Ireland Crypto‐Asset Licensing
To operate crypto-asset services from Ireland, a startup must obtain Markets in Crypto-Assets Regulation (MiCAR) authorisation as a Crypto-Asset Service Provider (CASP), which is obligatory for custody, trading-platform operation, any exchange, execution, reception, transmission, placing, portfolio management, advice or transfer services across the EU.
A firm already registered and operating as a VASP before 30 December 2024 can keep trading for up to 12 months (to 29 December 2025) while its CASP application is processed; all others must wait for full CASP authorisation before launching.
CBI experience shows a VASP application alone typically takes at least ten months; the Bank therefore advises new entrants to go straight to the CASP route instead of pursuing late VASP registration.
Any of the following eleven services provided “for clients” in or from Ireland: custody/administration, operation of a trading platform, exchange (crypto↔funds or crypto↔crypto), order execution, order reception & transmission, placing, portfolio management, advice, and transfer services.
1. Initial engagement – request a meeting; submit a slide deck at least ten working days beforehand. CBI outlines expectations and any gating issues.
2. Key Facts Document (KFD) stage – lodge the prescribed KFD template. Expect iterative feedback; quality at this stage materially drives the timeline.
3. Formal application – when invited, file the CASP Application Form plus, if you are not already a VASP, an AML/CFT Pre‑Authorisation Risk Evaluation Questionnaire. CBI checks completeness within 25 working days; missing items must be supplied within the time it sets.
4. Regulatory assessment – once complete, CBI has 40 working days (with a single possible pause of up to 20 days for additional information) to evaluate governance, business model, capital, risk management, IT/operational resilience (including DORA readiness) and customer‑protection arrangements.
5. Decision – CBI communicates approval or refusal within five working days of the decision.
- Maintain robust AML/CFT controls identical to those required of VASPs (risk assessment, customer due diligence, monitoring, STR filing, record‑keeping, staff training).
- Meet prudential capital or insurance, organisational, complaints‑handling, governance and safeguarding requirements contained in MiCAR (CBI and, for significant stablecoins, the European Banking Authority will supervise).
- Observe new EU‑wide market‑abuse prohibitions for crypto‑assets (insider dealing, unlawful disclosure, market manipulation).
- Ensure all persons in “controlled” or “pre‑approval controlled” functions remain fit and proper under the CBI Fitness & Probity regime; the obligation extends to beneficial owners.
Issuers of asset‑referenced tokens (ARTs) and e‑money tokens (EMTs) already require authorisation and a white paper since 30 June 2024; engage CBI’s authorisations team early. CASPs must delist or upgrade non‑compliant ARTs/EMTs by end‑Q1 2025.
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Where your business model includes custody or transfer of EMTs, those activities also qualify as payment services. You will therefore need either:
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a Payment Institution licence under PSD2 in addition to the CASP authorisation, or
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a partnership with an existing licensed payment‑service provider.
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The European Banking Authority expects dual licensing (or an alternative arrangement) to be in place by 2 March 2026. CBI will streamline the extra authorisation as far as possible using information already supplied in the CASP file.
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Behind Licentium
Our Edge
Licentium is a specialized platform that connects crypto-asset issuers and service providers with an international network of lawyers, regulatory consultants, and former supervisors. Projects can map applicable rules in key jurisdictions through a single interface, obtain jurisdiction-specific launch advice, arrange the drafting of white papers and licensing applications, and schedule ongoing compliance health-checks. The platform’s curated expert pool spans financial services, data protection, and corporate law, enabling founders to address cross-border requirements—from MiCA in the EU to securities, AML, and consumer-protection regimes elsewhere—within coherent project timelines and budgets.
