REGULOGRAPH
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Illustration: a book, a dotted line and a panda breaking a red ribbon at a finish line.
REGULATION / MICA

MiCA is moving from rules to real enforcement

The Austrian financial regulator FMA fined Bitpanda 70,000 euros for failing to meet the obligations attached to a crypto-asset white paper and the marketing communications that followed it. This is the first published final sanction decision issued by the Austrian FMA under MiCAR.

Read the full article on CoinGeek →

Source: CoinGeek. Primary announcement by the Austrian FMA. The text is an editorial summary, not a verbatim quotation.

REGULATORY EVIDENCE & COMMUNICATIONS OS

Every claim. Every source. Every interaction.

REGULOGRAPH is a system for companies that publicly communicate regulatory status, product or investment claims — and need to prove why a claim could be used, who approved it, what evidence it rested on, and what has changed since.

How it worksIntroductory consultation
Category—Regulatory Evidence & Communications OS
01Problem

Regulatory risk does not arise only from breaking a rule

It also arises from the gap between what a company actually did, what it wrote about it, how others interpreted it, and what it can prove years later.

In a regulated environment, several disconnected realities exist side by side: the legal text, internal decisions, marketing copy, regulatory correspondence, public statements by institutions and their representatives, and the media’s interpretation of all of it. Each has a different owner and a different archive. When their meanings drift apart, the company starts reconstructing its own past only once it is already under pressure.

FailureConsequence
Unmanaged claim
A website, pitch deck or interview uses the word ‘regulated’, ‘approved’ or ‘sandbox’ without a precise status and evidence.
Fragmented memory
Emails, filings, minutes and attachments are scattered across storage systems; a complete timeline cannot be assembled quickly.
Unclear interaction
After an informal consultation there is no record of what was said, what was not said, and what was to be provided.
Outdated status
A published claim or status no longer matches reality after a rule, licence or product changes — and nobody updates it.
Reactive defence
Lawyers start sorting evidence only after an incident; meanwhile the company keeps communicating inconsistently and increases its own risk.
NORTH STAR
No regulatory-sensitive claim without an identified entity, product, jurisdiction, audience, owner, evidence, approver, and a date for its next review.
02The chain

Every claim passes through the same chain

From regulatory status through precise wording and evidence to a named approver, publication, interaction and an exportable evidence pack. No claim skips a link.

  1. 01Statusthe regulatory position of the entity and product
  2. 02Claimthe precise wording that may be used
  3. 03Evidencethe primary source and its authority
  4. 04Approvala named owner and approver
  5. 05Publicationversion, channel and audience
  6. 06Interactioninquiries, filings and meetings
  7. 07Evidence packan exportable evidence bundle
03Why now

The rules require truthfulness, consistency, substantiation and records

REGULOGRAPH is not built on the AI hype cycle. It is built on a concrete obligation: to prove why a company was allowed to make a claim and how it kept its subsequent communication under control.

Legal wording differs across the EU, the UK and the US, but the shared principle is stable: communication must not be false or misleading, it must be balanced, and in the relevant regimes material claims must be substantiated. MiCA additionally requires marketing communications to be consistent with the crypto-asset white paper. The FCA applies the ‘fair, clear and not misleading’ standard, and the SEC explicitly addresses the ability to substantiate material statements on demand.

19,766
promotions amended or withdrawn following FCA intervention in 2024
FCA 2024
USD 63m+
combined penalties for 12 firms over off-channel communications, January 2025
SEC 2025

These figures are not REGULOGRAPH estimates. They are published FCA and SEC data. They do not mean that every client faces the same exposure; they do show that content control and record-keeping are distinct areas of supervision. Methodology and sources

Regulatory principleProduct response
Fair / clear / not misleading
Review of the meaning of the whole message, not just the presence of a disclaimer.
Consistency with official documentation
Claims linked to the white paper, prospectus, licence, decision and its current version.
Substantiation on demand
An evidence card for every material claim and an export of the underlying records.
Pre-approval / governance
Roles, four-eyes review, an approval matrix and a recorded reason for each decision.
Recordkeeping
An archive of version, channel, audience, approver, time and subsequent changes.
Regulatory change
Automatic identification of which claims and materials a rule change affects.
IMPORTANT BOUNDARY
The system must never suggest that legal correctness can be ‘computed’ as a single score. A score may prioritise review; the legal conclusion must remain explainable and reviewable by a human.
04Who it is for

REGULOGRAPH is for companies accountable for every public claim

If communication in your organisation is approved across legal, compliance, marketing and executive roles, this system addresses your daily problem.

  • you publicly communicate regulatory status, fundraising, product or partnerships
  • you operate multiple entities, products or jurisdictions and need to manage them coherently
  • you are preparing a licensing, registration or investor process and need defensible records
  • your communication approvals run fragmented through external counsel and you lose track of versions
  • you have experienced — or realistically expect — a dispute over the meaning of an earlier claim or interaction with an authority

REGULOGRAPH is a system of record in which every regulatory claim, piece of evidence, approval and interaction has an owner, a version and a date for its next review.

STATUS
The REGULOGRAPH platform is under development. The entry product is Regulatory Memory Reconstruction, a paid service for a limited number of partners. We do not publish pricing; scope and terms are discussed in an introductory consultation.
Next stepRegulatory Memory ReconstructionContinue →
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