Crypto License Ireland: CBI CASP Registration Under MiCA

A crypto license in Ireland today means a Crypto-Asset Service Provider (CASP) authorisation granted by the Central Bank of Ireland under the EU's Markets in Crypto-Assets Regulation (MiCAR). It replaces the AML-only VASP registration, carries minimum capital of EUR 50,000 to 150,000 by service class, and confers passporting rights across the EU and EEA.

If you searched for "crypto license Ireland" expecting a bespoke Irish licence, the more important point is this: Ireland no longer runs a standalone crypto regime. Since 30 December 2024, the licence that matters is the MiCAR CASP authorisation, a single EU framework applied nationally by the Central Bank of Ireland. Get authorised once in Ireland, and you can serve the entire single market. This guide walks through who regulates you, what the licence covers, how much capital you need, the step-by-step Central Bank process, your ongoing obligations, and why firms choose Ireland as their EU base. It is written for founders, exchange operators and compliance officers evaluating Ireland against other MiCAR jurisdictions such as Spain's CNMV CASP route or Germany's BaFin CASP authorisation.

Who regulates crypto in Ireland and what licence you actually need

The Central Bank of Ireland (CBI) is the single authority for crypto-asset licensing in Ireland. It is the designated National Competent Authority (NCA) for MiCAR, and it issues the CASP authorisation that lets a firm provide crypto-asset services lawfully in Ireland and across the EU. Any reference you find to a separate "Irish crypto licence" outside MiCAR is now historical.

The Central Bank of Ireland as MiCAR National Competent Authority

The Central Bank of Ireland was designated the National Competent Authority for MiCAR under S.I. No. 607/2024, the European Union (Markets in Crypto-Assets) Regulations 2024, published on 12 November 2024. That designation gives the CBI two related roles. It administered the legacy VASP AML registration regime, and it now authorises and supervises CASPs under MiCAR. In practice this means a single regulator handles your entire crypto-licensing relationship in Ireland, from pre-application engagement through authorisation to ongoing supervision under MiCAR and the Digital Operational Resilience Act (DORA).

CASP authorisation vs the old VASP AML registration

These two regimes are frequently confused, so it is worth stating the distinction plainly. A VASP (Virtual Asset Service Provider) registration was an AML/CFT registration only. Since 23 April 2021, virtual asset service providers became subject to anti-money-laundering and counter-terrorist-financing requirements for the first time and had to register with the Central Bank under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended). It was never a full prudential or conduct licence.

A CASP authorisation, by contrast, is the full MiCAR licence. It has applied to CASPs since 30 December 2024 and, in the Central Bank's own words, is "significantly broader and more substantial than a VASP registration." Where the VASP regime tested only your AML controls, the CASP regime tests capital, governance, conduct of business, ICT resilience and consumer protection. If you are unsure which applies to your model, our explainer on VASP vs CASP under MiCA covers the practical differences in detail.

What is a CASP and which crypto services need authorisation

A CASP is a firm authorised under MiCAR to provide one or more defined crypto-asset services. MiCAR fixes a closed list of activities, set out in Annex IV. If your business model touches any of these activities on a professional basis, you need a CASP authorisation before you can serve EU clients.

The 10 MiCAR crypto-asset services (Annex IV)

MiCAR recognises ten crypto-asset services. The class of authorisation you need, and the capital you must hold, depends on which of these you intend to provide:

• Custody and administration of crypto-assets on behalf of clients
• Operation of a trading platform for crypto-assets
• Exchange of crypto-assets for funds
• Exchange of crypto-assets for other crypto-assets
• Execution of orders for crypto-assets on behalf of clients
• Placing of crypto-assets
• Reception and transmission of orders for crypto-assets on behalf of clients
• Advice on crypto-assets
• Portfolio management of crypto-assets
• Transfer services for crypto-assets on behalf of clients

This list is drawn from MiCAR Annex IV as set out in ESMA's interactive rulebook. The combination of services you select determines your capital class, which we cover below.

Activities that fall outside MiCAR

Not every firm touching crypto-assets needs a full CASP authorisation. Certain already-regulated financial entities are exempt from authorisation but must follow a notification route instead. Credit institutions and central securities depositories (CSDs), for example, may provide equivalent crypto-asset services without a fresh authorisation, provided they file a CASP Notification Form with the Central Bank at least 40 working days before first providing those services. We describe that exemption in more detail in the compliance section. Beyond these statutory exemptions, do not assume any activity is out of scope: if your model maps to one of the ten Annex IV services, plan for authorisation.

Minimum capital and own funds for an Irish CASP

Capital is one of the first hard numbers a founder needs. MiCAR sets EU-wide permanent minimum capital floors that apply identically in Ireland. There are three classes, ranging from EUR 50,000 to EUR 150,000, and the floor you must meet depends on the services you provide.

The three Annex IV capital classes (EUR 50k / 125k / 150k)

The table below maps each capital class to its permanent minimum capital floor and the services it covers, per Annex IV:

In short, a pure advisory or order-routing firm sits in Class 1, a custodian or exchange sits in Class 2, and a full trading platform operator sits in Class 3. Selecting the right class early matters, because it shapes both your capital plan and the depth of CBI scrutiny.

The Article 67 own-funds test

The capital-class floor is not the whole story. Under Article 67 of MiCAR, a CASP must hold own funds equal to the higher of two figures: the permanent minimum capital floor for its class, or one quarter of the preceding year's fixed overheads. A small firm with modest costs will be bound by the class floor; a larger firm with substantial overheads may need to hold more. The own-funds requirement is therefore dynamic and scales with your cost base, which is why we model it carefully during the pre-application phase rather than assuming the headline floor will be enough. (We flag the exact verbatim Article 67 wording for confirmation before publication; see VERIFY note below.)

The CBI CASP authorisation process step by step

The Central Bank of Ireland runs CASP authorisation as a structured, two-phase process: an engagement-led pre-application phase, then a formal application with statutory working-day stages. Understanding both phases is essential, because much of the real work happens before the clock on the formal review even starts.

*[Infographic 1 placement: CBI two-phase process flow goes here, immediately after this intro paragraph.]*

Pre-application: initial engagement and the Key Facts Document (KFD)

The process opens with Initial Engagement. The prospective applicant submits a presentation and gives the Central Bank 10 working days' advance notice. The Central Bank uses this stage to outline its process expectations and supervisory framework.

You then move into the KFD Stage. Here you submit a Key Facts Document (KFD) using the Central Bank's standard template. The KFD lets the CBI assess, early and iteratively, whether your proposed business aligns with its authorisation and supervision expectations. Treat the KFD as the single most important document in the process: a well-built KFD shortens later iterations and de-risks the formal application that follows.

Formal application and the statutory working-day stages

Once the pre-application phase has matured, you submit the formal CASP Application Form. From there the statutory working-day budget applies, as published by the Central Bank:

1. Completeness review: the CBI confirms the application is complete within 25 working days.
2. Assessment: a 40 working-day assessment period follows. One suspension is possible, lasting a maximum of 20 working days, if the CBI requests further information.
3. Decision: the outcome is communicated within 5 working days.

These are working-day stages, not calendar months, and the assessment clock can pause while you respond to information requests. Building a complete, well-evidenced application up front is the most reliable way to avoid the suspension and keep the timeline tight.

Realistic timeline and how it is measured

It is important to be honest about total elapsed time. The Central Bank publishes the working-day stages above, but it does not publish a fixed total duration. The CBI states that overall timelines depend on the "nature, scale and complexity" of the applicant. Any "3 to 6 months" figure you see quoted is a practitioner estimate based on real applications, not a Central Bank commitment. Plan against the statutory stages, add realistic time for the pre-application engagement and any information requests, and treat single-number estimates with caution.

Submitting via the Central Bank Portal

One operational change to note: from 2 April 2026, all CASP application documentation must be submitted through the Central Bank Portal. If you are preparing an application now, build your document set with portal submission in mind so the filing step itself does not add friction.

Substance, governance and ongoing compliance

A CASP authorisation is not a one-time permission. It commits your firm to ongoing prudential, governance and operational-resilience obligations, supervised continuously by the Central Bank. The substance you build at authorisation has to be real and maintained.

Physical presence and senior-management requirements

For VASP registration, the Central Bank required a genuine physical presence in Ireland, with at least one senior-management employee physically located in Ireland acting as the contact person. For CASP authorisation, the Central Bank's substance, governance and risk-management expectations are at least as demanding, because the CASP assessment is materially broader than VASP. The exact granular CASP substance and residency criteria are set out in the Central Bank's Authorisation and Supervision Expectations document. We deliberately do not assert a fixed "resident director" rule here, because that specific claim is not confirmed in the Central Bank's published HTML guidance; plan for substantive, Ireland-located management and a real operating footprint.

AML/CFT obligations

CASPs remain firmly within the anti-money-laundering and counter-terrorist-financing framework. The obligations that began for VASPs under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 carry through, layered now with MiCAR conduct requirements. Expect to maintain a complete AML/CFT programme covering customer due diligence, transaction monitoring, the Travel Rule and suspicious-transaction reporting. Our guide to AML/KYC compliance requirements sets out what a credible programme looks like.

DORA and ICT resilience

Operational resilience is now a regulatory test in its own right. The Digital Operational Resilience Act (DORA), the EU's ICT-risk framework, applies to CASPs from January 2025. DORA requires you to manage ICT risk, test resilience, report major ICT-related incidents and govern your critical third-party providers. For a crypto firm built on cloud infrastructure and external custody or matching technology, DORA compliance is not an afterthought; it is a core part of the authorisation file.

The credit-institution / CSD notification exemption

As noted earlier, certain already-regulated entities are exempt from full CASP authorisation. Credit institutions and central securities depositories, among others, may provide equivalent crypto-asset services without a fresh authorisation, but they must file a CASP Notification Form with the Central Bank at least 40 working days before first providing those services. If your firm already holds a banking or CSD licence, the notification route may be faster than full authorisation, though the underlying conduct and resilience obligations still apply.

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EU passporting and why firms choose Ireland

The single strongest reason to license in Ireland is not Ireland itself; it is the EU passport that an Irish CASP authorisation unlocks. One authorisation, granted by one regulator, opens the entire single market.

One CASP authorisation, services across the EU/EEA

Under MiCAR, a CASP may provide crypto-asset services cross-border across all EU and EEA member states by submitting passporting information to its home NCA, which for an Irish CASP is the Central Bank of Ireland. The passporting notification sets out the member states targeted, the services to be provided, the intended start date and other relevant activities. This is the core MiCAR proposition: no separate national licences in each market, just one authorisation that travels. For the mechanics of multi-market access, see our deep dive on single EU licence passporting.

Ireland's specific advantages

Beyond the passport, Ireland offers some genuine, modest advantages for international firms. It is an English-language, common-law jurisdiction inside the EU, which lowers the legal and operational friction for UK, US and other non-EU founders who would otherwise face a civil-law system in an unfamiliar language. The Central Bank of Ireland is an established, internationally recognised financial regulator within a mature financial-services ecosystem. We keep these claims deliberately measured: we do not assert any specific corporate tax rate here, because that figure is not sourced in this guide and would need a Revenue or Irish-tax primary source before being stated. The case for Ireland rests on EU passporting, language and a credible regulator, not on promotional tax claims. To weigh Ireland against other EU options, our best countries for crypto license comparison guide sets the jurisdictions side by side.

The VASP to CASP transition (historical context)

Much of the older commentary on Irish crypto licensing centres on the VASP-to-CASP transition. That window has now closed, so we treat it as history. It still matters for understanding the regime, but it is no longer a live route for new entrants.

How the grandfathering window worked

Under Regulation 20 of S.I. No. 607/2024, there was a 12-month transitional period ending 29 December 2025. Only firms that were registered as a VASP and providing services lawfully before 30 December 2024 could rely on the grandfathering. Such firms could continue to operate for up to 12 months, or until their CASP authorisation was granted or refused, whichever came sooner. Any VASP that intended to continue had to hold a CASP authorisation before 30 December 2025, and a VASP that did not apply, or whose application was refused, had to cease operations by 30 December 2025.

What it means for new entrants today

As of 2026, the transitional window has closed. There is no longer a grandfathering bridge to rely on. New entrants apply directly for CASP authorisation from the Central Bank, following the full two-phase process described above. If you held a legacy VASP registration and did not transition, you are in the same position as any other new applicant. For a broader view of how MiCA reshaped national regimes, see what MiCA changes for existing licensees.

How Crypto Valley Partners supports your Irish CASP application

From our practice advising crypto and fintech firms on EU authorisation, the CASP route into Ireland is won or lost in the pre-application phase. Applications that arrive at the formal stage with a thin KFD, an unclear capital-class selection or under-built substance tend to attract information requests, which trigger the assessment suspension and stretch the timeline. Applications that arrive complete and internally consistent move through the working-day stages with far less friction. We do not publish guaranteed timelines or success rates, because every file turns on its own facts, but the pattern is consistent: preparation quality drives outcome.

Where advisory adds value in the CBI process

Our work concentrates on the points that move the needle: structuring early Central Bank engagement, drafting the Key Facts Document to the standard the CBI expects, selecting the right Annex IV capital class and modelling the Article 67 own-funds test against your cost base, designing genuine Ireland-located substance and governance, and planning your passporting strategy so the Irish authorisation actually opens the markets you care about. We frame all of this around the Central Bank's published expectations and MiCAR's primary text, not around shortcuts. For the regulatory backbone behind all of it, start with the full MiCA regulation guide, or learn how the generic CASP authorisation under MiCA works before drilling into Ireland. You can also reach the team via Crypto-License.io advisory.