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Article 12

Market Anomaly: Iceberg Orders (Legal)

Short explanation: An iceberg order ("reserve order") slices a large limit into visible small peaks and a hidden reserve. After each fill the next peak is revealed automatically, reducing market impact and slippage. The order type is legitimate; the anomaly arises from its tape footprint (apparently endless liquidity) and subsequent misinterpretation by other participants.

Market CEX Spot, CEX Derivatives
Evidence status & as of Spot-evidenced · As of: October 18, 2025, 12:00 UTC

Documented scenarios (CEX-based)

  • Binance (Spot, API): LIMIT / LIMIT_MAKER can be configured with icebergQty to create an iceberg; Time-in-Force = GTC required.
  • OKX (Algo order "Iceberg"): Built-in iceberg strategies (slicing modes such as "fast", "price/speed", "passive"); documented limits for outstanding algos.
  • Bitfinex (Hidden / "Visible on Hit"): Hidden orders where the remainder is shown only after partial fills - functionally related to iceberg peaking.
  • Third-party orderflow analyses: L3 / order-event data used to detect icebergs via queue replenishment and recurring peak quantities.

Icebergs are legitimate (impact reduction). Abuse only starts when combined with deceptive tactics (e.g. iceberg + artificial opposing pressure).

How it works

Short & understandable

  1. Motivation: Large orders seek to avoid price impact and disclosure of total size.
  2. Mechanic: Instead of 1×10,000 lots: e.g. 50×200 visible peaks. Each fill triggers the next peak while reserve remains.
  3. Effect on the tape: Continuously "regenerating" residual quantities at the same price look like persistent depth.
  4. Outcome: Absorption/damping with reduced slippage for the placer.
  5. Boundary to anomaly: Misreading as "real support" or combining with misleading counter-signals distorts the market picture.

Clear detection features (observable live)

  • Replenishment at the same price: Immediately (ms range) after each fill a similar peak size reappears.
  • Constant peak size: Many fills with nearly identical quantity (±2–5%) at the same level.
  • VWAP drift ≈ 0: Despite many fills, little net price progression (absorbing side).
  • Queue signature (L3): Repeated add/replace events on the same level → "reserve is being reloaded".

Why CEXs are vulnerable

  • Native iceberg support & high API rates → fine-grained slicing is trivial.
  • Limited transparency: public feeds do not show counterparty IDs; without L3 reserve replenishment is only indirectly visible.
  • Interpretation risk: "endless" bids/offers look like genuine depth → mistrades when relying solely on L1/L2.

Comparison: regulated exchanges

Icebergs are permitted (e.g. Nasdaq "Reserve/Iceberg"), but surveillance targets misleading combinations. Regulators have full order lifecycles, UTC timing quality (MiFID II / RTS 25) and cross-market visibility - abusive patterns are evidenced earlier.

Why early detection is critical – and what's changing in the EU

  • Market effect: Regenerating peaks distort trend/liquidity signals, delay breakouts and increase squeeze risk.
  • MiCA context: Largely applicable since 30.12.2024; transitional arrangements until 01.07.2026 possible (member-state specifics). Effective controls against misleading order signals are expected.

Concrete thresholds / alert rules (E3/E2/E1)

Adaptive, quantile-based, per symbol/venue against a 30-day baseline for the same time of day. Required: at minimum L2. Best: L3 events (order add/replace/fill sequences).

E3 (high) – "Classic iceberg signature"

  • ≥ 10 fills at the same price level within ≤ 3 min,
  • Peak consistency: median peak size in the cluster ± ≤ 5%,
  • Immediate replenishment: median time fill → new add/replace ≤ 150 ms,
  • VWAP drift: < 5 bp.

E2 (medium)

  • ≥ 6 fills within ≤ 3 min, peak consistency ± ≤ 10%, drift < 10 bp.

E1 (low)

  • Series of identical fills (≥ 3) within ≤ 2 min with stable spread → watchlist.

Without L3, replenishment is inferred from timing/size patterns; with L3 (order IDs / queue position) evidentiary strength increases.

Practical tips (minimising false positives)

  • Distinguish market making: similar series may occur - require consistency + immediate reload + low price drift together.
  • Check multiple venues: real flows often mirror cross-venue; local replenishment on a single venue is more typical for icebergs.
  • Check event context: news/listing/funding can create legitimate absorption.
  • "Visible on Hit" ≠ iceberg: related but distinct; can show similar reload patterns.

Why this matters (trader value & compliance)

  • For traders: Assess visible depth more realistically, time breakouts/exits better, reduce slippage.
  • For operators/compliance: Replenishment evidence (time/size/queue) is central to modern surveillance; MiCA expects recognition of misleading signals.

Relevant sources

  • Binance – Spot API / Support ("Trading endpoints", "What Is an Iceberg Order?") – icebergQty, GTC requirement.
  • OKX – Iceberg Strategy (Help & FAQs) + API Guide (modes/limits).
  • Bitfinex – Hidden / Visible-on-Hit (support/docs).
  • Nasdaq – Reserve (Iceberg) factsheet & disruptive trading practices FAQ (allowed order type; deceptive combos prohibited).
  • CoinAPI / Kaiko – L3 / order-book analysis pieces (queue reconstruction, iceberg detection).
  • ESMA / AMF – MiCA transitional framework (since 30.12.2024; transition until 01.07.2026 possible).