Introduction
This is a summary of the complaints management policy of B2C2 Europe S.à r.l., published under Article 71 of Regulation (EU) 2023/1114 (MiCAR) and Commission Delegated Regulation (EU) 2025/294. It describes how we receive, investigate and resolve complaints about the crypto-asset services we provide, and the rights available to you if you are not satisfied with our response.
1. Who this policy applies to
This policy applies to complaints about crypto-asset services provided by B2C2 Europe S.à r.l., a société à responsabilité limitée registered in Luxembourg (RCS B265273) and authorised as a crypto-asset service provider by the Commission de Surveillance du Secteur Financier (CSSF).
It applies to complaints from clients, prospective clients and other persons who consider they have been affected by a crypto-asset service we provide, whether or not they are eligible complainants for regulatory purposes.
It does not cover matters dealt with under separate procedures — in particular concerns raised by staff, which are handled under the B2C2 Whistleblowing Policy, and disputes with commercial partners, employees or other non-clients. Complaints about other B2C2 group entities are handled under the group Complaints Policy.
2. Regulatory framework
Regulation (EU) 2023/1114 on markets in crypto-assets (MiCAR), in particular Article 71
Commission Delegated Regulation (EU) 2025/294 — regulatory technical standards on the requirements, templates and procedures for the handling of complaints by crypto-asset service providers
CSSF Regulation N° 16-07 relating to out-of-court complaint resolution
Regulation (EU) 2016/679 (GDPR)
Council Directive 93/13/EEC on unfair terms in consumer contracts, where applicable
Applicable ESMA technical standards and guidelines under MiCAR
2. Regulatory framework
A complaint is any oral or written expression of dissatisfaction, whether or not justified, about the provision of — or failure to provide — one or more crypto-asset services, where the complainant has suffered or alleges they may suffer damage, loss or detriment. This includes complaints about our obligations under data protection law.
A complainant is any natural or legal person who has made a complaint, regardless of whether they are an eligible complainant for regulatory purposes.
What we may not treat as a complaint. Some correspondence does not meet this definition or does not raise an issue calling for investigation. Where we reach that view we will tell you and give our reasons. Examples include:
routine dissatisfaction with our automated risk pricing as displayed via GUI or API;
objections to steps or decisions we have taken in order to comply with a legal or regulatory requirement;
disapproval of a refusal to act where we have no legal power to do so;
anonymous submissions;
malicious, repetitive or vexatious claims, including harassment of staff, or resubmission of a complaint we have already answered.
Having given our reasons once, we will not normally continue to correspond on the merits of the position taken. We do not respond to abusive correspondence.
4. Cost and languages
Filing and handling a complaint is free of charge. You may complain in English or French, in an official language of Luxembourg, or in an official language of the European Union that is also an official language of your Member State. This summary and the standard complaint form are published in each language we use to market our services or communicate with clients.
5. Governance and resources
Approves this policy at least annually and monitors the proper implementation of the complaints-handling procedures.
Ensure complaints are handled effectively, oversee escalation, and receive the annual complaints report.
Head of Compliance, B2C2 Europe
Owns the complaints-handling function. Reviews and approves every complaint summary and proposed response, sets up and monitors the efficiency of the process, and verifies that all complaints are recorded, investigated and answered fairly and on time. Reports to the Authorised Managers, the Board and the CSSF as required.
Escalate any expression of dissatisfaction to Compliance promptly and act as the point of contact with the complainant where appropriate.
B2C2 Europe dedicates sufficient human and technical resources to complaints handling. Complaints are assessed by persons independent of the individuals and functions they concern, and any conflict of interest that could impair impartial handling is identified and managed under our Conflicts of Interest Policy.
6. How to submit a complaint
Full details including the information to provide, where to send it, and the standard template published under Commission Delegated Regulation (EU) 2025/294 , are set out on our
Submit a complaint page. In summary: by email to complaints@b2c2.com, by post to B2C2 Europe S.à r.l., 1 rue Jean Piret, L-2350 Luxembourg, or orally or in writing through your usual contact at B2C2. Use of the template is optional and a complaint will not be rejected because it was not used.
7. How we handle your complaint
Ideally within 3 business days of receipt
We confirm receipt in writing and state whether the complaint is admissible, giving reasons where it is not. The acknowledgement contains the date of receipt, the name and contact details (including email and telephone) of the person or department handling the complaint, the applicable timeframe, and a copy of the complaint where it was filed electronically.
The Head of Compliance or an appropriate delegate assesses the complaint impartially on the basis of all information available, requests any further information needed, and keeps the complainant informed of additional steps taken. Reasonable information requests from the complainant are answered without undue delay.
Where 30 days is exceeded
We explain the cause of the delay and indicate when we expect the investigation to be complete.
Within 2 months of acknowledgement
A reasoned written decision addressing every point raised, consistent with previous decisions on similar complaints (and explaining any departure). Where the complaint is not upheld in full, we explain our position and set out how the complainant may escalate.
Where a complaint is properly directed at another party, we will say so and, so far as we are able, point you to the options available to you. Complaints received via a regulator, lawyer, consumer association or other third party are answered to that party, with a copy to the complainant.
8. Complaint categories
We classify complaints so that recurring issues can be identified. Our current categories are:
trade execution, timing, exchange rates, fees and pricing;
information security;
compliance processes, client rejections and account terminations;
data protection and GDPR.
Further categories are added where new recurring issues emerge.
9. Records
Every complaint is recorded on the complaints register in our case management system, together with the complainant, the service concerned, the substance of the complaint, the investigation, the outcome, any action taken, and whether the complaint qualifies as a complaint for regulatory purposes. Records are kept securely in electronic form and retained in accordance with our records retention requirements.
10. Root cause analysis and reporting
The Head of Compliance reviews complaints data regularly to identify recurring or systemic problems and any legal or operational risk. This involves analysing the causes of individual complaints to identify root causes common to a category, considering whether those root causes affect other processes, products or services — including those not complained of — and correcting them where it is reasonable to do so.
Remedial action may include clarifying trading documentation or website disclosures, or changing product or process design, even where no fault is found on the merits of a particular complaint.
An annual summary report is prepared for the Authorised Managers covering the number of complaints received, their category, resolution status, any settlements or concessions and any follow-up action required. Where applicable, the Head of Compliance submits an annual summary to the CSSF classified by type of complaint together with the measures taken to handle them.
11. If you remain dissatisfied
You may refer the matter to the CSSF under its out-of-court complaint resolution procedure (CSSF Regulation N° 16-07), provided you have first complained to us and either were dissatisfied with our response or received no acknowledgement within one month, and provided your request reaches the CSSF within one year of the date you complained to us.
CSSF
283 route d’Arlon, L-1150 Luxembourg
reclamation@cssf.lu
cssf.lu/en/customer-complaints
The CSSF will ask you for a chronological statement of the facts and steps taken, a copy of your original complaint and our response, confirmation that the matter is not before a court, arbitrator or other ADR body, your agreement to the terms on which the CSSF intervenes, your authorisation for the CSSF to pass your file to us, evidence of authority where you are represented or acting for a legal entity, and valid identification. The matter must not concern B2C2’s commercial policy.
Where the CSSF accepts a request it will ask us to explain our position within one month and will normally issue a reasoned conclusion within 90 days, extendable in complex cases. Its conclusions are not binding on either party, and legal proceedings remain available if no agreement is reached.
Where your complaint concerns personal data, you may also complain to the Commission nationale pour la protection des données (CNPD) or to the supervisory authority in your own Member State.
12. Confidentiality and data protection
All complaints are handled confidentially. Personal data submitted with a complaint is processed only for the purposes of investigating and resolving it, meeting our regulatory obligations and improving our services, in accordance with the GDPR and our Privacy Policy. Where we need to verify your identity we will ask only for what is reasonable and proportionate in the circumstances.Where the CSSF accepts a request it will ask us to explain our position within one month and will normally issue a reasoned conclusion within 90 days, extendable in complex cases. Its conclusions are not binding on either party, and legal proceedings remain available if no agreement is reached.
13. Review
This policy is owned by Compliance and approved by the Board of Directors of B2C2 Europe at least annually. It is reviewed whenever there is a material change to our services, our regulatory obligations or the outcome of our root cause analysis.
