EU CryptoReg Roundup: April 2026

Welcome to our EU crypto update - a roundup of key Irish and EU legislative and regulatory developments shaping the crypto-asset sector. 

This update is brought to you by our Regulatory & Risk Advisory practice group in Ireland. 

Our aim is to keep you informed of the fast-evolving legal landscape, from new legislation and guidance to significant case law and observations. Sign up here to receive the next update in your inbox.

The "key dates" section highlights key legislative and reporting dates relevant to Irish CASPs. 

Key developments this month include:

• Central Bank of Ireland publishes quarterly CASP return and MiCAR suspicious transaction reporting form.
• ESMA statement on the end of MiCAR transitional periods.
• ECB opinion on the proposed market integration package.
• Final compromise texts for PSD3 and PSR.
• 20th Sanctions package against Russia. 

Legislation and guidance

Ireland

Central Bank CASP updates

April 2026 – The Central Bank of Ireland (Central Bank) has updated its MiCAR webpage to include a suspicious transaction and order report (STOR) form, pursuant to Article 92 of MiCAR.

• Crypto-Asset Service Providers (CASPs) that operate a trading venue and persons professionally arranging or executing transactions, are required to report suspicious orders and transactions to the Central Bank without delay.
• STORs must be submitted to the Central Bank through the Central Bank Portal.

April 2026 – The Central Bank has updated its MiCAR webpage with a 'regulatory reporting' section for CASPs and published its CASP Return Excel form and Guidance Notes. 

• As part of the return, CASPs are required to provide information on number of clients / transactions / crypto-assets, financials, client asset information, outsourcing and custody methods, passporting, etc. 
• CASPs are required to submit the return quarterly to the Central Bank, i.e., within 6 weeks (42 calendar days) of a calendar quarter end; 31 March, 30 June, 30 September, 31 December.
• The CASP return should be submitted via the Central Bank portal, and it must be signed off at executive level within the firm.

Europe

ECB opinion on the proposed market integration package

9 April 2026 – The European Central Bank (ECB) published its opinion on the market integration and supervision package proposed by the European Commission in December 2025.

• The ECB supports the proposed amendments to the European Securities and Markets Authority (ESMA) governance framework, which would make ESMA directly responsible for the supervision of all CASPs.
• The opinion notes that the ECB should be a non-voting member for discussions concerning CASPs, in view of the services CASPs offer in relation to the custody and exchange of e-money tokens (EMTs) and asset-referenced tokens (ARTs).
• The ECB suggests maintaining the MiCAR category of significant CASPs and expanding the existing criteria to include objective metrics of significance. The ECB notes that significant CASPs should be requested to establish an intermediate parent undertaking in the EU and to ensure that they have group-level recovery plans in place, in addition to additional requirements regarding internal controls and enhanced disclosures. The requirement to establish an intermediate parent undertaking in the EU should also be applicable in all cases where a third-country firm controls, in the EU, both a credit institution and a CASP and/or an electronic money institution issuing EMTs or ARTs.
• To address systemic risks posed by CASPs the ECB proposes that technical clarifications should be made to the Commission proposals on prudential requirements for CASPs, including those concerning statutory audit requirements and the introduction of risk sensitive own funds.
• Furthermore, the ECB recommends clarity on the services falling in the perimeter of an ‘offer’ of stablecoins, to avoid fragmentation and avert the risk that some CASPs could straddle the borderline between the provision of non-offer related services and making an offer to the public, particularly in the context of CASPs providing services with respect to non-MiCAR compliant stablecoins.
• The ECB has some concern about the proposed inclusion of CASPs in the DLT pilot regime, noting that CASPs currently operate under a lighter supervisory framework and lower, non-risk-sensitive own funds requirements.
• For more information on the market integration package see our December CryptoReg Update. 

ESMA statement on the end of MiCAR transitional periods 

17 April 2026 – ESMA has published a statement clarifying supervisory expectations ahead of the expiry of the transitional periods under MiCAR on 1 July 2026.

• ESMA confirms that, from this date, any entity providing crypto asset services to EU clients without MiCAR authorisation will be in breach of EU law and must cease operations. 
• Unauthorised CASPs are expected to have in place robust, credible and immediately executable wind down plans, ensuring an orderly exit and minimising detriment to clients, including through the transfer of crypto assets to authorised providers or self hosted wallets. 
• Authorised CASPs are expected to proactively manage the migration and onboarding of clients ahead of the deadline, applying appropriate AML/CFT and onboarding procedures. 
• ESMA reminds market participants that entities established outside the EU are, outside the narrow exception of reverse solicitation, not permitted to provide crypto-asset services that qualify as MiCAR services to EU investors or to solicit EU clients with a view to provide MiCAR services to them.

Final compromise texts for PSD3 and PSR

17 April 2026 – The Council of the EU has published the final compromise texts for the proposed Third Payment Services Directive (PSD3) and Payment Services Regulation (PSR), following agreement reached in trilogue negotiations between the co‑legislators. 

• The package represents a significant reform of the EU payments framework, repealing and replacing PSD2 and EMD2 and moving a large proportion of conduct of business rules into a directly applicable Regulation to ensure greater harmonisation across Member States. 
• Of relevance to the crypto‑asset sector and CASPs providing services in relation to EMTs, the framework acknowledges overlaps with MiCAR and seeks to ensure greater coherence between the two regimes, in light of EMTs being categorised as both crypto-assets under MiCAR and deemed e-money and therefore 'funds' for the purposes of the payments services framework.  
• The Council also published an 'I' Item note in which it recommended that the committee of the permanent representatives of the governments of the Member States to the European Union (COREPER) approve the draft regulation and directive with a view to reaching agreement at second reading with the European Parliament.
  EU adopts 20th sanctions package against Russia

23 April 2026 – The Council of the EU has adopted the 20th package of restrictive measures in response to Russia’s war of aggression against Ukraine, with new measures targeting energy, trade and financial services, including crypto‑assets. 

• The EU is designating a Kyrgyz entity which operates a platform where significant amounts of the government-backed stablecoin A7A5 are traded. 
• Furthermore, the EU is introducing a total sectoral ban on providers and platforms established in Russia that allow the transfer and exchange of crypto assets, including any decentralised platforms enabling crypto trading.
• The EU is also banning transactions in another crypto currency (RUBx) and all EU support for the development of the digital rouble.

Other updates

Ireland

Central Bank Blog on future-proofing Europe's financial system

2 April 2026 – Gabriel Makhlouf, Governor of the Central Bank has published a blog post on the role of digital innovation in the future of EU financial markets. 

• Mr Makhlouf notes that Europe’s next phase of financial integration is digital, with DLT and tokenisation offering efficiency and integration gains. The modernisation of payment and settlement infrastructure is a strategic priority in order to promote innovation and reduce dependency on non-European providers.
• Mr Makhlouf notes that the Central Bank needs to pursue a balanced approach that seeks to align public and private interests. In his view that means preventing central bank money settlement from being displaced by riskier settlement assets on private financial market infrastructures (to avoid exacerbating market fragmentation and any unwelcome indirect societal costs).

Europe

ECB publishes macroprudential bulletin exploring digital finance, tokenisation and DLT

13 April – The ECB has published the 33rd edition of its macroprudential bulletin, consisting of several articles on tokenisation and the future of EU capital markets, including:

• Article 1 - O brave new world, that has such digitalisation in it.
• Article 2 - Tokenised bonds: assessing efficiency and liquidity in a nascent market. 
• Article 3 - Towards an efficient and integrated digital capital market in Europe: the role of tokenisation and the Eurosystem’s policy response.
• Article 4 - Tokenised money market funds: new technology, familiar risks?
• Article 5 - Euro stablecoins and their potential impact on sovereign bond markets.

ECB digital euro updates

15 April 2026 – The ECB has published FAQs on the digital euro pilot.

• The digital euro pilot is a limited practical exercise to help the Eurosystem learn how a digital euro could work in everyday situations. The pilot will help the Eurosystem assess its technical, operational and user readiness for a potential digital euro by validating the infrastructure in real-life conditions and gathering evidence to inform future decisions.
• The operational phase of the pilot will take place during the second half of 2027 and will run for 12 months.

24 April 2026 – The ECB signs agreements with European standard setting organisations (ECPC, nexo standards and the Berlin Group) to support the development of the digital euro and ensure interoperability across the EU payments ecosystem. 

• In particular, the initiative aims to facilitate functionalities such as contactless payments, interoperability of payment systems and the use of alternative identifiers (e.g. mobile phone numbers) to initiate payments.
• The ECB emphasises that early coordination with market participants is a key component of its broader strategy to support efficient adoption, reduce implementation costs and ensure consistency across the euro area payments landscape.

Speeches

1 April 2026 – Piero Cipollone, member of the executive board of the ECB, delivered a public lecture on the digital Euro and the future of European payments infrastructure.

• Mr Cipollone explained that dependence on non-European payment infrastructure has become a strategic vulnerability. Merchants are reliant on a small number of private, non-European payment providers, leaving them vulnerable to the risk of withdrawal of access and susceptible to changes to charges. 
• He highlighted the digital Euro as a public European payment solution ensuring access to central bank money and allowing transactions to be carried out digitally without reliance on non-European providers.
• He also discussed the Pontes and Appia projects as key ECB initiatives in developing the infrastructure for DLT-based wholesale settlements and laying the foundations for a tokenised financial system in Europe.

15 April 2026 – Piero Cipollone delivered a keynote address on tokenisation and the role of central banks.

• Mr Cipollone highlighted how digital technologies, including tokenisation and instant payments, could reduce the cost of finance by simplifying processes, reducing fragmentation and lowering reliance on intermediaries. He emphasised that automation and programmability in financial infrastructure can improve capital allocation and competition, if implemented on a pan‑European and interoperable basis.
• He stressed that these benefits require deliberate public policy choices, with the ECB safeguarding monetary sovereignty, competition and financial stability as digital finance evolves.