Satu Mare, Romania, February 23rd, 2026 - Salvium said today that an independent legal opinion prepared by Gunnercooke GmbH, a German law firm, finds the project's native token, SAL, compliant with the EU's Markets in Crypto-Assets Regulation (MiCAR) and that nothing in MiCAR prevents SAL from being listed on exchanges authorised under the framework.
The legal note reinforces Salvium's long-held position that privacy-focused design and regulatory compliance can coexist. For the project and for privacy-centric digital assets more broadly, the opinion represents a milestone in clarifying how privacy mechanisms align with MiCAR's listing requirements.
How MiCAR frames token listings
MiCAR is the EU's comprehensive regulatory architecture for crypto-assets. The regulation establishes how tokens may be offered, traded, and serviced across EU member states. For a token to trade on a regulated EU exchange - platforms operating under MiCAR authorisation such as Coinbase, Bitpanda, Bitvavo, and OKX - it must fit a MiCAR classification and meet the rules that accompany that classification.
Within MiCAR, Article 76(3) has been particularly salient for privacy-focused projects. That provision prevents exchanges from admitting crypto-assets that have "inbuilt anonymisation functions" unless the exchange can identify holders and the transaction history. The provision has been a key reason cited for delistings of privacy-oriented tokens from some European trading venues, and it has commonly been interpreted as an effective prohibition on privacy coins.
Salvium has disputed an expansive reading of that provision. The project has maintained that MiCAR does not ban privacy-enabled features outright; instead, the regulation poses a specific operational test - whether exchanges can identify the holders and their transaction history.
Scope and basis of the independent analysis
Salvium engaged Gunnercooke GmbH to perform an independent legal review of SAL's compliance with MiCAR. The law firm's analysis relied on Salvium's publicly available documentation hosted in the project's GitHub repository, including the white paper and litepaper.
The opinion addresses SAL's classification under MiCAR and evaluates whether SAL's transaction privacy mechanisms create an impediment to admission to trading under Article 76(3).
Main findings from the opinion
- Classification: SAL is an "Other Crypto-Asset" according to MiCAR. The analysis confirms that SAL meets MiCAR's definition of a crypto-asset and is not a financial instrument under MiFID II, not an e-money token, not an asset-referenced token, nor a utility token. This places SAL in the same broad category as Bitcoin and many Layer-1 native tokens under MiCAR's taxonomy.
- Privacy features and Article 76(3): While SAL incorporates privacy-by-default transaction capabilities that could be characterised as an inbuilt anonymisation function, the opinion finds these features do not trigger the prohibition on admission to trading under Article 76(3). The legal reasoning centers on the practical ability of crypto-asset service providers operating trading platforms to identify SAL token holders and to review relevant transaction history.
- Functionality enabling compliance: The assessment states that SAL's technical structure provides exchanges with the means to identify holders and inspect transactions. The opinion highlights a combination of mechanisms - custodial onboarding, CARROT addressing for deposit attribution, selective disclosure via viewkeys, and SPARC for return handling and spend-authority proofs - as collectively furnishing exchanges with the operational tools needed to satisfy regulatory obligations while listing SAL.
- Admission to trading: The opinion concludes that admitting the SAL token to trading on MiCAR-authorised exchanges is legally permissible under the circumstances described in the reviewed documentation.
Practical implications
The legal opinion is intended to give exchanges the documented legal comfort necessary to assess SAL for listing under MiCAR. It directly confronts the central concern that has prompted privacy token delistings within Europe - Article 76(3) - and it contends that Salvium's protocol was architected to satisfy the regulatory tests set by the provision.
The full legal analysis is available to exchanges and regulatory authorities that are evaluating SAL. The project has stated that members of its community can confirm the opinion was produced independently by Gunnercooke GmbH and that the conclusions align with the summary provided by Salvium.
Context from Salvium's development thesis
Salvium's origin story, as the project describes it, began with a fork from Monero. The stated thesis underpinning the effort was that the crypto industry is moving toward increased regulation and that privacy coins face the risk of exclusion from regulated markets unless they provide mechanisms for regulated entities to satisfy their obligations. Salvium's design choices - including CARROT, SPARC, viewkeys, and an exchange mode - are presented as engineered responses to that regulatory reality rather than as compromises of privacy.
According to the project's description, these features are the reason SAL can be considered for listing on regulated platforms while other privacy coins have faced delistings. The argument is that privacy that only operates outside the regulated financial system will not serve the majority of people who need it.
What Salvium says about product capabilities
Salvium positions itself as a privacy-first layer-one protocol that marries Monero-derived privacy techniques with compliance-enabling features and planned decentralized finance capabilities. Built on modified CryptoNote technology with audited innovations, Salvium's stated functionality includes private transactions, native staking, and prospective smart contract support while aiming to meet global regulatory obligations.
For media or technical enquiries and for exchange integration assistance, Salvium lists contact routes through its community Discord and at salvium.io. The project provided an email contact for its development team as [email protected].
Closing observation
By securing an independent legal opinion that finds SAL consistent with MiCAR's requirements, Salvium says it has created a pathway for a privacy-centric Layer-1 token to be evaluated by regulated exchanges in the EU. The opinion focuses narrowly on whether the token's privacy features prevent exchanges from identifying holders and transaction history, and concludes that, given the protocol's built-in disclosure and attribution tools, the SAL token can be admitted to trading on MiCAR-authorised platforms.