Ireland CASP Authorisation: MiCA Licence from the Central Bank of Ireland
Ireland CASP authorisation under MiCA: the Central Bank engagement meeting and Key Facts Document, €50,000 to €150,000 capital, substance and timeline.
Written and reviewed by the Regulatory Counsel team. Last reviewed: 19 October 2026.
The short answer
An Ireland CASP authorisation is a licence granted by the Central Bank of Ireland under Article 63 of the Markets in Crypto-Assets Regulation (MiCA) to an Irish company providing crypto-asset services, such as custody, exchange, brokerage or transfers for clients. It is valid across the European Union through the MiCA passport.
The Central Bank runs a structured process. An initial engagement meeting comes first, then a Key Facts Document (KFD), a detailed pre-application summary of the proposal in the Central Bank's template. Only then is the firm invited to submit the formal application, through the Central Bank Portal. From there MiCA's statutory timetable applies: completeness within 25 working days and a decision within 40 working days of a complete application.
The Central Bank expects substance and autonomy in Ireland, led by a local crypto-competent executive team and board, with full local control of client assets. Capital is €50,000, €125,000 or €150,000 by service class, or one quarter of fixed overheads if higher. The Irish transitional period ended on 30 December 2025.
Key facts at a glance
| Regulator | Central Bank of Ireland, designated competent authority for MiCA |
|---|---|
| Legal basis | Regulation (EU) 2023/1114 (MiCA) and S.I. No. 607 of 2024 |
| Permission | CASP authorisation under MiCA Article 63, listing each service authorised |
| Entity | An Irish company with its registered office in Ireland and its place of effective management in the EU |
| Leadership | Local crypto-competent executive team and board with autonomy from the group. Pre-Approval Controlled Function (PCF) holders assessed for fitness and probity |
| Minimum capital | €50,000, €125,000 or €150,000 by service class (MiCA Annex IV), or one quarter of the previous year's fixed overheads if higher |
| Process | Initial engagement meeting, Key Facts Document, invitation to apply, formal application through the Central Bank Portal |
| Statutory timetable | Completeness within 25 working days; decision within 40 working days of a complete application; one pause of up to 20 working days |
| Transitional period | Ended 30 December 2025 (Regulation 20 of S.I. No. 607 of 2024) |
| First contact | caspauthorisations@centralbank.ie, or the Innovation Hub for firms with no existing Central Bank contact |
| EU passport | Article 65 notification. Services may start in each host state from the Central Bank's confirmation or, at the latest, the 15th calendar day after notifying |
| Authorised firms | Twelve entries with Ireland as home state on the ESMA interim MiCA register (update of 16 October 2026) |
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Tell us the business, the markets and your timing. Every enquiry is answered the same business day, with a written proposal: the licence, the requirements, the cost and the timeline.
Your enquiry
What is the Ireland CASP Authorisation (MiCA)?
An Ireland CASP authorisation is the licence the Central Bank of Ireland grants under the Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114 (MiCA), to an Irish company providing crypto-asset services. Ireland gave effect to MiCA through S.I. No. 607 of 2024, which designates the Central Bank as competent authority and set a 12 month transitional period for existing Irish VASPs ending on 30 December 2025.
The authorisation is valid across the European Union. An Irish CASP can serve clients in other member states by notification, without a separate licence in each. The Central Bank applies MiCA in full together with its own authorisation and supervision expectations, published in December 2024, and its cross-sectoral guidance for applicant firms.
The Central Bank's stated objective is clarity, transparency and predictability for applicants, combined with the standards the public expects of regulated firms. Firms that show they meet and will continue to meet those standards can expect to be authorised in a timely manner.
Who needs Ireland CASP Authorisation (MiCA)?
Any firm that wants to provide crypto-asset services from Ireland, or to make Ireland its EU home state, needs this authorisation.
- - Crypto exchanges and brokers serving retail or institutional clients
- - Custodians holding crypto-assets for clients
- - Payment firms adding crypto transfer or conversion services
- - Investment firms and banks building crypto services that go beyond an Article 60 notification
- - Global groups placing their EU crypto business in an English-speaking, common law jurisdiction with genuine Irish leadership
- - Former Irish VASPs that did not complete MiCA authorisation before 30 December 2025
Irish VASP registration under anti-money laundering law is not a MiCA authorisation and the transitional period ended on 30 December 2025. Equally, the KFD stage is not optional paperwork: the Central Bank invites the formal application only after the KFD has addressed the issues it raises.
The Central Bank of Ireland authorisation process, stage by stage
The Central Bank publishes a defined route for CASP applicants. The pre-application stages are where the substance of the proposal is tested, so the formal application that follows is focused and complete.
| Stage | What happens | Timing |
|---|---|---|
| First contact | New applicants email the CASP Authorisation Team with the information in Section 4.3 of the System Submissions Guide. Firms with no Central Bank contact may start with the Innovation Hub | At the applicant's initiative |
| Initial engagement meeting | The applicant presents its proposal. The Central Bank sets out the stages, its authorisation and supervision expectations and the purpose of the KFD | Presentation submitted at least 10 working days before the meeting |
| Key Facts Document | The applicant submits a KFD in the Central Bank template, including detailed DORA content. The Central Bank assesses alignment with its expectations and raises issues to resolve | Continuous engagement until the Central Bank invites the application |
| Formal application | The applicant submits the CASP Application Form through the Central Bank Portal. Firms that are not Irish VASPs also complete the AML, CFT and Financial Sanctions Pre-Authorisation Risk Evaluation Questionnaire | Completeness review within 25 working days |
| Assessment | The Central Bank assesses the complete application. It may request additional information once, pausing the clock | 40 working days, plus one pause of up to 20 working days |
| Decision | The Central Bank grants or refuses authorisation and notifies the applicant | Within 5 working days of the decision |
Substance and governance the Central Bank expects
The Central Bank's MiCAR Authorisation and Supervision Expectations (December 2024) state that firms must demonstrate substance and autonomy in Ireland and be led by a local crypto-competent executive and board with a strong understanding of the local regulatory environment.
- - PCF role holders of good repute, with crypto knowledge, skills, experience and sufficient time, supported by evidence of the applicant's own due diligence
- - A board with full oversight of the firm and its risks, of sufficient size, expertise and independence
- - Local autonomy: the Irish board makes decisions independently of any group board
- - A clear organisational structure with consistent lines of responsibility
- - A strategy and plan with measurable actions to embed a customer-centric culture
- - Where significant passporting or outsourcing is proposed, a stated rationale for seeking authorisation in Ireland
Protection of client assets
The Central Bank expects the Irish entity to have full control of all client assets and associated safeguarding accounts, with full segregation. MiCA Article 70 requires client funds, other than e-money tokens, to be placed with a credit institution or central bank by the end of the next business day.
- - A Head of Client Asset Oversight is appointed
- - A safeguarding framework with reconciliations, internal controls and detailed policies and procedures
- - Safeguarding expertise on the board, in particular among non-executive directors
- - An annual conflicts of interest assessment reviewed by the board
- - Independent third-party assurance each year that the safeguarding framework operates as described. The Central Bank may also require it for initial authorisation
Business model and financial resilience
The Central Bank expects a board-approved business strategy that shows the business model is viable and sustainable, including under a plausible but severe stress scenario, and plans for a safe and orderly exit from the market. Its assessment considers the use case and utility of the product, whether clients are retail or institutional, and the conduct risks involved. Higher inherent risk in the offering means higher expectations of the firm's controls.
For group structures, the Central Bank applies ESMA's Opinion of 31 July 2024 on global crypto firms that seek authorisation for brokerage in the EU while keeping intra-group execution venues outside it. Applicants with that model should address it directly in the KFD.
AML, the Travel Rule and DORA
- - Anti-money laundering: Irish law implementing Directive (EU) 2015/849 applies today. The EU Anti-Money Laundering Regulation (EU) 2024/1624 applies from 10 July 2027
- - Pre-authorisation questionnaire: applicants that are not existing Irish VASPs complete the AML, CFT and Financial Sanctions Pre-Authorisation Risk Evaluation Questionnaire
- - Travel Rule: Regulation (EU) 2023/1113 has applied since 30 December 2024, requiring originator and beneficiary information on every crypto-asset transfer
- - DORA: Regulation (EU) 2022/2554 has applied to CASPs since 17 January 2025. The CASP KFD asks for a more prescriptive level of DORA detail than earlier templates
E-money tokens and the payment institution licence
Custody and transfer services involving e-money tokens are payment services under PSD2. The Central Bank has confirmed that, under the EBA no-action letter, relevant CASPs have needed a payment institution authorisation, or a partnership with a payment service provider, since 2 March 2026, and that it has no discretion to extend that date.
Where both licences are needed, the Central Bank runs two assessments but shares information between the teams and relies to a large extent on the CASP submission for the payment institution application. We prepare both on a single set of governance, AML and ICT documents.
Existing regulated firms: the Article 60 notification
Credit institutions, MiFID investment firms, e-money institutions (for their own e-money tokens), in-scope UCITS management companies, alternative investment fund managers, central securities depositories and market operators can provide equivalent crypto services by notification instead of authorisation. MiCA requires 40 working days' notice. The Central Bank may extend that period if it needs further information, which it must request within the first 20 working days.
The Central Bank expects these firms to contact their supervision team before notifying and to confirm whether their existing licence requires prior approval for the change.
Passporting from Ireland and ongoing supervision
After authorisation the firm notifies the Central Bank of its target member states under MiCA Article 65. The Central Bank passes the notification on within 10 working days, and services may start from its confirmation or, at the latest, on the 15th calendar day after notification.
Authorised CASPs submit regulatory returns to the Central Bank, including the quarterly CASP return announced in March 2026, maintain capital at all times, notify changes to PCF holders and qualifying holdings, and keep a wind-down plan where they provide custody, trading platform, exchange, execution or placing services.
Ireland and Lithuania compared
Both apply the same MiCA requirements and statutory timetable. The differences are the pre-application route, language and local expectations.
| Point | Ireland (Central Bank of Ireland) | Lithuania (Bank of Lithuania) |
|---|---|---|
| Pre-application stage | Initial engagement meeting and Key Facts Document before an invitation to apply | No formal stage published |
| Application channel | Central Bank Portal, mandatory since 2 April 2026 | Prescribed forms and annexes under the Licensing Rules |
| Language | English | Business plan and client-facing procedures in Lithuanian |
| Leadership | Local crypto-competent executive team and board, autonomous from the group | At least part of key decision makers resident in Lithuania |
| Client assets | Head of Client Asset Oversight and annual independent safeguarding assurance | MiCA segregation and safeguarding rules |
| Transitional period ended | 30 December 2025 | 31 December 2025 |
| Home-state entries on ESMA register (16 October 2026) | Twelve | Six |
Key requirements
Capital
The higher of the MiCA Annex IV floor (€50,000 for Class 1, €125,000 for Class 2, €150,000 for Class 3) and one quarter of the previous year's fixed overheads, held as Common Equity Tier 1 own funds, a qualifying insurance policy, or both. Transfer services are Class 1.
Irish substance and autonomy
An Irish company with substance in Ireland, led by a local crypto-competent executive team and board that decides independently of any group board, with adequate resources for its business.
Fitness and probity
PCF role holders of good repute with crypto knowledge, skills, experience and time, evidenced by the applicant's own due diligence and assessed under the joint EBA and ESMA suitability guidelines.
Client assets
Full local control of client assets and safeguarding accounts, a Head of Client Asset Oversight, a reconciled safeguarding framework and annual independent assurance.
AML, Travel Rule and DORA
An AML and financial sanctions framework for the firm's crypto business, Travel Rule compliance under Regulation (EU) 2023/1113 and a DORA-compliant ICT risk framework detailed in the KFD.
Business model and exit
A board-approved, viable strategy tested under a severe but plausible stress scenario, and a plan for a safe and orderly market exit.
What does an Ireland CASP authorisation cost?
The cost is driven by regulatory capital and by the Irish team, board and control functions the Central Bank expects to see.
- - Regulatory capital: €50,000, €125,000 or €150,000 by class, or one quarter of fixed overheads if higher, held as Common Equity Tier 1 own funds, a qualifying insurance policy, or both
- - Local leadership: an Irish executive team, PCF holders and a board with independent non-executive directors, including safeguarding expertise
- - Control functions: compliance, risk, money laundering reporting, internal audit and a Head of Client Asset Oversight
- - Independent assurance on the safeguarding framework, annually and possibly at authorisation
- - Systems: blockchain analytics, Travel Rule messaging, transaction monitoring, sanctions screening and DORA-compliant ICT arrangements
- - Ongoing Central Bank supervisory levies once authorised
- - Professional fees: we quote a fixed fee once the scope is confirmed
The application process
First contact
We prepare the information required by Section 4.3 of the System Submissions Guide and contact the CASP Authorisation Team, or the Innovation Hub where appropriate.
Initial engagement meeting
We prepare your proposal presentation, submitted at least 10 working days before the meeting, and your leadership team for the discussion.
Key Facts Document
We draft the KFD in the Central Bank template, including DORA detail, and manage the engagement until the Central Bank invites your application.
Formal application
We submit the CASP Application Form and supporting documents through the Central Bank Portal. Completeness is reviewed within 25 working days.
Assessment and decision
The Central Bank decides within 40 working days of a complete application, with one possible pause of up to 20 working days, and notifies the decision within 5 working days.
Passport
We file Article 65 notifications for your target member states. Services may start in each from the Central Bank's confirmation or at the latest the 15th calendar day.
The pre-application stages run at the pace of your readiness. The formal application follows MiCA: completeness within 25 working days and a decision within 40 working days of a complete application, with one possible pause of up to 20 working days.
How long does an Ireland CASP authorisation take?
The formal application follows MiCA Article 63: completeness within 25 working days, then a decision within 40 working days of a complete application. The Central Bank may pause the assessment once, for up to 20 working days, to request additional information, and notifies its decision within 5 working days.
The Central Bank states that the overall duration depends on the nature, scale and complexity of the firm and how prepared it is, and that the best-prepared firms that engage transparently proceed most efficiently. Time spent getting the KFD right is time saved at the formal stage. A firm that arrives with its team, capital and documents ready moves through on the Central Bank's own timetable.
Why applications fail, and how we prevent it
Leadership not yet in Ireland
The Central Bank expects a local crypto-competent executive team and board. Recruit before the engagement meeting.
Group dependence
Boards that defer to a group board, or models that rely on non-EU execution venues, need a clear explanation. Address autonomy and group structure in the KFD.
Client assets controlled outside the entity
The Irish entity must control all client assets and safeguarding accounts. Design segregation and reconciliation before filing.
Incomplete portal submissions
The Central Bank may refuse to review an application that remains incomplete after its deadline. Follow the System Submissions Guide and submit a complete pack.
Practitioner notes on Irish CASP applications
- - Treat the KFD as the application. The Central Bank tests substance, governance and the business model there
- - Hire the Irish leadership before the engagement meeting. The Central Bank expects to meet the people who will run the firm
- - Appoint the Head of Client Asset Oversight early and design safeguarding reconciliations before filing
- - Explain group structures openly, including any non-EU execution venue or intra-group outsourcing
- - Build the PSD2 position into the plan if you will hold or transfer e-money tokens for clients
- - Follow the System Submissions Guide closely. Portal submissions must be complete and consistent
- - State plainly what is not yet known. The Central Bank's engagement principles ask applicants to say so rather than guess
How we help
Process management
We manage the engagement meeting, the KFD stage, the portal submission and every round of Central Bank correspondence through to authorisation.
KFD and application
Business plan, governance and PCF submissions, safeguarding framework, AML and Travel Rule framework and DORA documentation, written for your model.
Compliance after authorisation
Passporting notifications, Central Bank returns, safeguarding assurance, PCF changes, AML reviews and DORA incident processes.
Regulatory Counsel obtains licences and runs compliance across 65+ jurisdictions. For an Ireland CASP authorisation we prepare your engagement meeting and Key Facts Document, build the formal application for the Central Bank Portal, and keep your governance, safeguarding and AML framework aligned with MiCA after authorisation. We answer every enquiry the same business day with a written proposal, and we quote a fixed fee once the scope is confirmed.
Frequently asked questions
Contact the Central Bank's CASP Authorisation Team, attend an initial engagement meeting, submit a Key Facts Document, and when invited file the formal application through the Central Bank Portal. The Central Bank then checks completeness within 25 working days and decides within 40 working days of a complete application.
The KFD is the Central Bank's pre-application template for CASPs. It sets out the proposal in detail, including DORA content, so the Central Bank can test it against its expectations before inviting the formal application.
The formal stage follows MiCA: 25 working days for completeness and 40 working days for a decision on a complete application, with one pause of up to 20 working days. The pre-application stages depend on the firm's preparedness; the Central Bank says the best-prepared firms move most efficiently.
€50,000 for Class 1 services such as execution, transfer, advice and order transmission; €125,000 with custody or exchange; €150,000 with a trading platform. The firm must hold the higher of that floor and one quarter of its previous year's fixed overheads.
The Central Bank expects a local crypto-competent executive team and board with autonomy from the group. MiCA requires at least one director resident in the EU, and ESMA expects at least one executive board member resident in the authorising member state.
Regulation 20 of S.I. No. 607 of 2024 allowed existing Irish VASPs to continue until 30 December 2025 or until their MiCA application was decided, whichever came first. That period has ended.
Since 2 April 2026 all CASP application documents go through the Central Bank Portal. New applicants first email caspauthorisations@centralbank.ie with the information set out in Section 4.3 of the System Submissions Guide.
Yes. You notify the Central Bank of your target member states under MiCA Article 65. Services may start in each from the Central Bank's confirmation or, at the latest, on the 15th calendar day after notification.
If you provide custody or transfers of e-money tokens for clients, yes: since 2 March 2026 you need PSD2 authorisation or a partnership with a payment service provider. The Central Bank reuses much of the CASP submission for the payment application.
Yes, within limits, through a MiCA Article 60 notification with 40 working days' notice. Investment firms can provide services equivalent to their existing permissions; e-money institutions only custody and transfers of their own e-money tokens.
The ESMA interim MiCA register update of 16 October 2026 shows twelve entries with Ireland as home state, including Payward Europe Solutions Limited, Interactive Brokers Ireland Limited, StoneX Digital International Limited and CoinJar Europe Limited.
Primary sources
The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.
- Central Bank of Ireland: Markets in Crypto-Assets Regulation (MiCAR)
- Central Bank of Ireland: MiCAR frequently asked questions
- Central Bank of Ireland: MiCAR Authorisation and Supervision Expectations (December 2024)
- S.I. No. 607 of 2024, European Union (Markets in Crypto-Assets) Regulations 2024
- Regulation (EU) 2023/1114 on markets in crypto-assets (EUR-Lex)
- ESMA: MiCA page and interim MiCA register
- ESMA: supervisory briefing on the authorisation of CASPs (January 2025)
Last reviewed by the Regulatory Counsel team on 19 October 2026.