded with a timestamp in the information systems. Consent is collected through a non-circumventable mechanism in the application interface and may be revoked by the Client at any time with respect to future transactions; such revocation does not affect transactions already executed.

6.7 Specific Client instructions. Where the Client provides specific instructions relating to the Execution Venue or to other parameters of the order, the Company complies with such instructions within technically and legally permitted limits, informing the Client that compliance with specific instructions may prevent the full application of the measures provided for by the Execution Policy for the purposes of achieving the best possible result. Specific instructions are recorded in the information systems and associated with the order, enabling ex-post reconstruction of the logic followed during execution.

6.8 Logging and ex-post reconstruction. All relevant phases of the order lifecycle — receipt, qualification, selection of the Execution Venue, transmission, execution confirmation, update of the Internal Ledger — are fully recorded in the Company’s logging and audit trail systems and are fully reconstructable ex post, in accordance with the recordkeeping obligations set out in Delegated Regulation (EU) 2025/1140.

Comparative Summary of the Operating Models

7.1 For ease of reference, the following table sets out the main differences between the operating model in force until 30/06/2026 and the operating model applicable from 01/07/2026:

Profile	Model up to 30 June 2026	New operating model (from 1 July 2026)
Qualification of the service	Being aligned with MiCAR	Execution of Orders on Behalf of Clients pursuant to Article 78 MiCAR
Role of the Company	Being aligned with MiCAR	Intermediary (Agent); no assumption of market risk
Internal Order Book	Present, with matching between orders of different Clients	Dismissed; no internal matching
Multilateral trading system (CLOB)	Internal matching between orders of different Clients on a proprietary Order Book	Not operated (express commitment in the General Terms and Conditions — Crypto-asset Services)
Order types submitted on the Pro Platform	Market Order, Limit Order, Conditional Order (stop, stop-loss, stop-limit), orders with time-in-force parameters (GTC, IOC, FOK)	Limit Order (limit order) with Fill or Kill (FOK) time-in-force only; gradual extension to Limit IOC and to conditional orders (stop limit) subject to the features of the External Execution Venues. GTC not supported.
Execution modalities	Internal matching on the Platform’s Order Book	Routing via Smart Order Router to the External Execution Venue selected in accordance with the Execution Policy
Price formation	Crossing of orders on the internal Order Book	Price of the Limit Order (limit order) specified by the Client, executed at the External Execution Venue; the brokerage commission is applied to the intermediation result
Best Execution	Rules internal to the Platform	Best Execution Policy adopted pursuant to article 78 MiCAR (Annex 15)
Consent pursuant to article 78(5) MiCAR	Not required	Required where execution takes place outside an authorised trading platform; revocable
Regime of open orders	Kept on the Order Book until execution, expiry or cancellation by the Client	Unilateral cancellation before the technical maintenance; locked resources returned to the available balance

Unilateral Cancellation of Open Orders

8.1 In order to enable the technical update of the Young Platform Pro application infrastructure and the replacement of the internal Order Book with the Smart Order Router module, the Company arranged the unilateral cancellation of all Open Orders on the Pro Platform immediately before the beginning of the maintenance window referred to in Section 9.

8.2 The unilateral cancellation was applied without distinction to all buy and sell orders submitted by Clients on the Pro Platform and not executed, expired or cancelled at the start of the maintenance, including: Limit Orders, Conditional Orders (stop, stop-loss, stop-limit) and orders with time-in-force parameters (GTC, IOC, FOK) that were pending.

8.3 The unilateral cancellation does not result in the execution of the order at the price specified by the Client; the resources (in funds or in crypto-assets) locked as collateral for the order, if any, are returned in full to the available balance of the Client’s Account.

8.4 The Company shall not be liable for any lost profits or losses arising from the non-execution of an Open Order following the unilateral cancellation, subject to the full return of the locked resources to the available balance of the Account.

Effective Date and Maintenance Window

9.1 The changes referred to in this Notice took effect from the reopening of services at the end of the scheduled maintenance window of the Platform, which took place from 20:00 (Italian time, CEST) on Tuesday 30 June 2026 to 02:00 (Italian time, CEST) on Wednesday 1 July 2026. During the maintenance window, the Platform’s operations were entirely suspended.

9.2 Upon reopening of the Pro Platform at 10:00 (Italian time, CEST) on 1 July, the functionalities for submitting Limit Orders with Good Till Cancelled (GTC) time-in-force and Conditional Orders (stop, stop-loss, stop-limit) are dismissed; the only order type available is the Limit Order (limit order) with Fill or Kill (FOK) time-in-force. The internal Order Book is no longer displayed. The application interface makes clear to the Client, upon submission and confirmation of each order, the Journey used, the relevant applicable MiCAR service, and the order finality conditions.

Effects for the Client and Operational Recommendations

10.1 As a result of the changes described in the preceding Sections, the Client is recommended to:

1. take note that, upon reopening of the Pro Platform, operational strategies based on the submission of Limit Orders with Good Till Cancelled (GTC) time-in-force — i.e. orders that remain open in the book until execution or cancellation — and of Conditional Orders (stop, stop-loss, stop-limit) cannot be pursued through the Pro Platform until the possible reintroduction of the relevant order types in accordance with the roadmap set out in paragraph 6.4. Such extension will be subject to the technical and operational features of the External Execution Venues integrated by the Company under the Execution Policy and will be the subject of a dedicated notice;
   
2. review, before using the Pro Platform under the new operating model, the Best Execution Policy and the Fees and Pricing page, in order to fully understand the methodology for selecting External Execution Venues, the price formation criteria and the applicable fee schedule.
   

10.2 The Client is informed that, in order to carry out a buy or sell transaction of crypto-assets at a predetermined price outside the market, the assisted OTC Desk channel of the Company remains available, operating as an assisted channel of the Bilateral Exchange Service pursuant to article 77 MiCAR, in accordance with the OTC Service Notice published through the Company’s official channels.

Risks and Service Limitations

11.1 The new operating model of Young Platform Pro, based on the routing of orders to External Execution Venues pursuant to article 78 MiCAR, entails that the Client submits a Limit Order (limit order) with Fill or Kill (FOK) time-in-force: such order is executed in full at the price specified by the Client at the selected External Execution Venue where sufficient counterparty is available for the entire quantity, or is cancelled in full without partial execution where such counterparty is not available. In conditions of high volume, illiquidity, rapid movements or market volatility, the likelihood of full cancellation of the order may be significant. To the intermediation result obtained at the External Execution Venue, the brokerage commission is applied in accordance with the fee schedule.

11.2 The dismissal of Limit Orders with Good Till Cancelled (GTC) time-in-force and of Conditional Orders (stop, stop-loss, stop-limit) on the Pro Platform entails that, through the Pro Platform, the Client can no longer issue buy or sell instructions that remain open in the book until a specified market price is reached, until the possible reintroduction of such order types under paragraph 6.4. The Limit Order (limit order) with Fill or Kill (FOK) time-in-force currently available is executed in full at the price specified by the Client or, in the absence of a counterparty at that price for the entire quantity, cancelled in full without partial execution.

11.3 The unilateral cancellation of Open Orders referred to in Section 8 may result in the non-completion of transactions that the Client might have executed at the order price. Any decision to re-submit orders upon the Platform’s restart is left entirely to the Client.

11.4 Crypto-assets are instruments characterised by high volatility and entail a significant risk of loss, including total loss, of the invested capital. For a comprehensive assessment of the risks connected with the operability in crypto-assets, please refer to the General Risk Disclosure published at
youngplatform.com/legal/information-general-risks/

Communications and Complaints

12.1 The Company’s communications relating to the new operating model of Young Platform Pro are made through the Company’s official channels (institutional website, email, in-app notification), in compliance with the applicable pre-contractual transparency obligations.

12.2 For operational clarifications, the Client may contact the Company’s Customer Support through the portal support.youngplatform.com/hc/en, active according to the channels and times indicated on the portal itself.

12.3 For complaints, the Client may contact the Company in accordance with the Complaints Handling Procedure published through the official channels and in compliance with Article 71 MiCAR. The Client’s right to contact the competent supervisory Authority and to activate the applicable alternative dispute resolution systems remains unaffected.

Publication, Retention, and Amendments

13.1 This Notice is published through the Company’s official channels and is retained, together with its subsequent versions, for a period of no less than five (5) years, in compliance with the recordkeeping obligations set out in Delegated Regulation (EU) 2025/1140 and other applicable rules.

13.2 The Company reserves the right to amend this Notice for operational, technical, organisational reasons or for regulatory adaptation, by giving notice through the official channels and in compliance with the terms set out in the General Terms and Conditions.

This communication constitutes a service notice and does not represent a marketing communication nor an offer or solicitation to invest in crypto-assets. Crypto-assets are subject to specific risks, including the risk of total loss of the invested capital, and do not benefit from the guarantee schemes provided for bank deposits (Directive 2014/49/EU) nor from the investor compensation schemes (Directive 97/9/EC). For full information on the services offered, please refer to the Terms and Conditions of the service published through Young Platform’s official channels. Young Platform operates in accordance with the applicable law, including MiCAR (Regulation (EU) 2023/1114). Young Platform S.p.A., Via Cigna 96/17, 10155 Turin — youngplatform.com — PEC: [email protected].

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