Principles of complaint management
Principles of Complaints Management of Huddlestock GmbH
pursuant to BT 12.2 MaComp, Art. 26 MiFID II Delegated Regulation (EU) 2017/565, Art. 71 MiCAR and Delegated Regulation (EU) 2025/294
Last updated: 1 of October, 2026
1. Complaints Management Function and Responsibility
The complaints function under Art. 26 MiFID II Delegated Regulation (EU) 2017/565, BT 12 MaComp (for investment services and ancillary investment services) as well as under Art. 71 MiCAR in conjunction with Delegated Regulation (EU) 2025/294 (for crypto-asset services) is assigned to the Client Service department of Huddlestock GmbH.
Contact details of the complaints management function:
Huddlestock GmbH
c/o Scaling Spaces”
Client Service
Isartorplatz 8 80331 Munich, Germany
Email: clientservices@huddlestock.com
Phone: 0049-8151-1876650
Huddlestock GmbH is licensed as an investment firm (Wertpapierinstitut) under the WpIG and acts as a liability umbrella (Haftungsdach) within the meaning of section 3(2) WpIG for tied agents. For investment services and ancillary investment services, the handling of client complaints is, as a rule, carried out in full by the tied agent – from receipt through categorisation and examination to the decision and documentation – in the name of, and under the liability of, Huddlestock GmbH (section 3(2) WpIG in conjunction with Art. 29 MiFID II). For crypto-asset services, which Huddlestock GmbH provides directly itself within the meaning of Art. 3(1)(16) MiCAR, MiCAR does not provide for a concept equivalent to the tied agent model. In these cases, the handling of complaints relating to crypto-asset services is transferred to the tied agent acting as a service provider by way of an outsourcing arrangement pursuant to Art. 73 MiCAR; the legal basis for this is the respective outsourcing agreement between Huddlestock GmbH and the service provider. Irrespective of the applicable legal construction – attribution under section 3(2) WpIG on the one hand, outsourcing under Art. 73 MiCAR on the other – responsibility for compliance with all complaints management obligations remains, in both cases, fully with Huddlestock GmbH.
2. Definition of a Complaint
A complaint in connection with investment services or ancillary investment services is any expression of dissatisfaction which a client within the meaning of section 67(1) WpHG or a prospective client (complainant) addresses to Huddlestock GmbH in connection with the provision of an investment service or an ancillary investment service, irrespective of whether the term “complaint” is used.
A complaint in connection with crypto-asset services is any expression of dissatisfaction which a client or other interested party addresses to Huddlestock GmbH or to the service provider acting on its behalf in connection with the provision of a crypto-asset service within the meaning of Art. 3(1)(16) MiCAR, irrespective of whether the term “complaint” is used (Art. 71 MiCAR).
3. Complaints Process
a) Submission of the Complaint
The complaint may be submitted informally, i.e. orally by telephone, electronically, in writing or by fax. It is deemed to have been submitted once the complainant’s statement has been received by Huddlestock GmbH. As a rule, any employee is authorised to receive a complaint. Employees are required to forward complaints received without delay to the department responsible for complaints management. To ensure prompt handling, we kindly ask that any complaints be forwarded directly to the contact details set out above.
Complaints relating to crypto-asset services may additionally be submitted using the standardised template set out in the Annex to Delegated Regulation (EU) 2025/294. Use of this template is not a precondition for a complaint to be handled; complaints submitted informally are likewise accepted and processed (Art. 1 Delegated Regulation (EU) 2025/294).
Complaints may be submitted either directly to Huddlestock GmbH or to the relevant tied agent. The tied agent forwards complaints relating to investment services to Huddlestock GmbH’s complaints management function without delay, or handles complaints relating to crypto-asset services itself under the outsourcing arrangement, in accordance with the contractual requirements and these Principles.
When submitting a complaint, we further ask that you provide the following information:
- Your contact details (name, address, telephone, email),
- The service concerned (investment service or crypto-asset service),
- The reason for your complaint (background, cause),
- An indication of the disadvantage or damage threatened,
- Any supporting documentation substantiating your complaint.
There is no charge for submitting a complaint (section 67(1) WpHG and Art. 71 MiCAR respectively). Complaints are processed without delay.
b) Handling of the Complaint
For complaints relating to investment services or ancillary investment services, Huddlestock GmbH or the tied agent acting on its behalf under the outsourcing arrangement, proceeds as follows:
- Records the reported complaint,
- Categorises it in accordance with the requirements of the Annex to BT 12.2 MaComp Section A and records the reason for the complaint in accordance with the Annex to BT 12.2 MaComp Section B,
- Examines the merits of the complaint and decides whether, and if so in what form, to what extent and with what personnel and organisational consequences, the complaint will be resolved,
- Documents the measures taken in accordance with the requirements of the Annex to BT 12.2 MaComp Section C.
For complaints relating to crypto-asset services, Huddlestock GmbH, or the tied agent acting on its behalf under the outsourcing arrangement, proceeds as follows:
- Acknowledges receipt, stating the date of receipt, and informs the complainant whether the complaint is admissible (Art. 4 Delegated Regulation (EU) 2025/294),
- Investigates all relevant information and evidence relating to the complaint (Art. 5 Delegated Regulation (EU) 2025/294),
- Communicates its decision, as a rule, within two months of receipt of the complaint; where this timeframe cannot be met in an individual case, the complainant is informed without undue delay of the reasons for the delay and of the expected date of the decision (Art. 6 Delegated Regulation (EU) 2025/294),
- Communicates its decision in plain, easily understandable language, together with reasons, and, in the event of a full or partial rejection, information on available remedies and dispute resolution bodies (Art. 7 Delegated Regulation (EU) 2025/294).
4. Languages and Accessibility
The description of the complaints procedure set out in these Principles, as well as the template for submitting complaints relating to crypto-asset services, are published in the languages Huddlestock GmbH uses to market its services or to communicate with clients (Art. 1(4) Delegated Regulation (EU) 2025/294). Irrespective of this, Huddlestock GmbH ensures that clients are able to file complaints relating to crypto-asset services additionally in the official languages of the home Member State and host Member States, insofar as these are also official languages of the European Union (Art. 3(2) Delegated Regulation (EU) 2025/294). Communication with the complainant during the handling of the complaint is carried out in the language in which the complaint was filed, provided that this is one of the languages referred to above (Art. 7(2) Delegated Regulation (EU) 2025/294). The template is accompanied by a privacy notice pursuant to Art. 13 and 14 GDPR.
5. Internal Complaints Register
The internally maintained, secure complaints register documents all reported complaints relating to investment services and to crypto-asset services, categorised and recorded by reason for complaint, together with any remedial recommendations, decisions and measures taken in that respect. Records are retained for at least five years (section 9(4) WpDVerOV; for crypto-asset complaints, the same retention period is applied as an internal company policy, since Delegated Regulation (EU) 2025/294 itself does not prescribe a fixed retention period).
Where complaints relating to crypto-asset services are handled by a tied agent under an outsourcing arrangement pursuant to Art. 73 MiCAR, Huddlestock GmbH has direct, read-only access to the complaints register maintained by the tied agent at all times, as well as the right to request complete case files (Art. 73(1) subpara. 1(f) MiCAR in conjunction with the respective outsourcing agreement).
6. Complaints Report
Huddlestock GmbH prepares an annual complaints report pursuant to Art. 26 MiFID II Delegated Regulation and submits it to BaFin by 1 March each year for the preceding calendar year.
For crypto-asset services, Art. 71 MiCAR and Delegated Regulation (EU) 2025/294 do not provide for an obligation to submit a separate annual complaints report to BaFin equivalent to that under Art. 26 MiFID II Delegated Regulation; the RTS does, however, require an ongoing internal analysis of complaints data to identify recurring causes, as well as approval and oversight by senior management (Art. 2, Art. 8 Delegated Regulation (EU) 2025/294).
7. Alternative Dispute Resolution Bodies
The following alternative dispute resolution bodies are available for complaints relating to investment services and ancillary investment services as well as to crypto-asset services:
- BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht – German Federal Financial Supervisory Authority)
- European Commission – Online Dispute Resolution platform
- Außergerichtliche Streitbeilegungsstelle für Verbraucher und Unternehmer e.V. (out-of-court dispute resolution body for consumers and businesses)
8. Publication
These Principles of the complaints procedure, including the template for submitting complaints relating to crypto-asset services (Annex to Delegated Regulation (EU) 2025/294), have been approved by the management board and are published on the website of the Huddlestock GmbH.