Ireland Crypto Regulation – Builder’s Guide

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A builder-friendly guide to what the Central Bank expects, what MiCA changed, and when you need a licence.

Audience: founders, engineers, product leads building crypto products from Ireland or selling into the EU via an Irish entity.

Scope: Ireland-specific entry points (CBI), plus EU rules that apply in Ireland (MiCA, AML/Travel Rule, payments, securities perimeter).

Not legal advice. Use this to orient your decisions, then validate with qualified counsel and (where relevant) early engagement with the CBI.

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📋 What's Inside

Section	What you will get
1. The map	Who regulates what (CBI vs EU bodies)
2. AML/KYC in Ireland	Baseline obligations and the VASP legacy
3. MiCA in practice	Timeline, CASP licensing, passporting, ongoing obligations
4. Is my token a security?	A practical classification triage (MiCA vs MiFID II)
5. Stablecoins & e-money	ART/EMT, when you drift into EMI territory
6. Payments licensing	PSD2: when a PI/EMI licence is needed
7. Consumer protection & ads	What "clear, fair, not misleading" means in Ireland
8. DeFi, DAOs, RWAs	Grey areas and what to watch
9. Decision guide	Licence vs lawyer vs neither
Resources	Official links, legal primers, and contacts

1️⃣ The Regulatory Map (Ireland + EU)

If you are building in Ireland, the Central Bank of Ireland (CBI) is your main gatekeeper. But most of the rules you will comply with are EU rules that Ireland enforces through the CBI.

CBI's main hats for crypto:

Authoriser and supervisor for crypto-asset service providers (CASPs) under MiCA.
AML/CFT supervisor for virtual asset service providers (VASPs) under Ireland's Criminal Justice (Money Laundering and Terrorist Financing) Acts (2010–2021, as amended).
Payments and e-money regulator for Payment Institutions (PI) and Electronic Money Institutions (EMI) under PSD2 and the e-money regime.
Consumer protection and advertising supervision for regulated financial services in Ireland.

EU bodies you will hear about:

ESMA (markets) – guidance on when crypto-assets are "financial instruments" (securities perimeter).
EBA (banking/payments) – AML/Travel Rule guidance; payments/e-money guidance.
European Commission – writes the core regulations/directives; implements via delegated/implementing acts.

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Builder takeaway: start by deciding which "box" you are in: (A) crypto services under MiCA, (B) payments/e-money, (C) securities/investment services, or (D) a mix.

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2️⃣ AML/KYC in Ireland (the non-negotiable baseline)

Even after MiCA, Ireland's AML layer remains foundational. Historically, crypto firms started with VASP registration with the CBI (AML/CFT only). Under MiCA, many firms move from VASP registration to CASP authorisation, but AML obligations still apply in day-to-day operations.