Independent Legal Opinion Confirms: SAL Is Eligible for Listing on MiCAR-Authorised Exchanges

We’ve always said that privacy and compliance aren’t mutually exclusive. Today we can back that up with an independent legal analysis from gunnercooke GmbH, a German law firm, confirming that SAL’s classification and protocol features satisfy the requirements for listing on MiCAR-authorised exchanges — and that Salvium’s protocol provides the tools exchanges need to meet their obligations under Article 76(3).

This is a significant milestone for Salvium and, we believe, for the privacy coin space as a whole.

What is MiCAR and why does it matter?

MiCAR is the European Union’s comprehensive regulatory framework for crypto-assets. It sets out the rules for how tokens can be offered, traded, and serviced across all EU member states. For any token that wants to trade on a regulated European exchange — platforms like Coinbase, Bitpanda, Bitvavo, OKX, and others now operating under MiCAR authorisation — the token needs to fit within MiCAR’s classification system and meet its requirements.

For privacy coins, one provision has loomed large: Article 76(3). This is the rule that says exchanges must not admit crypto-assets with “inbuilt anonymisation functions” to trading — unless the exchange can identify the holders and their transaction history. This provision is the reason several privacy-focused tokens have been delisted from European platforms, and it’s been widely interpreted as a de facto ban on privacy coins.

We’ve always believed that interpretation was too broad. The regulation doesn’t prohibit privacy features. It asks a specific question: can the exchange identify who holds the token and see the relevant transaction history? If the answer is yes, the token is eligible for listing.

What we commissioned and why

We engaged Gunnercooke GmbH in Hamburg to conduct an independent legal analysis of SAL’s compliance with MiCAR. The analysis assessed the legal classification of the SAL token, its eligibility for admission to trading on centralised exchanges, and specifically whether SAL’s privacy features are compatible with Article 76(3).

The analysis was based on the Salvium documentation publicly available in our GitHub library, including the white paper and litepaper. It was delivered on 17 February 2026.

The key findings

SAL is classified as an “Other Crypto-Asset” under MiCAR. The opinion confirms that SAL qualifies as a crypto-asset within the meaning of MiCAR. It is not a financial instrument under MiFID II, not an e-money token, not an asset-referenced token, and not a utility token. SAL falls into the same broad category as Bitcoin and most Layer-1 native tokens. This is the classification we expected, but having it confirmed independently by qualified legal counsel is important when approaching exchanges and regulators.

SAL’s privacy features do not violate MiCAR. The analysis concludes that while SAL incorporates privacy-by-default transaction features that may be characterised as an inbuilt anonymisation function, these features do not give rise to a prohibition on admission to trading under Article 76(3) MiCAR. The reason is that crypto-asset service providers operating trading platforms are able to identify SAL token holders and their transaction history.

SAL’s functionality enables compliance. The general conclusion of the analysis is that a token can be structured in a way that enables an exchange, via mechanisms like a view key, to identify the holder of the crypto-assets and review the transaction history at any time. This is exactly how Salvium was designed. The combination of custodial onboarding, CARROT addressing for deposit attribution, selective disclosure via view keys, and SPARC for return handling and spend-authority proofs gives exchanges everything they need to meet their regulatory obligations while listing SAL.

The opinion concludes that the admission of the SAL token to trading on MiCAR-authorised exchanges is legally permissible, provided the relevant platform complies with its own MiCAR obligations — particularly those relating to AML/CTF compliance, customer identification, transaction monitoring, and the maintenance of appropriate operating rules.

What this means in practice

This opinion provides exchanges with the legal comfort they need to evaluate SAL for listing under MiCAR. It directly addresses the specific concern — Article 76(3) — that has driven privacy coin delistings across Europe, and demonstrates that Salvium’s protocol was designed from inception to navigate this regulatory environment.

To be clear about what this is and isn’t: it is a well-reasoned legal analysis from a qualified German law firm. It is not a regulatory approval, and it’s not a guarantee that any specific exchange will list SAL. Each exchange makes its own listing decisions and conducts its own due diligence. What the opinion does is remove the primary legal objection that has stood in the way of privacy coins on European platforms.

The full legal analysis is available to exchanges and regulatory authorities evaluating SAL. For the community, we can share that the opinion has been independently produced by Gunnercooke GmbH and that its conclusions are as summarised above. We’ll continue to make it available to partners as we pursue further exchange listings.

The bigger picture

When we forked Monero and started building Salvium, the thesis was straightforward: the crypto industry is moving toward regulation, and privacy coins that can’t adapt will be left behind. That doesn’t mean sacrificing privacy — it means building protocols that give users strong privacy by default while providing the tools that regulated entities need to meet their obligations.

CARROT, SPARC, view keys, and exchange mode aren’t compromises. They’re the reason SAL can exist on regulated platforms while other privacy coins face delistings. Privacy that only works outside the regulated financial system isn’t serving users — it’s limiting them.

This legal opinion validates that design philosophy. We’ll continue working with exchanges, regulators, and legal counsel as MiCAR implementation evolves across the EU.