Public Hearing on Updated Trading Rules for Digital Asset Trading: 1 - 7 July 2025

Modified on Tue, 1 Jul at 10:00 AM

Principle

Following the development of an automated Dollar-Cost Averaging (DCA) feature (Auto DCA) of Bitkub Online Co., Ltd. (“Company”) to facilitate customer investment, it is deemed appropriate to revise the digital asset trading rules ("Trading Rules"). This revision aims to align its operations with customer needs and provide a clear, consistent framework for using the Company's trading platform.

The Company is hereby holding a public hearing on updates to its Trading Rules, ensuring customers are informed of new service conditions before implementation. A key improvement is the addition of Auto DCA for buy orders of digital assets, which will allow customers to establish automated, continuous market order submissions based on their unique criteria. This Auto DCA functionality will enhance dollar-cost averaging (DCA) strategies and provide more convenient progress monitoring.

Impact

Relevant Party	Positive Impact	Negative Impact
Digital asset business provider (Company)	The Company can improve service satisfaction by responding to customers’ needs.	The Company needs to prepare and update the system according to the new Trading Rules. The Company needs to revise the requirements and usage conditions for Auto DCA.
Trader/user	Individuals who are interested in DCA investment can conveniently invest by using the Auto DCA feature to place buy orders according to the schedule and conditions set by themselves. Users can monitor and analyze their DCA investments more conveniently.	Users must study usage instructions, advantages, limitations, and risks of the DCA investment. Users must study the requirements and conditions of Auto DCA.

Enforcement guideline

This enforcement guideline will come into effect only after the Company receives approval for the amendments to the digital asset Trading Rules from the Securities and Exchange Commission. The details will be announced to customers and related parties through the Company’s communication channels accordingly.

Definitions of the related terms mentioned in the public hearing on the updated Trading Rules

Related Terms	Definition
Market Order	Matching of buy and sell orders according to the amount the buyer is willing to pay in Thai baht and the number of digital assets that the seller wants to sell respectively. The bid and ask will be matched at any conversion rate to get the best possible amount of Thai baht and/or digital assets according to the amount specified by the buyer or seller.
DCA	A type of long-term investment in which an investor regularly buys assets over a certain period and per the set conditions.
Auto DCA	A method for placing buy orders in advance by setting the conditions for the system to place the orders according to the pre-set schedule and conditions.
System	A system provided by the Company to receive orders from its customers and manage such orders according to the requested conditions.

Conditions of Auto DCA

Upon the scheduled date, the automated DCA system or Auto DCA will submit a market buy order according to the specified amount per each buying round. Before placing the order, the system will verify the remaining balance of Thai Baht in the customer's wallet on Bitkub Exchange; if the balance is insufficient based on the predetermined conditions, the system will skip that particular buying round without impacting subsequent orders.

The Company also conducts a quarterly qualification review of tokens offered on its Auto DCA system. To ensure that tokens available on the Auto DCA system remain suitable, the Company has established specific criteria for selecting tokens as detailed below.

The Company will take a snapshot of the 2% depth value every 15 minutes. This 15-minute data will be reviewed quarterly, commencing from the date of qualification assessment / review. Note that the 15-minute interval is chosen for its alignment with the period during which customers can place orders on the Auto DCA system.
The Company will use all data obtained from step 1. to calculate the proportion of values, which will be categorized into those with a value of 1,000,000 Baht or more and those with a value less than 1,000,000 Baht.
Tokens that will be selected for Auto DCA service must have a snapshot proportion of less than 1% when their value falls below 1,000,000 Baht.

If a token offered on the Auto DCA system does not meet the Company’s selection criteria during a period outside the quarterly qualification review, the Company will notify customers of the associated risks as follows:

The system will analyze 24 hours of historical data (96 snapshots every 15 minutes) from the preceding day (D-1) to identify whether there is a period when the 2% market depth is below 1,000,000 Thai Baht for 50% or more of the observed period (≥ 48 snapshots).
If this condition is met, the system will send a push notification to customers to communicate the token’s liquidity status during that period and provide initial recommendations to assist customers in evaluating the suitability of their investment for decision-making purposes.

In the event of a quarterly delisting of a token from the Auto DCA system, the Company will adhere to the following procedures:

Customers with active orders for tokens that fail the qualification criteria will receive a notification 14 days prior to the delisting date of the token from the Auto DCA system. Customers will have the option to manually cancel their active buy order(s) for the affected token by themselves.
Should a customer not cancel their active buy order(s) for a non-qualifying token by the specified date, the Company will automatically cancel such DCA orders for that token.

Usage of Auto DCA

Customers can access the Auto DCA feature through the Auto DCA menu on the website and application of Bitkub Exchange. There are 4 components of the Auto DCA page:

Auto DCA setting and order creation
Auto DCA order details
Auto DCA order history
Auto DCA conditions

To set up the Auto DCA, customers must complete setting up the following:

Select the desired digital asset
Set the buying amount in Thai Baht per cycle
Frequency and recurring schedule: Daily, weekly, and yearly
Recurring duration

There are 3 parts in the DCA order details and history:

Opening Auto DCA: Shows active DCA plans
Closed Auto DCA: Shows ended (canceled and inactive) DCA plans
Auto DCA Order History: Shows completed and failed DCA buy orders

To cancel Auto DCA orders, go to the Auto DCA page, select the Opening Auto DCA menu, and click Cancel. The Auto DCA system will immediately terminate order submission, and the status of that particular DCA will change to Closed.

In the case that the Auto DCA orders are active until the end of the recurring period, the status of that particular Auto DCA order will also change to Closed.