MiCA¹[1] imposes market-integrity surveillance obligations on Class 3 operators — exchanges, custodians-with-trading, and any CASP operating an order book or matching engine. Article 78 mandates systems and controls to detect and prevent wash trading, layering, spoofing, front-running, insider dealing, and manipulative practices — the same regulatory perimeter that has applied to traditional MiFID II venues for a decade, now extended to crypto.
In practice, this means a Class 3 CASP must run a market-surveillance system that produces defendable alerts — alerts that hold up under regulator inspection, that scale with order-book volume, and that cover the specific manipulation typologies the supervisor cares about. Three vendors dominate this market for institutional crypto operators in 2026: Eventus, Trillium, and Solidus Labs. Each has a recognisable strength and a recognisable weakness.
This is the practitioner comparison: the regulatory framing under MiCA Article 78, the three vendors at a glance, vendor-by-vendor pros and cons, the detection-depth matrix, integration considerations, pricing models, and a decision tree.
Disclaimer. The views expressed in this comparison reflect finconduit's practitioner experience working with these vendors at client sites. The overview does not constitute a formal vendor due-diligence report and may not include adverse media, security incidents, regulatory matters, or ownership changes affecting any vendor. Class 3 operators should conduct their own thorough vendor due diligence — security audits, financial integrity, regulator references, on-site visits — before signing.
MiCA Article 78 surveillance obligations
Article 78 requires Class 3 CASPs operating a trading platform to:
Maintain effective arrangements, systems and procedures to detect and report market abuse.
Run automated surveillance with alerting calibrated to typology-specific thresholds.
Maintain an STOR (Suspicious Transaction and Order Report) regime — discoverable, reportable to the home NCA without delay.
Retain order, trade and surveillance data for a minimum of five years, in a format inspectable by the supervisor.
Document tuning rationale: every threshold change, every alert dismissal pattern, every typology calibration.
ESMA² technical standards underpin the supervisory expectations. The substance test is whether the surveillance regime is materially equivalent to the MAR-aligned surveillance running at any MiFID II venue, adapted to the trading microstructure of crypto markets.
The three vendors at a glance
Eventus³[3] — the institutional incumbent. The Validus platform serves traditional exchanges, broker-dealers, and a growing roster of regulated crypto venues. Strongest brand recognition with regulators, deepest detection-typology library inherited from equities and futures markets, and the most mature institutional sales motion of the three. Headquartered in Austin, Texas, with European presence in London.
Trillium⁴[4] — the surveillance arm of Trillium Management, with the Surveyor platform. New York-headquartered, with deep equities-market lineage. Strong on detection-quality and analyst tooling; the platform is built around the surveillance analyst's workflow rather than around configurable rules-engine depth. Smaller crypto footprint than Eventus or Solidus but a credible institutional alternative for hybrid venues running both equities and crypto.
Solidus Labs⁵[5] — the crypto-native challenger. New York-headquartered, founded 2018, built for digital-asset markets from the ground up. Strongest on cross-venue and on-chain detection, deepest crypto-specific typology library, and the most aggressive cadence of typology releases. The right fit when crypto-native depth is decisive; the trade-off is a thinner equities-market track record than the other two.
The three vendors at a glance.
| Vendor | HQ | Origin | Strongest dimension | Crypto-specific depth |
|---|---|---|---|---|
| Eventus | Austin / London | Multi-asset (eq, futures, FX, crypto) | Brand + typology library + regulator credibility | Medium-High |
| Trillium (Surveyor) | New York | Equities-focused | Analyst workflow + alert quality | Medium |
| Solidus Labs | New York | Crypto-native | Cross-venue + on-chain detection | Highest |
Detection-typology comparison
Wash trading
Self-trading, related-party trading, circular volume that creates the appearance of liquidity. All three vendors detect this. Solidus has the strongest cross-account and on-chain wash-detection because of native blockchain integration; Eventus has the most-tested typology calibration from years of equities and futures markets; Trillium provides the cleanest analyst review surface.
Layering and spoofing
Order placement intended to influence price without intention to execute. Eventus and Trillium both bring extensive layered-detection from equities markets; Solidus has built crypto-specific calibration that handles the materially different microstructure (24/7, fragmented liquidity, lower order density). At Class 3 venues with tight spreads and high order-book churn, calibration matters more than typology library size.
Front-running and insider dealing
All three vendors handle pattern-detection on order-flow precedence. The crypto-specific challenge is detecting front-running across venues — particularly when the upstream signal is on-chain (token-listing announcement, large wallet movement) rather than off-chain. Solidus has the strongest cross-venue and on-chain integration; Eventus and Trillium are catching up but require the venue to feed external signals into the platform.
Manipulative ramp and pump-and-dump
Coordinated buying or selling intended to create false price signals. The crypto-specific dimension is social-media coordination (Telegram pump groups, Discord channels) that operates outside the venue's data feeds. Solidus integrates third-party social-signal feeds; Eventus and Trillium typically rely on the venue's own ingestion.
Cross-venue manipulation
Activity at venue A intended to manipulate prices at venue B. The detection requires correlated views across venues — typically through shared customer relationships or wallet-level on-chain linking. Solidus's clearest competitive advantage. Eventus and Trillium handle cross-venue with venue cooperation; Solidus handles it via on-chain forensics natively.
Eventus — deep dive
Eventus is the multi-asset surveillance platform of choice for traditional exchanges, broker-dealers and a growing roster of regulated crypto venues. The Validus platform brings 15+ years of typology development from equities, futures, FX and options markets, retrofitted progressively into crypto.
Pros
Strongest regulator credibility — Eventus is recognised by ESMA, FCA, NFA, MAS, and the institutional alphabet of supervisory bodies.
Deepest typology library inherited from multi-asset markets — over 100 detection scenarios across asset classes.
Mature analyst workflow with strong case-management, evidencing, and STOR-generation tooling.
Multi-asset coverage — right fit for hybrid venues running spot crypto + derivatives + traditional markets.
Enterprise-grade SLAs, security certifications, and operational maturity.
Cons
Crypto-specific calibration is a workstream — typologies were originally designed for equities and futures and require tuning for crypto microstructure.
On-chain integration is shallower than Solidus — feasible but requires the venue to bring in external on-chain feeds.
Higher pricing tier; commercial structure favours larger venues with multi-asset complexity.
Implementation timeline is longer than Solidus — expect 4–6 months from contract to production at full Class 3 coverage.
Trillium (Surveyor) — deep dive
Trillium Surveyor is the surveillance arm of Trillium Management, with deep equities-market lineage and a sister broker-dealer business that informs typology design. The platform is purpose-built around the surveillance analyst's workflow rather than around configurable rules-engine depth — alerts are higher-quality on average, with lower false-positive rates than its competitors at comparable venue size.
Pros
Best alert-quality ratio of the three — false-positive rates materially lower at comparable detection coverage.
Excellent analyst-workflow tooling: case management, alert linkage, evidence collection, STOR-drafting all inline.
Strong fit for venues already running equities or hybrid order-flow.
Competitive pricing in the mid-tier — well below Eventus for comparable Class 3 coverage.
Cons
Smaller crypto-venue track record than Eventus or Solidus.
On-chain integration is the weakest of the three — minimal native blockchain forensics.
Smaller European footprint and EU-supervisor brand recognition than Eventus.
Cross-venue detection requires more customer-driven configuration than Solidus.
Solidus Labs — deep dive
Solidus Labs was built crypto-native from inception in 2018 and is the platform of reference for many native digital-asset venues. The HALO platform integrates on-chain analytics, off-chain order-book surveillance, and cross-venue correlation in a single architecture. The trade-off is thinner traditional-markets pedigree — Solidus is a crypto-first vendor, not a multi-asset incumbent.
Pros
Crypto-native by design — typologies calibrated for digital-asset microstructure from the start.
Native on-chain integration — wallet-level forensics, cross-chain bridging analysis, smart-contract event monitoring.
Strongest cross-venue manipulation detection — the architecture supports correlated detection across multiple CASPs natively.
Faster typology release cadence than the more enterprise-bound competitors.
Implementation timelines materially shorter — 8–12 weeks to production at full Class 3 coverage is achievable.
Cons
Less institutional-incumbent brand recognition with traditional supervisors and bank counterparties — though this is shifting fast.
Multi-asset coverage is narrower than Eventus — not a fit for hybrid venues with substantial equities or futures activity.
Younger company; some larger venues prefer the operational track record of multi-decade incumbents.
Pricing has tightened materially as the product has matured — early-stage cost advantage is narrowing relative to Trillium.
Side-by-side feature matrix — practitioner view (1=weak, 5=strong).
| Dimension | Eventus | Trillium | Solidus Labs |
|---|---|---|---|
| Wash-trading detection | 5 | 4 | 5 |
| Layering/spoofing | 5 | 5 | 4 |
| Front-running | 4 | 4 | 5 |
| Cross-venue manipulation | 3 | 3 | 5 |
| On-chain integration | 3 | 2 | 5 |
| Multi-asset coverage | 5 | 4 | 3 |
| Alert quality / FP rate | 4 | 5 | 4 |
| Analyst workflow | 4 | 5 | 4 |
| EU regulator credibility | 5 | 4 | 4 |
| Implementation speed | 3 | 3 | 5 |
| Mid-volume pricing | 2 | 4 | 4 |
Integration considerations
All three vendors integrate via FIX, kafka, REST, or proprietary streaming protocols. Practical considerations:
Order and trade data feed: full event-level granularity, not aggregated. Time-stamp precision to microseconds.
Customer reference data: account-level KYC linkage, related-account graphs, beneficial ownership where applicable.
On-chain data feed: wallet linkage, deposit and withdrawal address attribution. Native at Solidus; partner-integration at Eventus and Trillium.
Alert routing into existing case-management and SAR-filing workflows.
Audit-trail retention: minimum five years, supervisor-inspectable.
Pricing models
All three vendors price on a combination of platform-licence fee + per-venue or per-trade-volume tier. Indicative annual ranges for a mid-sized Class 3 venue:
Eventus: $300k–$800k+ annual depending on asset coverage and venue size; multi-year commitment standard.
Trillium: $200k–$500k annual; flexible commercial structure on smaller venues.
Solidus Labs: $180k–$450k annual; pricing has tightened as the product has matured.
These are indicative ranges only. Actual pricing varies by asset coverage, trade-volume tier, on-chain feed inclusion, and negotiated terms. Get firm written pricing on a defined trading-volume forecast before committing.
How to choose: a decision tree
Hybrid venue with significant traditional-markets activity, large EU institutional book, supervisor-credibility critical → Eventus.
Mid-sized venue, alert quality and analyst-workflow are the priority, no significant on-chain detection requirement → Trillium.
Crypto-native venue, on-chain forensics central, cross-venue manipulation is the dominant risk, fast deployment matters → Solidus Labs.
Larger CASPs sometimes run hybrid: Eventus for the multi-asset surveillance + Solidus for on-chain typologies, with results consolidated into one case-management system.
Frequently Asked Questions
Is market surveillance mandatory for all CASPs?
Mandatory for Class 3 operators — those operating a trading platform under MiCA. Class 1 (advice/marketing) and Class 2 (execution/portfolio) CASPs have lighter obligations focused on order-handling rather than market integrity. The substance bar is determined by Article 78 and ESMA technical standards.
Can I build surveillance in-house?
Technically possible, rarely sensible. The vendors have invested decades and hundreds of millions of dollars into typology libraries, calibration, and analyst tooling. Building equivalent depth in-house typically costs more than vendor fees and produces a worse outcome at supervisor inspection. The exception: very large, technically-sophisticated venues with dedicated quantitative-surveillance teams.
How does this interact with AML transaction monitoring?
Market surveillance and AML transaction monitoring are separate functions. Surveillance focuses on market integrity (manipulation, insider dealing); TM focuses on AML/CTF (mixers, sanctions, structured deposits). Some vendors offer integrated platforms; most CASPs run separate vendors with consolidated case management.
What's a STOR and when does it need filing?
A Suspicious Transaction and Order Report — filed to the home NCA without delay when the venue identifies suspected market abuse. The substance bar is documented suspicion; the venue is not the prosecutor. Filing cadence is one of the supervisor's clearest indicators that the surveillance function is operating; zero STORs in 12 months is itself a flag.
Should I worry about MAR even though I'm under MiCA?
MAR⁶[6] applies to crypto-assets that are also financial instruments — security tokens, tokenised funds, certain derivative products. MiCA's surveillance obligations are calibrated to be materially equivalent. CASPs handling both should treat the controls as a unified regime rather than two parallel ones.
Book a free regulatory bankability assessment. We respond within 24 hours.
Book AssessmentMiCA Compliance Guide for CASPs — the Class 3 authorisation framework that triggers Article 78 surveillance.
AML Compliance for Crypto Firms — the parallel TM regime that runs alongside market surveillance.
AML Audit for a Regulated Crypto Firm — the audit will increasingly score Article 78 surveillance alongside the AML programme.
Bank Diligence File for a Regulated Crypto Firm — banks now expect Article 78 surveillance evidence in CASP diligence.
Compliance Advisory — our service: surveillance vendor selection, threshold tuning, supervisor preparation.
Market surveillance is the most operationally demanding obligation a Class 3 CASP runs in 2026. The platform decision is foundational; the calibration decision is continuous. Pick the vendor whose strengths match the firm's risk profile, run a 60-day shadow-mode evaluation against real order flow, document every threshold change with rationale, and file STORs when the typology fires. The supervisor's question is not whether the vendor is best-in-class; it is whether the surveillance regime is materially effective at preventing market abuse on your venue.
Footnotes & Citations