MiCA · Central Bank of Ireland
Ireland
One authorisation, twenty-seven markets. Which is why the choice of member state is a commercial decision, not an administrative one.
Verified
These claims have been checked against the instrument or the regulator's own material. Where a position is unsettled or a rule is still in draft, the page says so rather than implying certainty.
- Irish transitional period shortened to 12 months, ending 30 Dec 2025 — Department of Finance national discretion
- 1 Jul 2026 is the EU-wide outer boundary only; national periods ran 6, 9, 12 or 18 months
- CASP authorisation passports across all 27 — MiCA
- DAC8 self-certification by 1 Jan 2027 is an outer limit; national transposition varies
- AMLR (EU) 2024/1624 applies 10 Jul 2027; AMLA direct supervision from 1 Jan 2028
Why this matters now
A CASP authorisation obtained in any EU member state passports across all 27 EU and EEA states, which makes the home-state choice a question of processing time, regulator capacity, cost and substance appetite rather than of law. Ireland exercised the national discretion to shorten its transitional period to twelve months, so grandfathering here ended on 30 December 2025 — earlier than in member states that took the full eighteen months. Any firm still serving EU clients without authorisation is in breach rather than merely unlicensed.
Who is in scope
Whether this reaches you.
- Crypto-asset service providers serving EU clients
- Non-EU firms that need EU market access
- Issuers of asset-referenced and e-money tokens
- Firms whose grandfathering has now lapsed
Obligations
What the regime actually requires.
CASP authorisation
Full application to the Central Bank, with governance, prudential and operational requirements evidenced.
Substance
Real presence — the authorisation is not a mailbox exercise, and this is where applications most often stall.
DORA
Operational resilience obligations apply alongside MiCA, including the third-party register.
DAC8
Data collection began January 2026. Self-certification for relationships existing at 31 December 2025 is due by 1 January 2027 — but that is the outer limit and national transposition varies, so check the member state you registered in. Poland, for instance, requires it by 31 October 2026.
Transitional position
Only firms registered as VASPs and operating lawfully before 30 December 2024 could use the transitional period at all. Anyone else needed authorisation from the start.
Dates
When.
| Date | Event |
|---|---|
| Irish grandfathering ended — national period shortened to 12 months | |
| EU-wide outer boundary: no member state could grandfather beyond this | |
| DAC8 self-certification for pre-existing users — outer limit; some member states require it earlier | |
| AMLR (EU) 2024/1624 applies; AMLA direct supervision from 1 Jan 2028 | |
| AMLA supervision begins |
What we do
How we help here.
- Member-state comparison against your model and timeline
- CASP application preparation and submission
- Substance planning and the annual file that evidences it
- DORA readiness
- DAC8 scoping, remediation and filing
Sources
- 01MiCA (Regulation (EU) 2023/1114)
Authorisation and passporting - 02Central Bank of Ireland — impact of MiCAR on VASPs
Confirms the twelve-month Irish transitional period ending 30 December 2025 - 03ESMA list of MiCA grandfathering periods (Art. 143(3))
Member-state periods ranged from six to eighteen months - 04DAC8 (Directive (EU) 2023/2226)
Reporting obligations and timing
Does Ireland bind you?
Tell us where you are established, where your customers are and what you hold. That is usually enough to answer it — and to say what is already late.