# Article 15 — Batch file transfers of crypto-assets

**Source:** [Regulation (EU) 2023/1113 — EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1113)

In the case of a batch file transfer of crypto-assets from a single originator, Article 14(1) shall not apply to the individual transfers bundled together therein, provided that the batch file contains the information referred to in Article 14(1), (2) and (3), that that information has been verified in accordance with Article 14(6) and (7), and that the individual transfers carry the distributed ledger address of the originator, where Article 14(2), point (b), applies, the crypto-asset account number of the originator, where Article 14(2), point (c), applies, or the unique transaction identifier, where Article 14(3) applies.

## What this means in practice

Article 15 is a **narrow operational carve-out**, not a relaxation. It only applies where:

* the **originator is a single person**, and
* the batch file itself carries the full Article 14 originator/beneficiary information set, and
* that information has been verified, and
* each individual transfer still carries either the originator's DLT address, crypto-asset account number, or a unique transaction identifier.

In other words, batches let you avoid duplicating the originator data on every individual leg — but only if the batch wrapper carries the full information and the legs remain traceable back to it. Recital 41 makes the timing explicit: the information must be submitted **immediately and securely** with the batch transfer — after-the-fact submission is **not** permitted.

## Compliance checklist

* [ ] Batches must be from a **single originator** (multi-originator pools do not qualify).
* [ ] The batch file must carry the full Article 14(1), (2) and (3) information set.
* [ ] That information must be **verified** before the batch is transmitted (Art. 14(6)–(7) — AMLD5 CDD counts).
* [ ] Each individual transfer in the batch must carry the originator's DLT address, crypto-asset account number, or a unique transaction identifier — so that any single leg remains traceable to the batch's information set.
* [ ] Submit the batch's information simultaneously with the batch transfer — not after.


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