The Exchange Failure Index

Method: what this register includes, and how

Included. An entry must meet all of the following: (1) a custodial platform held customer assets; (2) those assets were frozen, lost or misappropriated, so the platform did not return them on demand; (3) the platform entered an insolvency, liquidation, rehabilitation or criminal process; (4) the cause, the legal treatment of customer claims and the recovery are documented in public estate, court or regulator records or, where those could not be retrieved, in attributed reports of them, with any gap stated in the entry; and (5) the entry names one identifiable platform.

Excluded. DeFi protocol exploits where no custodian held the funds; stablecoin depegs; hacks that a solvent operator absorbed without an insolvency process (listed in a separate table); platforms that closed or wound down while returning customer assets on demand; combined rows for unnamed peers; and failures for which no public record of the cause and the legal process could be found for this review. Platforms meeting the inclusion criteria are not all listed: the eight entries were chosen as documented examples across triggers and jurisdictions, and the register makes no claim to be a complete list.

DeFi protocol exploits belong to the academy's risk cluster and stablecoin depegs to the stablecoin cluster. Absorbed hacks are listed in a second table because the customer outcome was decided by the company's balance sheet, with no court involved. Each entry is classified twice. The initial trigger is one of external intrusion (assets taken by outsiders), insider fraud or misappropriation (used only where a criminal court or a regulator has made a finding or published a conclusion, named in the entry with its date and current status), or balance-sheet insolvency (assets lost through the platform's business decisions). A second column records what followed, because several cases changed character: an intrusion can end in insolvency, and an insolvency can later produce a fraud conviction.

Recovery is quoted as the estate, court or regulator stated it, in its unit, for its creditor class, with the date of the notice, because a claim paid at 120 percent of a dollar value fixed at an earlier date and a claim paid in coins are different outcomes wearing similar percentages. Where an estate docket could not be retrieved for this review, the figure is marked "qualified" and the best available official notice is cited, or the figure is omitted and the gap stated. The register is a set of eight examples, selected because each has a public estate, court or regulator record: it is not a complete census or a random sample, so it supports no prevalence estimate, such as how often custodial platforms fail, what share of platforms fail or which trigger is most common across the industry. Recovery percentages are quoted in each estate's own terms, and a percentage in one row is not comparable with a percentage in another until each is read with the claim valuation behind it, as the section on what decides recovery explains.

The register, 2014 to mid-2026

Five entries carry the register's argument. Mt. Gox shows how one failure can pass through several categories: it began with thefts from its hot wallet over years, an external intrusion that a 2017 US indictment alleges was carried out by hacking (as the trustee's 2019 report notes), and ended in bankruptcy, with a decade to first distribution and a valuation history that is easy to misstate. The 2014 bankruptcy valued BTC claims at 50,058.12 yen; the 2018 rehabilitation plan re-based them at 749,318.83 yen, about fifteen times higher, and states that this calculation does not turn cryptocurrency claims into yen claims (Mt. Gox rehabilitation trustee, plan, sections 2.1.2, 2.3, 4.2.2). Creditors could elect repayment in BTC and BCH or in cash (section 4.7.2), and the early lump-sum option paid 21 percent of the valued claim (section 2.2(4)). Three numbers must be kept apart: the coins the trustee held (141,686 BTC as of 30 September 2019, per the trustee's report to the Tokyo District Court, against about 850,000 the company reported missing in 2014, as reported by NBC News), the claim valuation (the 2018 yen rate), and the market value of a BTC distribution on the day it landed in 2024 or later, which the trustee does not fix and which depended on the price that day.

FTX is classed as insider fraud or misappropriation on the strength of a criminal conviction: a jury convicted its founder, Sam Bankman-Fried, on seven counts including wire fraud and conspiracy to commit wire fraud on 2 November 2023 (US Attorney, SDNY, 2 November 2023); he was sentenced to 25 years, and the Department of Justice stated that he stole over 8 billion dollars of customers' money (US Department of Justice, 28 March 2024). The US Court of Appeals for the Second Circuit affirmed the judgment on 12 June 2026 (United States v. Bankman-Fried, No. 24-961), and his petition for a writ of certiorari was filed with the US Supreme Court on 10 September 2026 and docketed on 15 September 2026, with the government's response due on 15 October 2026 (US Supreme Court, docket No. 26-349). Its estate pays claims as a percentage of a dollar value fixed by the prices in a court-approved conversion table (US Bankruptcy Court, District of Delaware, order and exhibit, D.I. 7090, 7 February 2024). The convenience class received 120 percent, the Dotcom customer class 96 percent and the US customer class 100 percent cumulative by the March 2026 distribution (FTX Recovery Trust, 31 March 2026). All of those percentages are of that dollar figure, so a customer whose claim was a coin position was paid in cash against the table price of that coin. The order and exhibit reviewed here do not state the date the table prices refer to, so this register does not give one.

QuadrigaCX shows how the story told at a freeze can differ from the cause assessed later. After co-founder and chief executive Gerald Cotten died in December 2018, the losses were widely attributed to crypto assets left inaccessible by his death; a June 2020 review by staff of the Ontario Securities Commission said "this was not the case" and concluded that the collapse resulted from a fraud committed by Cotten. Staff found that he had opened accounts under aliases, credited himself with fictitious balances that he traded with clients, and lost about C$28 million trading client assets on other platforms, and that new client deposits were re-routed to fund other clients' withdrawals (OSC staff review, June 2020). The report states that these are not findings of fact by an OSC hearing panel and have not been tested before the OSC tribunal or a court; no proceeding followed because Cotten had died and Quadriga was bankrupt. Celsius is the custodial-yield case the yield cluster describes. Its Earn accounts held crypto worth about 4.2 billion dollars as of 10 July 2022, and the bankruptcy court held that those assets were property of the estate because Celsius's Terms of Use transferred title to it, which put Earn depositors in the unsecured queue (US Bankruptcy Court, SDNY, opinion of 4 January 2023). Its founder, Alex Mashinsky, pleaded guilty on 3 December 2024 to commodities fraud and securities fraud and was sentenced to 12 years on 8 May 2025 (US Department of Justice, 8 May 2025), so this case began as a balance-sheet failure and later produced a fraud conviction.

Cryptopia is the counter-example for the pillar's segregation dimension: the New Zealand High Court held that account holders' coins were property held on trust, so holders were beneficiaries rather than creditors, and the liquidators returned coins in specie, entitlement by entitlement (Ruscoe v Cryptopia, 8 April 2020; Grant Thornton, 11 December 2025). It is a different world from the commingled estates, and it was set up by the platform's terms and ledger practice before the hack.

Hacks absorbed by solvent operators (not failures)

These incidents appear in most lists of exchange disasters, and they are kept out of the register above because no estate, court or liquidator decided the customer outcome. The company paid.

By the operators' own accounts, these four platforms absorbed thefts up to about 1.5 billion dollars (Bybit, per the FBI's figure). They do not change the arithmetic of what a customer owns while the outcome is unknown, and operator statements about backing are attributed claims, corroborated here only to the extent an agency or auditor is cited.

What actually decides what customers get back?

In this register, legal treatment separated outcomes most clearly, and it was set before the failure, in the account terms and the platform's actual practice. Where the terms and the ledger supported a trust, as at Cryptopia, the court treated holders as owners and the liquidators returned coins (Ruscoe v Cryptopia, 8 April 2020). Where terms transferred title, as the Celsius court found for Earn accounts, or customer deposits were moved out of customer accounts, as the Second Circuit described at FTX, where some deposits "went into Alameda's bank account instead" (opinion of 12 June 2026), customers joined the unsecured queue behind administrative costs and secured claims. The segregation dimension in the exchange safety pillar is this column turned into a diligence question, and in the EU the Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) addresses the same point: Article 75(7), which applies from 30 December 2024 to crypto-asset service providers that hold clients' crypto-assets in custody, requires them to segregate those holdings from their own and to keep them legally segregated from the provider's estate so that the provider's creditors have no recourse to them, in particular in insolvency (ESMA, MiCA rulebook, Article 75).

Jurisdiction decided speed and form. Japanese bankruptcy and then civil rehabilitation took a decade to first distribution at Mt. Gox, with the repayment deadline now 31 October 2026 (trustee notice, 27 October 2025); the US Chapter 11 estates of 2022 reached effective dates within twelve to twenty-six months of their freezes and were distributing within two to three years; Canadian bankruptcy paid a first dividend four years after the Quadriga freeze; the Turkish criminal process produced a first-instance conviction in 2023, a partial reversal on appeal in 2025 and a retrial (as reported by Anadolu Agency), the founder died in custody on 1 November 2025 before it ended (Turkish Ministry of Justice, General Directorate of Prisons and Detention Houses, 2 November 2025), and no distribution to Thodex customers was identified for this review. The pillar's jurisdiction dimension is this column: which regime and courts stand behind the entity an account actually contracts with.

The unit is the register's quiet finding. Claims fixed in currency at a date convert a coin position into a currency claim at that date's price. FTX's estate values coin claims in dollars at the fixed prices of a court-approved conversion table (D.I. 7090), and its claims guidance tells creditors to multiply each coin quantity by the table price; Quadriga's court fixed 15 April 2019 rates, with BTC at C$6,739.08; Cryptopia calculates entitlements as at 14 May 2019 but pays them in the coins themselves. Mt. Gox is the case most often misdescribed: the plan's yen valuation uses the June 2018 rate, roughly fifteen times the 2014 bankruptcy rate, and the plan says in terms that this does not convert the claims into yen claims, so a creditor who elected BTC/BCH repayment received coins whose market value was set on the day of distribution. A customer paid 120 percent of a table price years later has been paid in full by the estate's arithmetic, while the coins' market value on the day of payment may be much higher, and the register quotes the estate's figure with its unit and date so that the two can be compared.

What preceded the failures, and what does that mean for a holder?

The pre-failure chapters of several entries share features. Withdrawal friction: Mt. Gox halted bitcoin withdrawals on 7 February 2014, citing a technical issue known as transaction malleability, and its site went offline on 24 February (as reported by CoinDesk, 4 March 2014); Celsius halted withdrawals in June 2022 (US Department of Justice, 8 May 2025); FTX filed for bankruptcy on 11 November 2022 because it could not meet customer withdrawal requests, nine days after the balance-sheet publication described below (US Court of Appeals, Second Circuit, 12 June 2026). Yield dependence: Celsius, Voyager and BlockFi all marketed fixed rates on custodial balances, the pattern the guide to guaranteed-return warning signs examines. Regulatory action: in a settled order of 14 February 2022, entered without BlockFi admitting or denying the findings, the SEC found that BlockFi's retail interest accounts were offered as unregistered securities, and BlockFi agreed to stop offering them to new US investors, nine months before its bankruptcy (SEC, order of 14 February 2022). Published balance-sheet questions: on 2 November 2022 a version of Alameda Research's balance sheet was published by a cryptocurrency news site, which the Second Circuit describes as "triggering widespread customer withdrawals from FTX" (opinion of 12 June 2026). A fixed rate alone is not evidence of fraud; in these three cases it accompanied a balance sheet that was lending customer assets.

For a holder, the register maps onto three questions that the exchange safety pillar describes: how much sits on a platform relative to what its functions require, whether the withdrawal path has been used at routine size, and what the account terms say about title. Platform statements about soundness are one input among several: in the Celsius case, the Department of Justice's sentencing release states that Celsius marketed itself as the "safest place for your crypto" while its founder used customer assets "to place risky bets" (US Department of Justice, 8 May 2025). The absorbed-hack table adds that a well-capitalised platform can survive a large theft; it does not change the legal character of a customer's balance while an incident is being resolved.

Each estate in this register announces its distribution channels in its own notices, listed in the sources. Failures and thefts attract follow-on fraud: the FBI has warned that companies falsely claiming to recover lost crypto charge upfront fees and then stop responding or ask for more, that private companies cannot issue seizure orders, and that suspicious contacts can be reported to the Internet Crime Complaint Center at ic3.gov or a local FBI field office (FBI IC3, PSA, 11 August 2023). Outside the US, the national police or fraud-reporting service is the equivalent route. No estate, agency or service can promise that losses will be recovered.

Frequently asked questions

Were most of these failures hacks?

Two of the eight began as external intrusions (Mt. Gox and Cryptopia), three are classed as insider fraud or misappropriation (QuadrigaCX on an Ontario Securities Commission staff review, Thodex on a first-instance conviction later partly overturned, FTX on a jury conviction affirmed on appeal) and three began as balance-sheet insolvencies (Celsius, Voyager, BlockFi). The categories overlap: Mt. Gox's hot-wallet thefts ran for years and ended in bankruptcy, and Celsius's balance-sheet failure was followed by its founder's guilty plea to fraud charges (US Department of Justice, 8 May 2025). The eight are examples and support no prevalence estimate: they cannot show how often each trigger occurs or which costs customers more across the industry, and this register makes no such ranking. The hacks that solvent operators absorbed are listed separately because the company itself paid customers and no estate was involved.

Did FTX customers really get more than they lost?

In the estate's unit, some did: the convenience class received 120 percent of claims valued at the court-approved conversion table, and larger customer classes reached 96 to 100 percent by March 2026 (FTX Recovery Trust releases). In coins, the answer depends on the market: a customer holding bitcoin at the freeze was paid cash against the fixed table price for BTC set by the court-approved conversion table (order and exhibit, D.I. 7090, 7 February 2024), whatever bitcoin traded at on the day of payment.

How were Mt. Gox claims valued, and why did it take a decade?

The 2014 bankruptcy valued BTC claims at 50,058.12 yen per coin. The civil rehabilitation that began on 22 June 2018 re-based them at 749,318.83 yen, the rate on the day before the commencement order, and the plan states that this does not convert them into yen claims; creditors chose repayment in BTC/BCH or in cash (trustee plan, sections 2.1.2, 2.3, 4.2.2, 4.7.2). The delay came from the bankruptcy, the conversion to rehabilitation so that coins could be returned in kind, litigation over the recovered coins, and creditor voting and exchange onboarding; repayments began in July 2024 and the deadline is now 31 October 2026 (trustee notices).

What made Cryptopia different?

A court finding that account holders' coins were property held on trust, so holders were beneficiaries rather than creditors (Ruscoe v Cryptopia, 8 April 2020). The platform's 2018 terms said as much, and its ledger allowed holders to be identified; the liquidators have since returned over NZ$487 million in coins (Grant Thornton, 11 December 2025).

Is this list of exchange failures kept up to date?

Each recovery figure carries the date of the estate notice it comes from, and the last-reviewed date at the top of the page records when the figures were last checked; no update schedule is promised. Several processes were still paying in 2026: the Mt. Gox trustee's repayment deadline is 31 October 2026 (trustee notice, 27 October 2025), the FTX Recovery Trust made its fourth distribution on 31 March 2026 (FTX Recovery Trust, March 2026), and the Cryptopia liquidators planned further top-ups toward full entitlements (Grant Thornton, 11 December 2025). To check a figure against the latest position, compare the date quoted here with the newest notice on the estate's own case site, listed in the sources.

Sources and further reading

Primary sources for this edition; URLs accessed 23 or 24 September 2026 as marked.

• Rehabilitation Plan (English translation). MtGox Co., Ltd. Rehabilitation Trustee, sections 2.1.2, 2.2, 2.3, 3, 4.2.2, 4.3.2.2, 4.7.2, 2021. https://www.mtgox.com/d/04y7ivbnz5gw.pdf (accessed 23 September 2026)
• Notice regarding Commencement of Repayments in Bitcoin and Bitcoin Cash. MtGox Co., Ltd. Rehabilitation Trustee, 24 June 2024. https://www.mtgox.com/img/pdf/20240624_announcement_en.pdf (accessed 23 September 2026)
• Announcement regarding repayments in Bitcoin and Bitcoin Cash made to some creditors. MtGox Co., Ltd. Rehabilitation Trustee, 5 July 2024. https://www.mtgox.com/img/pdf/20240705_01_announcement_en.pdf (accessed 23 September 2026)
• Announcement of change of repayment deadline to 31 October 2026. MtGox Co., Ltd. Rehabilitation Trustee, 27 October 2025. https://www.mtgox.com/img/pdf/20251027_1cc36334-e8b2-4fe4-8135-97d9a149e4f7_announcement_en.pdf (accessed 23 September 2026)
• Report to Tokyo District Court by Rehabilitation Trustee. MtGox Co., Ltd. Rehabilitation Trustee, 1 October 2019. https://www.mtgox.com/img/pdf/20191001_report.pdf (accessed 24 September 2026)
• Mt. Gox Works With Cops After $490M in Bitcoins Vanish. NBC News, March 2014 (news report citing Mt. Gox's filing). https://www.nbcnews.com/business/markets/mt-gox-works-cops-after-490m-bitcoins-vanish-n62346 (accessed 24 September 2026)
• The Non-Expert's Guide to the Mt. Gox Fiasco. CoinDesk, 4 March 2014 (news report citing Mt. Gox statements). https://www.coindesk.com/markets/2014/03/04/the-non-experts-guide-to-the-mt-gox-fiasco (accessed 24 September 2026)
• Japan's High Court Rejects Former Mt Gox CEO's Conviction Appeal. CoinDesk, 12 June 2020 (news report of the Tokyo High Court ruling). https://www.coindesk.com/policy/2020/06/12/japans-high-court-rejects-former-mt-gox-ceos-conviction-appeal (accessed 24 September 2026)
• Ruscoe v Cryptopia Ltd (in liquidation) [2020] NZHC 728. High Court of New Zealand, 8 April 2020. https://www.grantthornton.co.nz/globalassets/1.-member-firms/new-zealand/pdfs/cryptopia/civ-2019-409-000544---ruscoe-and-moore-v-cryptopia-limited-in-liquidation.pdf (accessed 23 September 2026)
• Liquidators' 14th Report to Shareholders and Creditors of Cryptopia Limited (in liquidation). Grant Thornton New Zealand, 11 December 2025. https://www.grantthornton.co.nz/globalassets/1.-member-firms/new-zealand/pdfs/cryptopia/14th-liquidators-report_cryptopia_dec25_final.pdf (accessed 23 September 2026)
• Cryptopia account holders receive $400m from liquidators. Grant Thornton New Zealand, 20 December 2024. https://www.grantthornton.co.nz/press/press-releases-2024/cryptopia-account-holders-receive-$400m-from-liquidators/ (accessed 23 September 2026)
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• Frequently asked questions regarding the dividend. Ernst & Young Inc. as trustee in bankruptcy of Quadriga, 2023. https://documentcentre.ey.com/api/Document/download?docId=37252&language=EN (accessed 23 September 2026)
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• Hükümözlü Faruk Fatih Özer'in İntiharı ile İlgili İddialara İlişkin Basın Açıklaması (press statement 2025/15). Republic of Türkiye Ministry of Justice, General Directorate of Prisons and Detention Houses, 2 November 2025. https://cte.adalet.gov.tr/Home/SayfaDetay/hukumozlu-faruk-fatih-ozerin-intihari-ile-ilgili-iddialara-iliskin-basin-aciklamasi02112025081301 (accessed 24 September 2026)
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• Celsius Network LLC, et al., case site (effective date 31 January 2024). Stretto. https://cases.stretto.com/celsius/ (accessed 23 September 2026)
• Memorandum Opinion and Order Regarding Ownership of Earn Account Assets, In re Celsius Network LLC, Case No. 22-10964. US Bankruptcy Court, Southern District of New York, 4 January 2023. https://www.govinfo.gov/content/pkg/USCOURTS-nysb-1_22-bk-10964/pdf/USCOURTS-nysb-1_22-bk-10964-7.pdf (accessed 24 September 2026)
• Celsius Distribution FAQ (archived). Celsius Network, 2024 (debtor statement). https://celsiusnetwork.medium.com/celsius-distribution-faq-1cdd323251ef (accessed 24 September 2026)
• Founder Of Celsius Sentenced To 12 Years For Fraud And Market Manipulation. US Department of Justice, Southern District of New York, 8 May 2025. https://www.justice.gov/usao-sdny/pr/founder-celsius-sentenced-12-years-fraud-and-market-manipulation (accessed 24 September 2026)
• Celsius Emerges from Chapter 11 and Commences Distributions of Over $3 Billion of Cryptocurrency to Creditors. Celsius Network via Business Wire, 31 January 2024. https://www.businesswire.com/news/home/20240131994097/en/Celsius-Emerges-from-Chapter-11-and-Commences-Distributions-of-Over-$3-Billion-of-Cryptocurrency-to-Creditors (accessed 23 September 2026)
• Celsius Begins Distributions of Funds Recovered Through Post Effective-Date Litigation. Celsius Network via Business Wire, 5 December 2024. https://www.businesswire.com/news/home/20241205039857/en (accessed 23 September 2026)
• Decision Regarding Approval of Disclosure Statement, Confirmation of Plan of Reorganization, and Related Matters, In re Voyager Digital Holdings, Case No. 22-10943. US Bankruptcy Court, Southern District of New York, 11 March 2023. https://www.govinfo.gov/content/pkg/USCOURTS-nysb-1_22-bk-10943/pdf/USCOURTS-nysb-1_22-bk-10943-1.pdf (accessed 24 September 2026)
• How much value was returned in the initial recovery? Voyager Digital support notice, 2023. https://support.investvoyager.com/hc/en-us/articles/16443115488667-How-much-value-was-returned-in-the-initial-recovery (accessed 23 September 2026)
• FTX Trading Ltd. case site (effective date 3 January 2025). Kroll Restructuring Administration. https://restructuring.ra.kroll.com/FTX/ (accessed 23 September 2026)
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• Digital Asset Estimates (claims valuation guidance: the Court entered the Order Granting Motion of Debtors to Estimate Claims Based on Digital Assets [Docket No. 7090] on 7 February 2024; claim value equals quantity times the table price). FTX support centre (estate), undated. https://support.ftx.com/hc/en-us/articles/24863020316948-Digital-Asset-Estimates (accessed 25 September 2026)
• Digital Asset Estimates. FTX support, 25 March 2024 (debtor statement). https://support.ftx.com/hc/en-us/articles/24863020316948-Digital-Asset-Estimates (accessed 24 September 2026)
• FTX Receives U.S. Bankruptcy Court Confirmation of its Plan of Reorganization. FTX via PR Newswire, 7 October 2024. https://www.prnewswire.com/news-releases/ftx-receives-us-bankruptcy-court-confirmation-of-its-plan-of-reorganization-302269152.html (accessed 23 September 2026)
• FTX Commences Initial Distributions to Convenience Class and Sets Next Distribution. FTX Recovery Trust via PR Newswire, 18 February 2025. https://www.prnewswire.com/news-releases/ftx-commences-initial-distributions-to-convenience-class-and-sets-next-distribution-302379212.html (accessed 23 September 2026)
• FTX Recovery Trust to Distribute More than $5 Billion to Creditors in Second Distribution on May 30, 2025. FTX Recovery Trust via PR Newswire, May 2025. https://www.prnewswire.com/news-releases/ftx-recovery-trust-to-distribute-more-than-5-billion-to-creditors-in-second-distribution-on-may-30-2025-302456976.html (accessed 23 September 2026)
• FTX Recovery Trust to Distribute Approximately $1.6 Billion to Creditors in Third Distribution on September 30, 2025. FTX Recovery Trust via PR Newswire, September 2025. https://www.prnewswire.com/news-releases/ftx-recovery-trust-to-distribute-approximately-1-6-billion-to-creditors-in-third-distribution-on-september-30--2025--302561856.html (accessed 23 September 2026)
• FTX Recovery Trust to Distribute Approximately $2.2 Billion to Creditors in Fourth Distribution on March 31, 2026. FTX Recovery Trust via PR Newswire, March 2026. https://www.prnewswire.com/news-releases/ftx-recovery-trust-to-distribute-approximately-2-2-billion-to-creditors-in-fourth-distribution-on-march-31--2026--302717707.html (accessed 23 September 2026)
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• North Korea Responsible for $1.5 Billion Bybit Hack (PSA250226). FBI Internet Crime Complaint Center, 26 February 2025. https://www.ic3.gov/PSA/2025/PSA250226 (accessed 23 September 2026)
• Increase in Companies Falsely Claiming an Ability to Recover Funds Lost in Cryptocurrency Investment Scams (PSA230811). FBI Internet Crime Complaint Center, 11 August 2023. https://www.ic3.gov/PSA/2023/psa230811 (accessed 24 September 2026)
• Fully Backed Within 72 hours: Bybit Maintains 1:1 Customer Assets Ratio in Latest Proof of Reserves Audited Report by Hacken. Bybit, February 2025 (operator statement). https://www.bybit.com/en/press/post/fully-backed-within-72-hours-bybit-maintains-1-1-customer-assets-ratio-in-latest-proof-of-reserves-audited-report-by-hacken-bltb767a9461133831f (accessed 23 September 2026)
• MiCA Article 75: Providing custody and administration of crypto-assets on behalf of clients. ESMA interactive single rulebook. https://www.esma.europa.eu/publications-and-data/interactive-single-rulebook/mica/article-75-providing-custody-and (accessed 23 September 2026)

To cite this report: Bron Academy, The Exchange Failure Index, first edition, September 2026, bron.org/academy.