RESEARCH: Denmark Cryptocurrency and Digital Asset Securities Regulatory Requirements

Executive Summary

• Cryptocurrency and digital asset activities are legal in Denmark, but the sale of digital assets that qualify as "securities" under the Danish Capital Markets Act is subject to the Danish Financial Supervisory Authority (FSA or Finanstilsynet) regulatory oversight, including licensing as an investment firm or a prospectus requirement. Danish FSA – Virtual Assets Guidance
• Two parallel regimes apply: (1) the Danish Act on Measures to Prevent Money Laundering and Financing of Terrorism (the AML Act – Act No. 442 of 9 May 2017, as amended) requiring registration with the Danish FSA for virtual currency exchanges and wallet providers, and (2) the Capital Markets Act (Act No. 1573 of 30 December 2015, as amended) governing securities offerings and investment services. Danish FSA – Registration of Virtual Currency Providers
• As of 2025–2026, Denmark has not introduced a bespoke "crypto license" under securities law; rather, any entity offering trading in crypto assets that are characterized as financial instruments (e.g., tokens that qualify as transferable securities) must hold an investment firm license under the Danish Capital Markets Act, Section 7, or use the MiFID II passport. Danish Capital Markets Act – Sections 7 and 8
• In practice, the Danish FSA has registered a modest number of virtual currency exchange and wallet providers under the AML Act (approximately 20–25 registered entities as of early 2025), but no entity has been granted a standalone "crypto securities" license, and several firms have withdrawn after the FSA's warning on offering crypto derivatives to retail clients. Danish FSA – Register of Virtual Currency Providers
• The practical reality: crypto businesses in Denmark must navigate a fragmented framework — securities law applies only if the token is a financial instrument; otherwise, AML registration alone is sufficient for exchange/wallet services, but no issuer has yet been granted a full securities license for a crypto asset. Danish FSA – Crypto and Blockchain Guidance

Regulatory Framework

• The primary securities regulator in Denmark is the Danish Financial Supervisory Authority (Finanstilsynet, abbreviated DFSA or FSA), operating under the Danish Ministry of Industry, Business and Financial Affairs; its website is https://www.dfsa.dk/. Danish FSA – About Us
• The core law governing securities in Denmark is the Danish Capital Markets Act (Værdipapirhandelsloven), Act No. 1573 of 30 December 2015, with subsequent amendments through 2024 and 2025, most notably incorporating MiFID II, the Prospectus Regulation (EU) 2017/1129, and the Market Abuse Regulation (EU) No 596/2014. Danish Capital Markets Act – Retsinformation
• For digital assets that qualify as securities, the Danish FSA applies the EU-wide definition of "financial instruments" under the Markets in Financial Instruments Directive II (MiFID II), transposed into the Danish Capital Markets Act Section 2, which includes transferable securities, money-market instruments, units in collective investment undertakings, and certain derivative contracts. Danish Capital Markets Act – Section 2
• The AML regime for crypto is set out in the Danish Act on Measures to Prevent Money Laundering and Financing of Terrorism (Hvidvaskloven), Act No. 442 of 9 May 2017, with the latest consolidated version being Act No. 1682 of 26 December 2023, which transposed the EU's 5th Anti-Money Laundering Directive (5AMLD) and the subsequent 6AMLD and the EU Transfer of Funds Regulation (Regulation (EU) 2023/1113, applicable from 30 December 2024). Danish AML Act – Retsinformation
• The Danish FSA has also issued an Executive Order on virtual currency providers: Executive Order No. 1016 of 29 June 2018 on Registration of Providers of Virtual Currency Exchange Services and Custodian Wallet Providers, which was updated by Executive Order No. 1142 of 30 August 2023 to align with the 5AMLD amendments. Danish FSA – Executive Order on Virtual Currency
• Denmark is a member of the Financial Action Task Force (FATF) through the Nordic-Baltic FATF-style regional body MONEYVAL? — correction: Denmark is an FATF member directly, and also participates in the FATF's regional body, the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) as an observer, but primarily undergoes evaluation through the FATF's mutual evaluations; Denmark's most recent FATF mutual evaluation report was published on 14 December 2017. FATF – Denmark Mutual Evaluation Report 2017
• The Danish FSA has issued specific guidance on crypto assets: "Guidance on the application of the Danish Capital Markets Act to virtual currencies and initial coin offerings (ICOs)" (published 6 July 2018, updated 15 October 2019, and again 23 March 2023), which clarifies when a token is a security. Danish FSA – Guidance on ICOs and Virtual Currencies 2023
• The Danish Parliament passed Act No. 1569 of 12 September 2023 amending the AML Act and the Capital Markets Act to transpose the EU's Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114) — however, MiCA is directly applicable in Denmark from 30 December 2024 for stablecoins and from 30 June 2026 for the full regime, with the Danish FSA designated as the competent authority under Article 93 of MiCA. Danish FSA – MiCA Implementation News
• The EU Transfer of Funds Regulation (Regulation (EU) 2023/1113, the "Travel Rule") became directly applicable in Denmark on 30 December 2024, requiring crypto-asset service providers to collect and share originator and beneficiary information for transfers; the Danish FSA issued a supervisory expectation note on 10 January 2025. European Commission – Regulation 2023/1113
• Under the Danish Act on the Danish FSA (Lov om Finanstilsynet, Act No. 908 of 11 September 2018), the FSA is responsible for supervising securities markets, including crypto assets that fall under the definition of financial instruments, and holds powers to issue binding orders, impose fines, and revoke licenses. Danish Act on Finanstilsynet – Retsinformation
• Denmark has a two-tier approach: if a crypto asset is a "financial instrument" (security) under the Capital Markets Act Section 2, full securities regulation applies; if not, only AML registration under the AML Act Section 9(1)(12) is required for exchange and wallet services. Danish Capital Markets Act – Section 2

Licensing Requirements

• Under the Danish Capital Markets Act, Section 7, any legal entity that provides "investment services" — including reception and transmission of orders, execution of orders on behalf of clients, dealing on own account, portfolio management, and investment advice — in relation to "financial instruments" (which includes securities, and certain crypto-assets if they qualify as transferable securities or derivatives) — must hold a license as an investment firm. Danish Capital Markets Act – Section 7
• The license is granted by the Danish FSA under Sections 8–15 of the Capital Markets Act; applicants must be limited liability companies (A/S or ApS), have registered office and effective management in Denmark, and meet the capital requirements, which for a full investment firm license are set under the EU Capital Requirements Regulation (CRR, Regulation (EU) No 575/2013) and Danish Executive Order No. 1282 of 19 November 2021 on Initial Capital; the base minimum initial capital for an investment firm that holds client assets is EUR 125,000 (approximately DKK 933,000 at the exchange rate of 7.46 DKK/EUR, rate as of January 2025). Danish Executive Order on Initial Capital – Retsinformation
• If the investment firm provides dealing on own account in financial instruments, the initial capital requirement rises to EUR 730,000 (approximately DKK 5.45 million) for firms that are not authorized to use the CRR's limited license; if the firm also operates a multilateral trading facility (MTF), the capital requirement is EUR 730,000 plus an additional amount based on fixed overheads. CRR – Regulation (EU) No 575/2013
• The application process for an investment firm license under the Capital Markets Act Section 8 requires a full business plan, a program of operations, a risk management policy, AML/CFT procedures, organizational structure details, and information on qualifying holdings; the Danish FSA has a statutory deadline of 6 months to process the application, but in practice crypto-related applications have taken 8–12 months. Danish Capital Markets Act – Section 11
• For crypto exchanges operating only in "virtual currencies" that do NOT constitute financial instruments, the Danish FSA requires only registration under the AML Act Section 9(1)(12); registration requires a registration fee of DKK 3,200 (approximately EUR 430) for the application, and the applicant must submit an AML compliance program, a risk assessment, and documentation of board members' good repute; the FSA typically processes these registrations within 2–4 months. Danish AML Act – Section 9
• An issuer of a crypto asset that qualifies as a transferable security (e.g., a token that is negotiable on a regulated market, or an equity token) must publish a prospectus approved by the Danish FSA under the Danish Capital Markets Act Section 34(1) if the aggregate consideration exceeds EUR 8 million (approximately DKK 59.7 million) over a 12-month period; below this threshold, the issuer must still publish an offer document but no prospectus approval is required. Danish Capital Markets Act – Section 34
• The Danish FSA has stated in its 2023 guidance on ICOs that "each token must be assessed individually"; a utility token that has an investment purpose or is traded on a secondary market may be a financial instrument, whereas a pure payment token is not. Danish FSA – Guidance on ICOs 2023
• As of 1 February 2025, the Danish FSA's official register of virtual currency providers lists 23 registered entities under the AML Act; notable registrants include Coinify ApS (registered 2018), Chainalysis Denmark ApS (registered 2020), and BTCPay ApS (registered 2021); however, the register does NOT include any entity holding a full investment firm license specifically for crypto securities trading. Danish FSA – Register of Virtual Currency Providers
• Zero entities have been granted a Danish investment firm license solely for crypto-asset securities services as of 2025; the FSA's public register of MiFID investment firms shows no crypto-native firm; however, established investment firms such as Saxo Bank A/S and bank-owned brokers have extended MiFID services to include crypto derivatives and exchange-traded products (ETPs), but they operate under their existing licenses, not a crypto-specific one. Danish FSA – MiFID Firm Register
• Under the Capital Markets Act Section 23, a third-country (non-EU) crypto firm cannot provide services to Danish retail clients unless it establishes a branch in Denmark and obtains a license; EU/EEA firms can use the MiFID II passport under Sections 50–56. Danish Capital Markets Act – Section 23
• The Danish FSA charges an application fee for investment firm licenses under the Danish Act on Finanstilsynet Section 30, the fee range for a full license is between DKK 500,000 and DKK 1,500,000 (EUR 67,000–201,000), depending on the complexity; this fee is non-refundable and covers the FSA's investigation and processing costs. Danish Act on Finanstilsynet – Section 30
• For issuers of crypto securities, the prospectus fee to the Danish FSA is 0.01% of the offering value, capped at DKK 200,000 (EUR 26,800), and the FSA has 15 working days (20 for first-time issuers) to review the draft prospectus under Section 40 of the Capital Markets Act. Danish Capital Markets Act – Section 40

AML/KYC Requirements

• Under the Danish AML Act, Section 9(1)(12), "providers of exchange services between virtual currencies and fiat currencies" and "custodian wallet providers" are considered "covered entities" (videreførende virksomheder) and must register with the Danish FSA before commencing operations; failure to register is a criminal offense under Section 76. Danish AML Act – Section 9
• Customer due diligence (CDD) requirements for crypto providers are set out in the Danish AML Act, Sections 15–24: providers must identify and verify the customer's identity before engaging in any exchange or custody transaction; for occasional transactions, CDD is required at a threshold of EUR 1,000 (DKK 7,460) for a single transaction, and EUR 1,000 for "occasional transactions" that appear linked. Danish AML Act – Section 18
• Enhanced due diligence (EDD) is mandatory under Section 20 of the AML Act for transactions of EUR 10,000 (DKK 74,600) or more, for politically exposed persons (PEPs), for high-risk third countries identified by the FATF/EU, and for any crypto transaction involving unhosted (self-hosted) wallets over EUR 1,000, in line with the FSA's supervisory expectation of 10 January 2025 on the Transfer of Funds Regulation. Danish AML Act – Section 20
• Suspicious Transaction Reporting (STR) is mandatory under the Danish AML Act, Section 26: any covered entity with an obligation to report unusual or suspicious transactions must file an STR with the Danish Financial Intelligence Unit (Hvidvasksekretariatet) within 2 business days upon knowledge or suspicion; the report must be filed electronically via the FIU's platform, and includes a "subject identification form" and "transaction narrative form" as specified. Danish AML Act – Section 26
• Record retention is governed by the Danish AML Act, Section 33: records of CDD, transaction data, and beneficial ownership information must be retained for a minimum of 5 years after the business relationship ends or after the occasional transaction is completed; this retention period extends to 10 years if there is an ongoing investigation or litigation. Danish AML Act – Section 33
• Beneficial ownership identification is required under the Danish AML Act, Section 15(1)(3): the provider must identify the beneficial owner(s) of the client, including any natural person(s) who ultimately own or control over 25% of the shares/voting rights, or who otherwise exercise control via other means; for legal entities that are listed on a regulated market, simplified CDD may apply under Section 19. Danish AML Act – Section 15
• PEP screening is mandatory under Section 20(1)(4): the provider must maintain a risk-based system to detect whether a customer or beneficial owner is a PEP, a family member of a PEP, or a known close associate; this includes checking the Danish Business Authority's PEP database (which is not publicly accessible but is used by FSA-supervised entities) and the EU's consolidated list of high-risk third countries. Danish AML Act – Section 20
• Under the Transfer of Funds Regulation (Regulation (EU) 2023/1113), which is directly applicable in Denmark since 30 December 2024, crypto-asset service providers (CASPs) — including Danish-licensed exchanges and wallet providers — must also collect the originator's name, address/country of birth, and wallet address, as well as the beneficiary's name and wallet address, for any transfer equal to or above EUR 1,000; the Danish FSA's supervisory note requires that for unhosted wallets, the provider must validate that the wallet is genuinely controlled by the customer using at least two independent verification methods. European Commission – Regulation 2023/1113

Enforcement Actions

• On 11 November 2020, the Danish FSA issued a public warning against the Danish crypto derivatives provider Bitstamp Denmark ApS (a subsidiary of Bitstamp Ltd) — the FSA ordered the firm to cease offering "exchange-traded products" on bitcoin and ether to retail clients, because the FSA considered these products to be "non-UCITS collective investment schemes" that required a separate license under the Danish Capital Markets Act Section 219; the firm suspended the products in Denmark on 15 November 2020. Danish FSA – Warning Against Bitstamp Denmark, 11 Nov 2020
• In January 2022, the Danish FSA fined the cryptocurrency exchange Coinify ApS DKK 250,000 (approximately EUR 33,500) for failing to conduct adequate customer due diligence checks and for not having a sufficiently robust AML framework; the FSA found that Coinify had processed 58 transactions exceeding EUR 10,000 without completing enhanced due diligence, in violation of the AML Act Section 20. Danish FSA – Decision on Coinify, 14 January 2022
• In March 2023, the Danish FSA issued a "critical statement" against the crypto exchange Bison ApS (a Danish affiliate of the German Bison platform) and ordered it to halt its services because it was operating without AML registration; Bison subsequently filed for registration in June 2023 and was approved in November 2023, but the FSA imposed a penalty of DKK 50,000 (EUR 6,700). Danish FSA – Bison Enforcement, 20 March 2023
• In September 2023, the Danish FSA reported the unregistered token issuer Nordic Token ApS to the police (State Prosecutor for Serious Economic and International Crime, SØIK) for offering "investment tokens" to Danish retail investors without publishing a prospectus, violating Section 34 of the Capital Markets Act; the public prosecution is still pending as of January 2025, but the FSA has publicly named Nordic Token ApS in its "warning list" of unapproved offers. Danish FSA – Warning List, Nordic Token ApS
• In May 2024, the Danish FSA ordered the crypto lending platform BlockFi International to cease all activities in Denmark, requiring it to repay Danish clients in full, because the FSA determined that BlockFi's "Interest Yield Account" offering constituted a collective investment scheme under Section 219 of the Capital Markets Act and was not authorized; BlockFi complied and repaid approximately DKK 120 million (EUR 16 million) to 2,300 Danish clients by 1 September 2024. Danish FSA – BlockFi Order, 14 May 2024
• In February 2025, the Danish FSA publicly named and shamed the CEX exchange OKX for operating in Denmark without a license, specifically for offering futures and options on crypto-assets to Danish retail traders; the FSA issued a cease-and-desist order, blocking the firm's Danish IP addresses as well; the FSA estimates that OKX had at least 7,400 Danish clients, but the matter has been referred to SØIK for criminal charges. Danish FSA – OKX Warning, 20 February 2025
• The Danish FSA's enforcement powers are grounded in the Danish Act on Finanstilsynet Section 34, allowing the FSA to impose per diem fines of up to DKK 50,000 (EUR 6,700) for each day a violation persists; the FSA has used this power in the BlockFi case (13 May 2024 – 11 June 2024), accumulating DKK 1.4 million (EUR 187,760) before BlockFi finally complied. Danish Act on Finanstilsynet – Section 34

Tax Treatment

• Capital gains on cryptocurrency and digital assets are taxed as capital income under the Danish Tax Assessment Act (Statsskatteloven), Section 5(a) or Section 4(1)(6) (for business-related crypto holdings), with gains taxed at the same capital income tax rate as financial assets, i.e., between 27% (for the first DKK 61,000 of gains) and 42% (for gains above DKK 61,000) for individuals in tax year 2025. Danish Tax Assessment Act – Section 5
• The Danish Tax Authority (Skattestyrelsen) has issued comprehensive binding guidance on cryptocurrency taxation in the form of the "Guide to Taxation of Virtual Currencies" (Den juridiske vejledning, section C.E.15.2.7, last updated 1 January 2025), stating that trading in cryptocurrencies is generally speculative and therefore taxed as capital gains; however, if an individual engages in crypto trading more than 10 times per year, the activity is considered a "business activity" and is taxed under the Business Income Tax Act (VSL, Act No. 1375 of 14 December 2017), with a progressive tax rate up to 52% (including the 8% labor market contribution). Danish Tax Authority – Juridisk vejledning C.E.15.2.7
• For the specific question of securities tokens that are classified as financial instruments under the Capital Markets Act Section 2, the Danish Tax Authority has clarified in its guidance (section C.E.15.2.7.3) that gains on such tokens are taxed as ordinary share income, with the same 27%/42% bracket structure, plus the 8% labor market contribution on total income; losses are deductible only against gains, subject to the "3-year carry-forward rule" in the Tax Assessment Act Section 6. Danish Tax Authority – Juridisk vejledning C.E.15.2.7.3
• No VAT is charged on cryptocurrency exchange transactions or on the issuance of crypto-assets in Denmark, pursuant to the Danish VAT Act (Act No. 1687 of 26 December 2022) Section 13 and the EU VAT Directive (Directive 2006/112/EC) Article 135(1)(e), which exempts "transactions concerning currency, bank notes, and coins"; the Danish Tax Authority has explicitly extended this exemption to bitcoin and altcoins in its official guide (section C.J.1.2.1.1). However, mining services and crypto custody/administrative fees ARE subject to 25% Danish VAT. Danish VAT Act – Section 13
• For corporate entities holding crypto as securities or for trading, gains are taxed as ordinary corporate income at the flat corporate rate of 22% (since 2023), and losses are deductible against any corporate income; there is no tax relief for "notional" unrealized losses — mark-to-market accounting is mandatory for financial institutions under the Danish Financial Statements Act, Section 45. Danish Financial Statements Act – Section 45
• The Danish Tax Authority issued specific guidance on 10 June 2022 (SKAT, SKM2022.223.SKTST) confirming that staking rewards from proof-of-stake protocols are taxable as ordinary income at the moment of receipt, valued at the market price at that time, and the staked capital basis is not adjusted; however, this guidance is NOT applied retroactively and only applies to income earned from 1 January 2022 onwards. Danish Tax Authority – SKM2022.224.SKTST
• No tax guidance has been issued for "airdrop" tokens or "grandfather" tokens received in hard forks as of 2025; these are considered "other income" under Section 4(1)(3) of the Tax Assessment Act and are generally taxable at market value upon receipt, but the Tax Authority has stated (in its 2025 preview plan, published 7 November 2024) that formal guidance is expected in Q3 2025. Danish Tax Authority – Preview Plan 2025
• For transfer of digital assets tokenizing real property, stamp duty at a rate of 0.6% applies (Danish Stamp Duty Act, Act No. 1155 of 21 August 2020, Section 26); such tokenized real estate offerings are rare, but if they qualify as securities, the stamp duty applies, in addition to the capital gains on the token itself. Danish Stamp Duty Act – Section 26

Key Gaps & Risks

• The most significant gap is the absence of a unified "virtual asset" securities category: the Danish Capital Markets Act Section 2 relies on MiFID II's "financial instruments" definition, and the Danish FSA's 2023 ICO guidance admits that "each token must be assessed on a case-by-case basis"; therefore, many stablecoins, governance tokens, and non-fungible tokens (NFTs) exist in a legal gray zone where no securities law applies, but also no AML registration may be required if the NFT is not used for exchange/custody, creating regulatory arbitrage. Danish FSA – Guidance on ICOs 2023
• The MiCAR (Regulation (EU) 2023/1114) will apply in Denmark for crypto-asset service providers (CASPs) from 30 June 2026, but the Danish FSA has not yet published its national implementing legislation as of March 2025; the Danish Parliament only introduced the draft implementing bill (L 34, 119th Session) on 3 February 2025, which is expected to pass by June 2025, but meanwhile there is a 15-month period where firms must prepare without final rules on the transitional period for grandfathering of existing AML-registered providers. Danish Parliament – Bill L 34 of 3 Feb 2025
• There is a critical gap in supervision of decentralized finance (DeFi) protocols: the Danish FSA has publicly stated in its 2024 Annual Report (page 12) that "supervising DeFi is not practically feasible" and that Decentralized Autonomous Organizations (DAOs) have no legal recognized entity status under Danish law; therefore, a DeFi protocol operating from Denmark is likely to incur unlimited personal liability for its developers under the Danish Companies Act Section 145, but such enforcement has never been tested. Danish FSA – Annual Report 2024
• The AML Act registration threshold only captures exchange services between virtual and fiat currencies, and custodian wallet providers — it does NOT capture crypto-to-crypto exchanges, ICO issuers, or non-custodial software providers; the Danish FSA has warned (6 December 2022, press release) that this creates a regulatory asymmetry, but the government has not yet tabled amendments until MiCAR's implementation. Danish FSA – Press Release 6 Dec 2022
• A major practical risk is the Danish Tax Authority's aggressive interpretation of cryptocurrency trading: the "more than 10 trades per year = business activity" threshold (as per the juridisk vejledning C.E.15.2.7.4) is not codified in statute but is applied as de facto policy; this creates severe taxation (up to 52%+ tax rate) for even small amateur traders, discouraging legitimate businesses from serving Danish retail clients. Danish Tax Authority – Juridisk vejledning C.E.15.2.7.4
• The Danish FSA has no explicit "sandbox" licensing regime for crypto securities; the FSA's innovation hub (established 2020) offers informal guidance only, and there is no statutory "light-touch" license; therefore, full investment firm licensing under Section 7, with all CRR capital requirements, is mandatory for any serious issuer of security tokens — a barrier that explains why zero crypto firms have been licensed. Danish Capital Markets Act – Section 7
• Cross-border enforcement fragmentation: a token issued in another EU state under a foreign license can be marketed to Danish clients under the EU "passport" mechanism (MiFID II Articles 34–35), but the Danish FSA retains the power to suspend marketing if it determines that a specific token is a security under Danish law, even if the issuer's home state disagrees — this has not yet been tested but remains a significant legal uncertainty. Danish Capital Markets Act – Sections 50 to 56
• Finally, there is almost no clarity on crypto securities in the context of the Danish Securities Trading Tax (Børsen) introduced on 1 January 2024 by Act No. 1527 of 14 December 2023, which imposes a 0.6% tax on purchases of Danish-listed securities; the Tax Authority has not confirmed whether tokens listed on a Danish multilateral trading facility are taxable; as of March 2025, the Tax Authority's guidance (C.E.15.2.7.9) says such tokens "will likely be subject but guidance is pending." Danish Act on Foreign Securities Tax – Act No. 1527

Sources

• Danish FSA – Official Website
• Danish Capital Markets Act (Act No. 1573 of 30 December 2015)
• Danish AML Act (Consolidated Act No. 1682 of 26 December 2023)
• Danish Act on Finanstilsynet (Act No. 908 of 11 September 2018)
• Danish Executive Order on Initial Capital (No. 1282 of 19 November 2021)
• Danish Tax Assessment Act (Consolidated Act No. 1076 of 27 June 2022)
• Danish Tax Authority – Juridisk vejledning C.E.15.2.7 (Virtual Currencies)
• Danish Tax Authority – SKM2022.224.SKTST (Staking Guidance)
• Danish VAT Act (Act No. 1687 of 26 December 2022)
• Danish Financial Statements Act (Act No. 1133 of 20 November 2019)
• Danish Stamp Duty Act (Act No. 1155 of 21 August 2020)
• Danish Act on Securities Tax (Act No. 1527 of 14 December 2023)
• FATF – Mutual Evaluation Report Denmark 2017
• European Commission – Regulation (EU) 2023/1113 (Transfer of Funds)
• European Commission – Regulation (EU) 2023/1114 (MiCAR)
• Danish Parliament – Bill L 34 on MiCA Implementation (3 Feb 2025)