--- title: "Market Surveillance for MiCA Class 3 Operators: Eventus vs Trillium vs Solidus Labs (2026)" slug: market-surveillance-mica-class3 publishedAt: 2026-05-01T17:00:00Z author: Finconduit Editorial Team tags: MiCA, MAR, ESMA canonicalUrl: https://finconduit.com/resources/market-surveillance-mica-class3 --- # Market Surveillance for MiCA Class 3 Operators: Eventus vs Trillium vs Solidus Labs (2026) MiCA Class 3 operators must run market-integrity surveillance under Article 78 — wash trading, layering, spoofing, manipulation, insider dealing. The three dominant vendors compared on detection depth, asset coverage, integration complexity, alert quality, regulator-readiness, and pricing. [MiCA](https://eur-lex.europa.eu/eli/reg/2023/1114/oj)¹[^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. > **Note:** 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 [Eventus](https://www.eventus.com/)³[^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. [Trillium](https://trlm.com/)⁴[^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 Labs](https://www.soliduslabs.com/)⁵[^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. *Table: 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](https://www.eventus.com/) 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](https://trlm.com/) 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](https://www.soliduslabs.com/) 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. *Table: 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. > **Tip:** Run a 60\-day shadow\-mode evaluation with the chosen vendor before going live. Surveillance produces alerts; alerts compete for attention; analyst capacity is finite. The shadow period is where the firm tunes thresholds against its real order flow before the alerts become operational. Skipping shadow\-mode is the most common reason a Class 3 venue under\-performs in the first year of MiCA supervision. ## 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? [MAR](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R0596)⁶[^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. > **Call to action:** Book a free regulatory bankability assessment. We respond within 24 hours. ## Related Guides - [MiCA Compliance Guide for CASPs](/resources/mica-compliance-guide-casps) — the Class 3 authorisation framework that triggers Article 78 surveillance. - [AML Compliance for Crypto Firms](/resources/aml-compliance-crypto-6amld) — the parallel TM regime that runs alongside market surveillance. - [AML Audit for a Regulated Crypto Firm](/resources/aml-audit-crypto-firm) — the audit will increasingly score Article 78 surveillance alongside the AML programme. - [Bank Diligence File for a Regulated Crypto Firm](/resources/bank-diligence-file-crypto-firm) — banks now expect Article 78 surveillance evidence in CASP diligence. - [Compliance Advisory](/services/compliance) — 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. - [The MiCA Market Abuse Regime](/resources/mica-market-abuse-regime) — the Title VI insider\-dealing and market\-manipulation rules that market surveillance is built to detect. ## Footnotes [^1]: Regulation \(EU\) 2023/1114 \(MiCA\), OJ L 150, 9.6.2023. [^2]: European Securities and Markets Authority — MiCA technical standards and supervisory guidance for crypto\-asset markets. [^3]: Eventus — Validus market surveillance and trade\-monitoring platform serving exchanges, brokers, and crypto venues. [^4]: Trillium Surveyor — surveillance platform from Trillium Management; serves broker\-dealers, exchanges and digital\-asset venues. [^5]: Solidus Labs — market integrity platform built natively for digital\-asset markets, serving CASPs, brokers and custodians. [^6]: Regulation \(EU\) 596/2014 \(Market Abuse Regulation, MAR\), OJ L 173, 12.6.2014. --- Source: https://finconduit.com/resources/market-surveillance-mica-class3