Providers · Exchange
Hodl Hodl
Bitcoin-only P2P marketplace: trade directly with other people through an escrow, with no identity check.
No licence in the EU – not listed in the ESMA registerBitcoin only Worldwide, excluding the USA, Russia, Belarus and sanctioned countries, among othersEN · RU · ES · PT
Facts at a glance
- Category
- Exchange
- Offering
- Bitcoin only
- Tradable crypto assets
- Bitcoin only
- Regulation / supervision
- No licence in the EU – not listed in the ESMA register
- Headquarters
- Marshall Islands (Hodlex Ltd)
- Available in
- Worldwide, excluding the USA, Russia, Belarus and sanctioned countries, among others
- Languages
- English, Russian, Spanish, Portuguese
- Savings plan
- no savings plan
- Lightning
- Yes
- Withdrawal to your own wallet
- Yes
- Self-custody (your own keys)
- Yes
- Identity check (KYC)
- None
- Fees (summary)
- 0.75% per trading party, minimum fee usually up to $5; plus network fees (as of Sept 2026)
- Platforms
- Web
- Last checked
- 28 September 2026
No guarantee – please verify with the provider.
Who is it for?
- Advanced users who want to buy Bitcoin without an identity check
- Users with their own wallet who don’t want to leave funds on a platform
- Buyers who already know P2P trading and its risks
Strengths & weaknesses
+Strengths
- Bitcoin only, trading via Lightning too
- The platform holds no funds – bitcoin go straight to your wallet
- No identity check: an email address and password are enough
−Weaknesses
- No EU licence, no supervision, operating company in the Marshall Islands
- In a dispute, a member of the platform’s staff decides
- You trade with strangers – scam attempts and reversed payments are possible
- The minimum fee can make small purchases more expensive
Our take
What is Hodl Hodl?
Hodl Hodl is a marketplace for P2P tradingGlossaryP2P trading (peer-to-peer trading)Buying or selling bitcoin directly between private individuals, often via software that locks the bitcoin in an escrow address until the payment arrives. More privacy, but more effort and scam risks of its own.On the learning path: Stage 6 · Step 2 – Spotting scams →In the glossary →: buyers and sellers trade Bitcoin directly with each other and arrange the payment in euros or another currency themselves.[1] Each offer sets its own price – compare it with the market price before you trade. The operator is Hodlex Ltd, a company incorporated under the laws of the Marshall Islands.[5]
An email address and a password are enough to get started; there is no identity check (KYCGlossaryKYC (Know Your Customer)The obligation of regulated providers to identify you before the business relationship starts and to ask, for example, about its purpose and, where necessary, the source of your money. In Germany, the legal basis is the Money Laundering Act (GwG).On the learning path: Stage 4 · Step 3 – Buying Bitcoin →In the glossary →).[3] You need your own wallet.[1] Users from the USA, Russia, Belarus and sanctioned countries, among others, are excluded.[5] For your first Bitcoin purchase, a regulated provider is usually simpler. What to watch out for when buying peer to peer is explained in Peer-to-peer & Bitcoin without KYC.
Costs (as of September 2026)
- Trading fee: 0.75% each for buyer and seller, 0.5% with a referral code. It is only charged if the trade completes; the buyer’s fee is deducted from the bitcoin paid out.[4]
- Minimum fee: small on-chain trades are subject to a variable minimum fee – according to Hodl Hodl, normally no more than $5 in BTC.[4]
- Network fees (on-chain): charged twice – when the escrow is funded and when it is released.[4]
- Lightning trades: the same trading fee plus a small, variable swap fee (according to Hodl Hodl, around $1 on a $10,000 trade).[4]
Security & custody
According to Hodl Hodl, it holds neither funds nor private keys.[5] In on-chain trades, the seller locks the bitcoin in a dedicated 2-of-3 multisigGlossaryMultisig (multi-signature)A wallet in which several keys jointly control the bitcoin – for example 2 of 3. If one key is lost or stolen, the bitcoin stays safe. In return, setting it up and backing it up is considerably more demanding.On the learning path: Stage 6 · Step 4 – Inheritance & emergency plan →In the glossary → address. Buyer, seller and Hodl Hodl each hold one key; the platform cannot move the bitcoin on its own.[3],[2] Once the payment has arrived, the seller releases the bitcoin directly to the buyer’s wallet.[1] Lightning trades use a different escrow (Arkade).[4]
In a dispute, Hodl Hodl’s support team decides who gets the bitcoin, based on proof of payment and the trade chat.[3],[5] At this point, you are trusting the platform after all.
Supervision
Hodl Hodl has no licence under MiCAGlossaryMiCA (Markets in Crypto-Assets Regulation)The EU regulation on markets in crypto-assets. Since 30 December 2024, exchanges, brokers and custodians in the EU have needed authorisation; the last transitional period ended on 1 July 2026. MiCA regulates providers, not Bitcoin itself.On the learning path: Stage 4 · Step 2 – Choosing a provider →In the glossary → and is not listed in ESMA’s register.[6] So there is no supervisory authority you can turn to if something goes wrong. On top of that come the usual P2P risks, such as forged payment receipts or reversed payments.
Related articles
The basics you should know before signing up:
- Stage 4 · Step 2Choosing a providerMiCA authorisation, real bitcoin, withdrawals, costs, savings plan, security: how to check a Bitcoin provider yourself – with a guide and checklist.
- Stage 4 · Step 3Buying BitcoinRegistration, ID check, two-factor protection, SEPA deposit and first purchase: the complete process with example screens and warnings.
- Deep dive · Stage 4Understanding feesSpread, maker/taker, service fee, card surcharge, withdrawal and network fee: what buying Bitcoin costs – with a worked example for $1,000.
- Stage 5 · Step 4First withdrawalSending bitcoin from an exchange to your own wallet: check the address, send a test amount, proof of ownership under the Travel Rule, whitelist, confirmations.
Sources6 sources · 3 publishers
The superscript numbers in the text refer to these sources.
- Hodl Hodl – P2P Bitcoin Trading Platform – Hodlex Ltd (accessed 28/09/2026)
- About Hodl Hodl – Hodlex Ltd (accessed 28/09/2026)
- FAQ – Hodl Hodl – Hodlex Ltd (accessed 28/09/2026)
- Hodl Hodl Bitcoin Fees Explained: Full Fee Guide – Hodl Hodl, 18.03.2026 (accessed 28/09/2026)
- Terms of Service – Hodlex Ltd, effective 04.06.2026 (accessed 28/09/2026)
- Interim MiCA Register – Crypto-Asset Service Providers (CASPS.csv) – ESMA, as of 24.09.2026 (accessed 28/09/2026)