Detailed overview
Ireland: Central Bank of Ireland MiCA Authorisation under the European Union (Markets in Crypto-Assets) Regulations 2024
Ireland is a full MiCA jurisdiction. The Irish framework is based on Regulation 2023/1114 and the Irish European Union (Markets in Crypto-Assets) Regulations 2024.
The Central Bank of Ireland is the Irish competent authority for MiCA.
Ireland should not be treated as a continuing VASP registration jurisdiction. The former Irish VASP regime was an AML, counter-terrorist-financing and financial-sanctions registration regime. It was not equivalent to MiCA authorisation and does not provide a simplified route into CASP authorisation.
Regulator
The main regulator is the Central Bank of Ireland.
The Central Bank receives CASP authorisation applications, receives Article 60 notifications, supervises authorised providers and exercises supervisory powers under MiCA and Irish law.
Other Irish and EU regimes may still apply where the activity involves payment services, e-money, e-money tokens, asset-referenced tokens, financial instruments, deposits, funds, insurance products, AML, sanctions, TFR, DORA or tax reporting.
Licensing route
A business that provides crypto-asset services in or from Ireland generally needs MiCA authorisation as a crypto-asset service provider unless it is an eligible financial entity using Article 60 or a duly authorised EU CASP passporting into Ireland.
The relevant crypto-asset services are custody and administration of crypto-assets for clients, operation of a crypto-asset trading platform, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of client orders, placing of crypto-assets, reception and transmission of orders, advice on crypto-assets, portfolio management on crypto-assets and transfer services for clients.
Transfer services are a separate MiCA service and should be included in the service-mapping analysis.
The licence perimeter applies only where the asset is within MiCA. Tokens that qualify as financial instruments, deposits, structured deposits, fund interests, payment instruments, non-MiCA e-money arrangements, insurance products or other regulated products require separate legal analysis.
Article 63 authorisation
A standard unregulated Irish CASP applicant applies to the Central Bank for MiCA authorisation.
A MiCA-authorised CASP must have a registered office in an EU Member State where it carries out at least part of its crypto-asset services, its effective management in the EU and at least one EU-resident director.
From 2 April 2026, CASP application documentation is submitted through the Central Bank Portal.
A credible Irish application should include a full service map, legal perimeter analysis, Irish home-state analysis, programme of operations, business plan, constitutional documents, proof of prudential safeguards, governance materials, local substance evidence, management fit-and-proper evidence, qualifying-holder information, internal controls, AML and counter-terrorist-financing procedures, sanctions controls, TFR procedures, risk assessment, business-continuity plan, ICT and DORA materials, client-asset and client-fund segregation procedures, complaints procedures, conflicts management, outsourcing framework, custody policy where relevant, trading-platform rules and market-abuse systems where relevant, exchange commercial policy and pricing methodology where relevant, execution policy where relevant, advice and portfolio-management competence evidence where relevant and transfer-service procedures where relevant.
The Central Bank may determine that an application is incomplete where required information is missing or inadequate. A complete and transparent application is therefore central to timing.
Central Bank process
The Irish authorisation process involves early engagement before formal filing.
The Central Bank expects applicant firms to engage through an initial meeting and key facts document before submitting the full application. The key facts document helps the Central Bank understand the proposed business model, operating model, risks and authorisation perimeter.
The Central Bank assesses completeness before moving to full substantive assessment. A complete file is then assessed against MiCA and Irish requirements.
The Central Bank may request additional information. Additional information requests can suspend the assessment clock in the circumstances permitted under MiCA.
Irish substance
Ireland is a high-substance authorisation jurisdiction.
The Central Bank expects firms to demonstrate substance and autonomy in Ireland. This includes a local crypto-competent Executive and Board, strong local governance, local risk-management capability, independent decision-making, sufficient size and expertise, and the ability to explain the business model and risk profile to the Central Bank.
Outsourcing is possible, but responsibility remains with the Irish regulated firm. Outsourcing risk must be managed within the Irish entity.
A thin Irish company with key decision-making, control functions, operational records and risk ownership located elsewhere is high risk.
Article 60 notification
Article 60 is not a general shortcut for unregulated applicants. It is a notification route for specified regulated financial entities and permitted crypto-asset services.
The Article 60 route may be relevant for credit institutions, central securities depositories, investment firms, market operators, electronic-money institutions, UCITS management companies and alternative investment fund managers.
A financial entity must notify the Central Bank before first providing the relevant crypto-asset services. It must also check whether the proposed crypto-asset services require approval or notification under its existing regulatory regime.
A regulated entity must map each proposed crypto-asset service to its existing authorisation and to the MiCA Article 60 equivalence rules.
A regulated entity that wants to provide non-equivalent crypto-asset services may still need full CASP authorisation.
Transitional position
Ireland’s MiCA transition has expired.
A CASP that provided crypto-asset services lawfully before 30 December 2024 could continue only until 30 December 2025 or until authorisation was granted or refused, whichever occurred sooner.
Only firms registered as VASPs and operating before 30 December 2024 could rely on the Irish transition.
VASP registration was not MiCA authorisation and should not be marketed as such.
Ireland did not provide a simplified authorisation process for VASPs because the Irish VASP regime was a registration regime, not an authorisation regime.
New or continuing Ireland-facing crypto-asset service activity should be structured through MiCA authorisation, a valid Article 60 route or a valid MiCA passport.
Passporting and register checks
A MiCA-authorised CASP may provide its authorised services across the EU through the MiCA passport, subject to the required notification process and authorised service scope.
A legacy Irish VASP registration did not give passporting rights.
Central Bank and ESMA register information should be checked before relying on a provider’s authorisation status, onboarding a counterparty, launching services or publishing any authorisation claim.
A CASP passporting into Ireland should also check the Irish Consumer Protection Code. The revised Code applies to activities regulated under MiCA.
PSD2 and EMT activity
EMT-related activity should be analysed separately.
The Central Bank has stated that certain MiCA activities involving e-money tokens may also qualify as payment services under PSD2. This can include transfer services and custody involving EMTs.
A CASP providing EMT-related services may require authorisation as a payment institution or may need a compliant arrangement with an authorised payment service provider.
The EBA no-action transition deadline for this overlap has passed. A relevant firm that does not have the necessary permission or arrangement should not assume it can continue EMT-related payment activity.
Wallets, EMT transfers, EMT custody, settlement models, payment-like flows and client-balance models should be assessed before launch.
Token issuance and white papers
CASP authorisation and token-offer compliance are separate.
For crypto-assets other than ARTs and EMTs, MiCA may require a white paper and compliant marketing communications, but the Central Bank does not approve those white papers. The Central Bank reviews whether the submission is complete.
ARTs and EMTs have separate MiCA treatment and may involve additional authorisation, notification, e-money, banking or payment-services analysis.
A CASP licence should not be treated as covering public offers, admission to trading, ART issuance, EMT issuance or white-paper obligations.
Costs
Applicants should budget for Central Bank costs and ongoing levy exposure.
The Central Bank industry-funding framework applies to regulated entities authorised or registered by the Central Bank. Firms authorised during a year may be liable on a pro-rata basis.
A fixed CASP application fee should be checked against the current Central Bank fee schedule before filing or publication.
These amounts are not the full cost of authorisation. Applicants should also budget for legal, governance, AML, sanctions, TFR, DORA, ICT, custody, outsourcing, complaints, conflicts, audit, accounting, prudential, insurance and operational implementation costs.
Prudential safeguards
A CASP must maintain MiCA prudential safeguards at all times.
The required amount is at least the higher of the applicable permanent minimum capital requirement and one quarter of fixed overheads for the preceding year.
The MiCA class amounts are EUR 50,000 for class 1, EUR 125,000 for class 2 and EUR 150,000 for class 3.
Class 1 covers execution of orders, placing, transfer services, reception and transmission of orders, advice and portfolio management.
Class 2 includes class 1 services plus custody and administration, exchange of crypto-assets for funds and exchange of crypto-assets for other crypto-assets.
Class 3 includes class 2 services plus operation of a crypto-asset trading platform.
Where a provider offers services in more than one class, the highest applicable class applies.
Prudential safeguards may take the form of own funds, an insurance policy, a comparable guarantee or a permitted combination.
AML, TFR and DORA
Irish CASPs must prepare AML, sanctions, TFR and ICT controls before filing.
Core controls include customer due diligence, beneficial ownership analysis, AML risk assessment, sanctions screening, transaction monitoring, suspicious-activity escalation, travel-rule procedures, treatment of self-hosted addresses where relevant, outsourcing oversight, recordkeeping and staff training.
DORA and ICT readiness are central. An Irish application should include ICT governance, security documentation, incident management, business continuity, outsourcing controls and operational-resilience evidence.
The former VASP regime does not replace MiCA, TFR, DORA or CASP authorisation requirements.
Ongoing obligations
An Irish CASP must comply with MiCA, Irish implementation law, Central Bank supervisory requirements, AML and counter-terrorist-financing obligations, sanctions controls, TFR, DORA and applicable consumer-protection rules.
Core obligations include governance, management suitability, qualifying-holder controls, prudential safeguards, internal controls, risk management, AML and counter-terrorist-financing procedures, sanctions controls, transaction monitoring, TFR implementation, business continuity, ICT and DORA controls, outsourcing oversight, complaints handling, conflicts management, custody safeguards, client-asset and client-fund segregation, recordkeeping, fair and non-misleading client information, cost and fee transparency, market-abuse systems where relevant and service-specific conduct rules.
Enforcement risk
Ireland is not a light-touch jurisdiction.
The Central Bank may request information, suspend crypto-asset services, prohibit crypto-asset services, publish non-compliance and order immediate cessation where there is reason to assume unauthorised crypto-asset services.
Irish sanctions can include public statements, cease-and-desist orders, disgorgement, management bans and monetary sanctions.
For relevant CASP-related legal-person infringements, monetary sanctions may reach EUR 5,000,000 or 5 percent of annual turnover.
The main enforcement risks are operating without MiCA authorisation, relying on expired transition, presenting VASP registration as MiCA authorisation, using Article 60 without eligibility, providing services outside authorised scope, weak AML or TFR controls, weak DORA readiness, ignoring PSD2 and EMT overlap, insufficient Irish substance and misleading marketing or authorisation claims.
Practical assessment
Ireland is suitable for firms that want MiCA authorisation through a sophisticated EU financial regulator and are prepared to build real Irish substance.
It is not suitable for firms looking for a paper registration, continued VASP transition, automatic conversion from VASP status, or a low-substance EU gateway.
The main execution risks are incorrect service classification, missing transfer services, treating Article 60 as a general shortcut, relying on expired transition, underestimating Central Bank expectations, weak Irish substance, overlooking PSD2 or EMT issues, failing to evidence prudential safeguards and filing before AML, TFR, DORA, ICT, custody, outsourcing, complaints, conflicts and service-specific controls are ready.