This FAQ explains how Fluyt works: BTC-settled environmental certificate trading with registry-native delivery, no crypto custody, and a calm, bilateral desk structure. It is designed for miners, Bitcoin-native businesses, corporate treasuries, trading desks, ESG teams, auditors and lawyers.
Table of Contents
- 1. General
- 2. Products
- 3. Trade Process
- 4. Bitcoin Settlement
- 5. Registry Delivery & Custody
- 6. Reporting & Audit
- 7. Risk & Compliance
- 8. Security
- 9. Operational Questions
- 10. Accounting & Tax
- 11. Legal Structure & Contracts
- 12. Sanctions, AML & Eligibility
- 13. Payment Failures & Errors
- 14. Delivery Risks
- 15. Disputes & Offboarding
- 16. Data Protection & Privacy
- 17. Business Continuity
- 18. Scalability & Roadmap
- 19. Pilot Phase Details
- 20. Post-Pilot Roadmap
1. General
1. What is Fluyt?
Fluyt is a bilateral trading desk that allows professional counterparties to buy environmental certificates—such as REGOs, GOs, US RECs, I-RECs and voluntary carbon credits—and settle the trade in Bitcoin. Fluyt does not run an exchange, does not tokenize certificates, and does not custody client Bitcoin.
2. Why is it called “Fluyt”?
A fluyt was a 16th-century Dutch cargo vessel optimised purely for trade: wide hull, narrow deck, minimal crew. It transformed shipping by focusing on efficiency and simplicity. The brand adopts the same attitude: no hype, no theatrics, just a calm vessel for moving environmental value with Bitcoin as the payment rail.
3. Why would anyone buy environmental certificates with Bitcoin?
- Bitcoin-native businesses hold or earn BTC and prefer not to unwind to fiat just to purchase environmental instruments.
- Miners and datacentres often want renewable coverage or carbon-neutrality, but their income stream is BTC-heavy.
- Corporate treasuries that hold BTC want environmental procurement to align with how they manage value.
- Trading desks may want exposure to BTC-settled commodity flows without building full crypto infrastructure.
Fluyt leaves the underlying certificates exactly as they are—registry-issued and registry-delivered—while replacing only the fiat payment leg with Bitcoin.
4. Who is Fluyt for?
- Bitcoin-native operating businesses
- Miners and energy-intensive compute operators
- Corporate sustainability teams with BTC-based operations
- Trading desks and brokers exploring BTC settlement
- APAC, EU, UK, US corporates needing REGOs, GOs, RECs, I-RECs or carbon
5. Who is Fluyt not for?
- Retail users and individuals.
- Anonymous or pseudonymous entities who refuse KYC.
- Tokenised carbon speculators.
- Clients looking for yield, staking or “green coin” investments.
- Anyone unwilling to provide basic business documentation.
6. What makes Fluyt different from an exchange or a tokenised platform?
- Registry-native: Delivery via Ofgem, AIB, I-REC and recognised carbon / REC registries.
- No tokenisation: No wrapping, no synthetic tokens, no on-chain “green coins”.
- No crypto custody: Clients hold and send their own BTC; Fluyt never manages wallets for clients.
- Bilateral OTC: Every trade is a specific quote, not an order-book or matching engine.
- Audit-first: Every trade produces a concise deal pack linking BTC TXID to registry evidence.
7. Are these trades financial instruments?
No. Environmental attribute certificates are not classified as financial instruments in the UK, EU, US, Singapore and most other markets. They are compliance or voluntary environmental commodities. Paying for them in BTC does not turn them into securities.
8. Is Fluyt a crypto company?
Fluyt is an environmental certificate trading desk that uses Bitcoin as a settlement rail. It does not offer wallets, exchanges, swaps, loans, staking or token issuance. Its core expertise is in REGOs, GOs, RECs, I-RECs and carbon markets.
9. Does Fluyt ever hold Bitcoin for clients?
No. Clients remain in control of their BTC until they pay a specific invoice/quote. Fluyt does not custody Bitcoin, manage balances, operate margin, or hold tokens on behalf of clients.
2. Products
10. Which environmental certificates can I buy via Fluyt?
- REGOs (UK): Renewable Energy Guarantees of Origin issued under Ofgem.
- European GOs: Guarantees of Origin from AIB-compliant registries.
- US RECs: Renewable Energy Certificates from registries such as M-RETS, PJM GATS, ERCOT, WREGIS, IREC (where accessible via partners).
- I-RECs: International Renewable Energy Certificates under the I-REC Standard.
- Voluntary Carbon Credits: From Verra (VCS), Gold Standard, Puro, ART-TREES or similar, subject to quality checks.
- Bundles: Pre-structured combinations of the above, especially for miners and BTC-native treasuries.
11. What are Fluyt “bundles”?
- Renewable Power Bundle: A monthly or quarterly volume of REGOs / GOs / RECs / I-RECs matched to your electricity usage.
- Carbon-Neutral Mining Bundle: Renewable certificates plus matching carbon credits, delivered and documented together.
- Regional Blend Bundle: A mix of UK, EU, US and I-REC certificates optimised for cost or availability.
- Treasury Green Cover: A quarterly or annual purchase aligned with BTC-related activities or treasury exposure.
12. Are bundles mandatory?
No. Bundles are an option for simplicity. You can buy individual instruments, mix products manually, or run occasional one-off trades.
13. Do I have to buy carbon credits?
No. Carbon credits are optional and only included when requested. Fluyt does not push offsets as the default solution and applies higher scrutiny to carbon projects than to EACs.
14. What minimum trade sizes apply?
- REGOs: typically 100–500 MWh minimum.
- GOs: typically 500 MWh+.
- US RECs: 500–1,000 MWh+.
- I-RECs: 500 MWh+.
- Carbon credits: 100–500 tonnes+.
The desk is not designed for micro-retail trades.
3. Trade Process
15. How do I start a trade?
Submit a trade enquiry via the Fluyt trade form (for example at /start-trading/) with:
- Product type (REGOs, GOs, RECs, I-RECs, carbon, bundle).
- Country/region and technology (e.g. UK wind, Nordic hydro).
- Vintage (e.g. 2023, 2024, specific months).
- Volume (MWh or tonnes).
- Delivery preference (transfer to your registry or cancellation on your behalf).
- Timing (ASAP, this month, later).
- Registry account details if you want transfers.
16. What happens after I submit the form?
- Feasibility: Fluyt checks if the requested trade is possible at current market conditions.
- KYC: If not already completed, basic KYC is requested.
- Quote: You receive a firm BTC-denominated quote with validity window.
- Settlement: You accept the quote by sending BTC to a one-off address within the validity window.
- Delivery: Fluyt executes registry transfers or cancellations and issues the deal pack.
17. Is KYC mandatory?
Yes. Basic KYC is required for all Clients for AML and registry compliance reasons. It is significantly lighter than bank-level onboarding but still non-optional.
18. What documents are required for KYC?
- Certificate of incorporation or registry extract.
- Registered address.
- Directors and beneficial owners.
- Sanctions screening information.
- Proof of registry account ownership (for transfer deliveries, where needed).
Miners and datacentres may be asked for additional information on operating entities and location.
4. Bitcoin Settlement
19. How does BTC settlement actually work?
- You receive a quote that specifies a total BTC amount, based on underlying EAC price, FX and BTC reference rate.
- The quote includes a validity window (e.g. 2–6 hours) and a one-time payment address.
- You pay the BTC amount from your own wallet within the window.
- Once the transaction has the required confirmations, settlement is considered complete and delivery begins.
20. Why is there a quote validity window?
BTC is volatile. A validity window locks the BTC rate for a short period. If the window expires before payment confirms, the quote lapses and a new quote is needed.
21. How many confirmations do you require?
- Small trades: typically 1 confirmation.
- Medium trades: typically 3 confirmations.
- Large trades: typically 6+ confirmations.
The exact requirement is stated in each quote.
22. What if I underpay or overpay?
- Underpayment: Fluyt may request a top-up. If not resolved, funds are refunded.
- Overpayment: The surplus BTC is refunded, minus network fees.
23. Can I pay from an exchange account?
Technically yes, but it is not recommended because exchanges batch withdrawals, may introduce delays, and muddle provenance. Corporate wallets, custody solutions, or self-custody are cleaner for reconciliation and AML.
24. Do you support Lightning?
Not during the pilot. Only on-chain BTC is supported to keep audit and reconciliation simple and to align with corporate treasury processes.
25. How do you link the BTC payment to the certificates?
Each trade generates a deal pack including the BTC transaction hash, timestamp, block confirmations, and the matching registry delivery records. This creates a verifiable chain: Quote → BTC TXID → Registry transfer/cancellation → Deal pack.
5. Registry Delivery & Custody
26. Do I need my own registry accounts?
- REGOs: you can receive transfers or request cancellation on your behalf.
- GOs: usually require your own AIB registry account.
- US RECs: require your registry accounts or an agreed structure via partners.
- I-RECs: require your I-REC account if you want transfers.
- Carbon credits: may be transferred or retired in Fluyt/partner accounts on your behalf.
27. How long does Fluyt hold certificates on behalf of clients?
The intent is to hold them only as long as needed to execute the trade:
- Target: 0–7 days.
- Maximum: 30 days with explicit written instruction.
Anything held in Fluyt/EMT accounts for clients is marked in an internal Client Position Register that segregates client-owned positions from proprietary inventory.
28. How do I know certificates were actually delivered?
- Registry screenshots or exports.
- Transfer or cancellation references.
- Retirement or cancellation certificates for carbon, where applicable.
- Deal pack tying these to the BTC TXID.
29. Can you cancel certificates instead of transferring them?
Yes. For many clients it is simpler for Fluyt to cancel certificates on their behalf in the registry and provide evidence, instead of moving them into another account that then retires them later.
6. Reporting & Audit
30. Will auditors accept BTC-settled EAC procurement?
Yes. From an audit perspective, BTC is just the payment method. The key questions are:
- Are the certificates real and registry-issued?
- Is the chain-of-custody clear?
- Are they allocated correctly to the reporting period and entity?
The deal pack provides the same evidence as a fiat trade, plus the BTC payment trace.
31. Do you align with GHG Protocol and RE100/CDP frameworks?
Yes. Fluyt follows standard EAC accounting norms (GHG Protocol Scope 2, RE100 and CDP-style reporting). Fluyt cannot certify your external claims, but it can provide clean underlying evidence.
32. Can you provide quarterly or annual reports?
Yes. Fluyt can summarise volumes, regions, technologies, vintages, and associated BTC payments in a structured way suitable for ESG and finance teams.
7. Risk & Compliance
33. What are the main AML risks?
- Use of shell companies to hide beneficial owners.
- Use of tainted BTC from mixers, darknet sources or sanctioned entities.
- Inflated pricing or fictitious volume trades as laundering schemes.
- Low-quality carbon projects used as vehicles for speculative flows.
Fluyt mitigates these with KYC, sanctions screening, on-chain BTC screening and strict counterpart identification.
34. Are environmental certificates themselves regulated?
They are regulated as environmental instruments and registry products, but not as financial securities. This distinction is important: Fluyt is not providing investment products or derivatives.
35. Does Fluyt run any tokenised carbon or EAC products?
No. Fluyt does not mint, list, or support tokenised EACs or tokenised offsets. All value remains inside the existing registry systems.
8. Security
36. How is the BTC payment process secured?
- Every quote has a unique, single-use BTC address.
- No client login is needed to pay—only your own wallet.
- Payments are tracked using the transaction hash and confirmations.
- There is no shared “custodial” wallet for multiple clients.
37. How are registry accounts secured?
- Two-factor authentication where supported.
- Restricted user access and roles.
- Internal dual-control for key actions (transfers, cancellations).
- Regular reconciliation of balances against internal ledgers.
9. Operational Questions
38. How are quotes generated internally?
Each quote is built from:
- Current EAC or carbon market price.
- Any execution/sourcing costs.
- FX where applicable.
- BTC reference price from agreed sources.
- Operational margin as agreed.
39. Can Fluyt handle very large trades?
Yes, subject to market liquidity. Typical practical ranges:
- REGOs: 1–10 GWh per trade.
- GOs: 5–20 GWh per trade.
- US RECs: 1–10 GWh per trade.
- I-RECs: 5–30 GWh per trade.
- Carbon credits: 1,000–10,000 tonnes per trade.
40. Can miners automate monthly purchases?
Yes. This is what Fluyt bundles are for: recurring monthly or quarterly volumes, fixed structure, and repeatable BTC settlement.
10. Accounting & Tax
41. How is BTC-settled EAC procurement treated in accounts?
From an accounting standpoint, you are purchasing environmental commodities. These may be booked as intangibles, inventory, or cost-of-goods/environmental cost, depending on your accounting policy. BTC is simply the payment mechanism, not the object of procurement.
42. Does paying with BTC create tax events?
Typically yes: using BTC to pay is treated as a disposal event for tax in many jurisdictions. Clients should obtain their own tax advice; Fluyt does not advise on taxation.
11. Legal Structure & Contracts
43. Who is my legal counterparty?
Your counterparty is Energy Marketing and Trading Ltd (EMT), a UK company. Fluyt is the trading name/brand. Operational support may be provided by SingNRG Pte Ltd in Singapore.
44. Do I have to sign a Master Trading Agreement?
During the pilot, smaller trades can operate on quote-and-acceptance terms. Larger or institutional clients may request, or be required to sign, a Master Trading Agreement for repeated flow.
45. Which law governs the relationship?
By default, trades are governed by the law of England and Wales, unless another jurisdiction is explicitly agreed in a Master Trading Agreement.
12. Sanctions, AML & Eligibility
46. Do you accept clients from all countries?
No. Fluyt does not onboard entities from sanctioned or high-risk jurisdictions, and may decline clients whose beneficial ownership or operating structure creates unacceptable AML or sanctions exposure.
47. Do you onboard anonymous or pseudonymous entities?
No. All clients must undergo KYC and be identified as real-world legal entities.
48. What if incoming BTC is flagged as high-risk?
If on-chain screening flags incoming BTC as suspicious or linked to sanctions/mixers/darknet, Fluyt may pause the trade, refund funds where legally possible, offboard the client and, if appropriate, file a report with relevant authorities.
13. Payment Failures & Errors
49. What if my BTC payment confirms after the quote expires?
Fluyt may either refund the BTC (minus network fees) or agree a new quote based on current prices before proceeding. You will not be forced into a trade at an expired rate.
50. Can I cancel a trade after paying?
BTC settlement is final. In rare cases, if certificates have not yet been sourced and there is a clear error, Fluyt may voluntarily unwind and refund—but this is discretionary, not guaranteed.
14. Delivery Risks
51. What happens if certificates become unavailable after I pay?
If an unforeseen market event makes the specific certificates unavailable after settlement, Fluyt will either supply equivalent certificates or refund your BTC. These cases are rare due to immediate sourcing post-settlement.
52. What if a registry is offline or slow?
Delivery can be delayed. Fluyt will communicate ETAs and execute as soon as registries are operational again.
15. Disputes & Offboarding
53. How are disputes handled?
Most disputes are resolved by reviewing the deal pack: quote terms, BTC transaction details and registry evidence. If not resolved, the governing law and dispute resolution clause in the contract or quote applies.
54. Can Fluyt offboard a client?
Yes. Reasons include sanctions risk, repeated AML concerns, non-cooperation with KYC, or abuse of quote processes. Offboarding is documented and, where necessary, reported.
16. Data Protection & Privacy
55. What data do you store?
Fluyt stores:
- Basic corporate and KYC data.
- Registry account details (where needed).
- Trade details and pricing.
- BTC transaction hashes and settlement records.
56. Do you sell or broker data?
No. Data is used only for operating trades, compliance and internal reporting, and is shared externally only with registries and authorities where required.
17. Business Continuity
57. What happens if Fluyt/EMT is temporarily unavailable?
New quotes may pause. Existing deliveries resume when systems are back online. Certificates already delivered or cancelled remain valid in the registries regardless of Fluyt’s operational status.
58. What happens if EMT becomes insolvent?
Certificates held in EMT accounts on behalf of clients remain beneficially owned by those clients, not EMT. Registry evidence and the Client Position Register can be used to assert ownership and recover positions.
18. Scalability & Roadmap
59. Will there be an API?
Yes, likely after the pilot, to support programmatic quote requests, trade submissions, bundle management and reporting. Initial focus is getting manual flow right.
60. Will there be a dashboard or portal?
Eventually, a minimal portal may be introduced for trade history, positions and document downloads. The aesthetic will remain simple and functional, not an exchange-style trading UI.
19. Pilot Phase Details
61. What is included in the pilot?
- Priority onboarding.
- Access to BTC-settled EAC trades.
- Option to test bundles for miners/treasuries.
- Simplified documentation.
- Direct desk access via email/secure channels.
62. What is not included?
- Public API.
- Lightning payments.
- Retail access.
- Tokenised instruments.
- Full self-service portal.
63. How long will the pilot run?
Approximately 6–12 months, depending on volume, operational learning, and regulatory feedback.
20. Post-Pilot Roadmap
64. What happens after the pilot?
Planned steps include moving to a production offering with clearer pricing tiers, expanding product coverage, adding API and minimal portal access, and formalising Fluyt as a standalone brand (and potentially a dedicated legal entity).
65. Will I need to re-onboard?
No. Existing KYC remains valid unless your corporate structure or risk profile changes, or regulatory requirements force an update.
