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28 May 2024

The EU Markets in Crypto-Assets Regulation (MiCAR) represents a sea change in the regulation of Crypto-Asset Service Providers (CASPs) in the EU. The introduction of authorisation requirements for Crypto-Asset Service Providers (CASPs) from 1 January 2025 will bring CASPs fully within the regulatory perimeter. This will create a number of challenges for new and existing CASPs in terms of compliance, governance and supervision by the Central Bank of Ireland.

For existing CASPs the increase in regulatory scrutiny, requirements and expectations is likely to give rise to many questions. These requirements derive not only from MiCAR, but from the broader set of regulatory requirements applicable to all regulated entities in Ireland. CASPs can therefore learn from the regulatory and supervisory experiences of existing operators in other financial services sectors, such as investment firms and payment service providers.

Key areas of focus for CASPs in preparation for authorisation and supervision are likely to include:

In this article, our Financial Regulation team examines the potential impact of these requirements for new and existing CASPs with a view to getting ready for authorisation and supervision by the Central Bank. This may require CASPs to examine their existing policies, procedures, systems and controls, as well as their internal governance, in the short to medium term. This should ensure that their engagement with the Central Bank as part of the authorisation process proceeds as smoothly as possible, and meets all legal and regulatory requirements and expectations. 

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Regulation for Crypto-Asset Service Providers

How KPMG can help

KPMG has significant experience assisting regulated firms with all stages in a firm’s lifecycle, from initial business planning, through authorisation and beyond.

Our multi-disciplinary teams including consultants, accountants, and lawyers allows us to provide unparalleled service through a single provider.

We can assist with reviewing existing governance and processes against regulatory expectations and requirements, and can assist with both the authorisation application, as well as the implementation of policies, procedures and operational matters, to effectively navigate the authorisation process with the Central Bank.

If you have any queries related to the any aspects of MiCAR or other regulatory requirements or expectations, please do not hesitate to contact our team below. We would be delighted to hear from you.

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