Central Bank of Ireland Opens Consultation on DLT and Tokenisation in Financial Services, March 2026

On 5 March 2026, the Central Bank of Ireland (CBI) published Discussion Paper 12 (DP12), titled "Distributed Ledger Technology (DLT) & Tokenisation in Financial Services." The paper is active and open for public consultation until 5 June 2026. It is a non-binding discussion instrument that initiates structured dialogue with domestic and international stakeholders on how DLT and tokenisation are reshaping financial services and what regulatory responses may be appropriate.

DP12 is issued under the CBI's mandate as Ireland's national financial regulator and central bank, operating within the broader EU regulatory architecture that includes Regulation (EU) 2022/858 on a pilot regime for market infrastructures based on distributed ledger technology (the DLT Pilot Regime) and Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA). The discussion paper addresses the full application spectrum: from tokenised securities, funds, and bonds, to settlement infrastructure and the role of central bank digital currencies. The CBI invites comment on questions across seven thematic areas, including governance, risk management, investor protection, and systemic stability.

Firms operating in Irish financial services — including credit institutions, investment firms, fund managers, payment institutions, and crypto-asset service providers — face direct engagement obligations. The CBI expects regulated entities to assess how DLT and tokenisation fit within their existing risk and compliance architecture, and to contribute written responses by the 5 June 2026 deadline. Non-Irish EU firms passporting into Ireland are also within scope, as the CBI's DP12 analysis feeds into Ireland's input to EU-level policy development.

The paper signals that formal regulatory proposals may follow after the consultation period closes. The CBI has not announced a specific timeline for any subsequent rulemaking, leaving open whether DP12 responses will inform a formal supervisory notice, guidance note, or contribution to ESMA or EBA standard-setting. Firms that provide submissions gain an early position in shaping any future Irish or EU-level requirements for DLT-based financial services.

Licentium advises on licensing, regulatory structuring, and compliance strategy for crypto-asset service providers, DLT-based financial services firms, and tokenisation projects across EU and common law jurisdictions. Our partner network covers Irish financial regulation, MiCA authorisation, and distributed ledger technology law. Contact us to discuss your position. Examples of matters we handle or assign to partners: CASP authorisation under MiCA, DLT Pilot Regime applications, tokenised fund structuring, cross-border passporting, and regulatory sandbox engagement with EU financial regulators.

Source: Central Bank of Ireland, Discussion Paper 12 — Distributed Ledger Technology (DLT) & Tokenisation in Financial Services, DP12, published 5 March 2026, consultation closes 5 June 2026. Official URL: https://www.centralbank.ie/publication/discussion-papers/discussion-paper-detail/discussion-paper-12-dlt-tokenisation-in-financial-services. Confirmed 23 March 2026.

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