EU CryptoReg roundup: September 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 Crypto Asset Service Providers (CASPs). 

Key developments this month include:

• Launch of Pontes.
• CBI guidance on sanctions reporting for CASPs.
• Commission Delegated Regulation on central contact points for CASPs.
• Publication of EBA decision on the MiCA reporting platform.
• ESCB response to the European Commission’s MiCA review consultation.
• ESMA's supervisory priority on digital innovation.
• EBA's 2027 Work Programme.
• ESMA TRV Report No. 2/2026.
• European Parliament briefing on regulating and supervising digital assets.

Legislation and guidance

Ireland

CBI Guidance on sanctions reporting for CASPs

26 September 2026 – The Central Bank of Ireland (CBI) wrote to CASPs' Heads of AML clarifying reporting obligations under Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine, particularly the transaction bans relevant to CASPs in Articles 5ad, 5ba and 5bb of the Regulation. 
Following engagement with the European Commission, the CBI confirmed that where a CASP cannot technically refuse an incoming transaction from an entity subject to the transaction ban, it should hold the assets rather than return them, as returning them would breach the Regulation. Breaches or potential circumvention must be reported to the CBI via the Financial Sanctions Return (FSR) on the CBI Portal, and separately to An Garda Síochána. The CBI set out interim instructions for completing the FSR and noted that it is developing an updated FSR form for CASPs.

Europe

European Commission Delegated Regulation on Central Contact Points for CASPs

8 September 2026 – The European Commission adopted a Delegated Regulation (Document C(2026) 6179 final) amending the regulatory technical standards in Delegated Regulation (EU) 2018/1108 with regulatory technical standards on the criteria for the appointment of central contact points for electronic money issuers and payment service providers and with rules on their functions to extend the criteria for the appointment of central contact points, and the rules on their functions, to CASPs. The amendments retain the existing approach applied to electronic money issuers and payment service providers and introduce specific criteria for determining when host Member States may require CASPs to appoint a central contact point to ensure compliance with local AML/CFT rules. The draft standards were developed by the European Banking Authority (EBA) following a public consultation that closed on 4 February 2025. The Delegated Regulation will enter into force 20 days after its publication in the Official Journal but has not yet been published. 

EBA Decision on the MiCA Reporting Platform 

17 September 2026 – On 17 September 2026, EBA published its decision (EBA/DC/579 of 16 May 2025) on the Markets in Crypto-Assets Regulation (MiCA) reporting platform. The decision concerns the MiCA requirements on data exchanges between authorities. Articles 22 and 43 of MiCA specify that the reported data is to be shared by the competent authorities with the European Banking Authority (EBA), the European Central Bank (ECB), the host competent authorities and the national central banks where applicable. The technical reporting platform built on EBA's European Centralised Infrastructure for Supervisory Data (EUCLID) for reporting and exchanging data on asset-referenced tokens (ARTs) and e-money tokens (EMTs) between issuers, national competent authorities and the EBA. The decision sets out submission, onboarding, data-quality and dissemination requirements, requires prompt correction of errors, and took effect immediately. The reporting platform's functions and operational procedures will be set out separately. 

Other updates

Europe

EBA publishes its 2027 Work Programme

30 September 2026 – EBA published its Work Programme setting out its key areas of focus and deliverables for 2027. The programme incorporates EBA’s new responsibilities, including as supervisor of significant issuers of crypto-asset tokens under MiCA, and notes that rapid innovation, including in crypto-assets and tokenisation, is reshaping banking and payments. The EBA will continue to foster the effective functioning of the Single Market for banking, payment services and crypto-assets.

In terms of legislative updates, EBA notes its ongoing technical input to EU initiatives in digital finance (i.e. Digital Euro), DORA, the MiCA review and the response to the European Systemic Risk Board's Recommendation on third-country multi-issuer stablecoin schemes. Additionally, EBA expects to publish guidelines on financial inclusion and the Digital Euro Act in Q4 2026. The forthcoming Digital Euro Act is expected to create EBA mandates relating to financial inclusion and the use of the digital euro, with EBA guidelines planned as part of the implementing framework.

ESMA calls for changes to make MiCA clearer, safer and ready for emerging services

30 September 2026 – The European Securities and Markets Authority (ESMA) responded to the European Commission's public consultation on the review of MiCA, with recommendations aimed at simplifying the framework while improving investor protection and addressing innovative  and evolving business models including Decentralized Finance (DeFi), staking, lending and borrowing. ESMA proposes stricter rules on the marketing of crypto-assets, including online marketing by influencers, greater cost transparency and proportionate requirements for staking, crypto lending and borrowing. It also recommends stronger supervisory powers to tackle unauthorised third-country firms, online fraud and non-compliant stablecoins, clearer criteria for determining which activities are genuinely decentralised, a new regulated crypto-asset service for access to DeFi protocols, and the power for ESMA to issue binding opinions on token classification. In summary, ESMA proposes: 

• New regulated services for CASPs acting as gateways to DeFi;
• Reinforced supervisory powers and empowerment to issue binding opinions on token classification;
• Streamlined white paper notification procedures, simplified authorisation requirements for transfer services, and greater alignment of prudential requirements with other regulatory frameworks;
• Targeted requirements for staking, lending, and borrowing services;
• Enhanced investor protection measures such as marketing practice restrictions and cost transparency; and
• Stricter rules against the provision of CASP services in respect of unauthorised stablecoins.

ESMA considers it disproportionate that an investment firm using the Article 60 MiCA notification procedure to provide crypto-asset services equivalent to investment services for which it is already authorised under Directive 2014/65/EU on markets in financial instruments (MiFID II) may still need to obtain a separate CASP authorisation for an intrinsically linked transfer service. ESMA therefore proposes amending MiCA to clarify that an investment firm may use the Article 60 notification procedure to provide a transfer service that is intrinsically linked to a crypto-asset service equivalent to an investment service already covered by its MiFID II authorisation. 

Eurosystem Call for Expressions of Interest in New Wave of Digital Euro Innovation Activities

28 September 2026 – The Eurosystem invited private companies and organisations in a call for expression of interest to collaborate in digital euro activities, building on its existing innovation platform, launched in 2024, and exploring how the digital euro could support market innovation. Participants will be asked to engage in two workstreams: experimentation - supporting the development of practical features and services to improve the digital euro user experience, and exploration - assessing technologies that could enhance future releases. 

EBA identifies priorities for the review of MiCA

24 September 2026 – The EBA published its response to the European Commission’s targeted consultation on the review of MiCA. The EBA considers the existing requirements for issuers of ARTs and EMTs broadly appropriate but recommends strengthening the framework to address the risks posed by third-country multi-issuer stablecoin schemes and reviewing issuers’ reserve requirements. EBA also calls for clarification of the scope of, and definitions in, MiCA to support consistent classification of crypto-assets, and encourages the Commission to consider regulating crypto-asset lending, including where CASPs facilitate access to decentralised finance lending protocols. As of 1 September 2026, 39 EMTs had been issued under MiCA, and no ARTs had been authorised. The EBA highlights difficulties in classifying a range of tokens under existing rules, including hybrid, wrapped and commodities-linked tokens, amongst other things. 

ESMA sets new Supervisory Priority on Digital Innovation from 2027

23 September 2026 – ESMA announced its new Union Strategic Supervisory Priority (USSP) on digital innovation, initially focusing on the use of artificial intelligence and tokenisation by supervised entities while maintaining investor protection and effective oversight. The USSP will operate alongside the existing focus on cyber and operational resilience in place since 2025.

ESCB responds to European Commission's consultation on MiCA review

22 September 2026 – The ECB published the European System of Central Banks (ESCB) response to the European Commission’s targeted consultation on MiCA. The response sets some key messages on the MiCA review, requirements applicable to ARTs and EMTs, the adequacy of the current legal framework, multi-function groups and other topics beyond the initial scope of MiCA, such as DeFi, staking and lending, and tokenised deposits. In its response, ESCB considers that the prohibition on stablecoin remuneration should continue, and that transferring supervisory powers to ESMA would help ensure supervisory convergence, reduce fragmentation and mitigate cross-border risks. The response also proposes replacing the fixed bank-deposit quota for stablecoin reserves with one-day and five-day liquidity buckets, and addresses group-level oversight of significant CASPs, crypto-specific operational resilience and the private-law treatment of tokens.

Eurosystem launches Pontes

21 September 2026 – The Eurosystem launched Pontes. Pontes is a solution enabling wholesale transactions in tokenised assets to be settled in central bank money.  The Eurosystem comprises the ECB and the national central banks of the Member States whose currency is the euro, as the monetary authority of the euro area. The launch marks the first step in implementing the Eurosystem’s strategy for tokenised finance, with banks and market infrastructures to join gradually and further enhancements to be introduced over the next two years.

ECB Press Release on settlements via Pontes

21 September 2026 – The ECB has published a press release announcing plans to invest in tokenised securities with settlement via Pontes. At this stage, the ECB has launched preparatory work to invest a small portion of its own funds in tokenised securities. This move will enable the ECB to gain practical experience and institutional expertise in the use of distributed ledger technology (DLT), ensuring that central bank money remains fit for the digital age.

ESMA publishes TRV Report

10 September 2026 – ESMA published its second 2026 Trends, Risks and Vulnerabilities (TRV) Risk Monitor for the period from 31 December 2025 to 30 June 2026. The report provides a comprehensive overview of developments across EU financial markets. The report provides a risk outlook and examines key risk indicators and drivers. With regard to the securities markets and crypto assets, ESMA notes that elevated macro uncertainty, falling crypto prices and broader risk-off sentiment brought the growth of the stablecoin market to a halt, with outstanding supply stabilising at around EUR 275 billion following exceptional growth in 2025. The stablecoin market remains highly concentrated, with Tether’s USDT and Circle’s USDC accounting for 82% of total stablecoin value.

European Parliament Briefing on Regulating and supervising digital assets: where does control lie?

8 September 2026 – The European Parliament published a briefing examining whether regulators and supervisors can identify where control, risk and responsibility lie in increasingly complex digital-asset arrangements. The briefing proposes assessing the instrument, protocol and access layers separately, focusing on factors such as practical control, transparency, jurisdictional reach and the ability to mitigate risk rather than broadly classifying arrangements as centralised or decentralised.

Speeches

23 September 2026 – Piero Cipollone, Member of the ECB’s Executive Board, delivered a presentation titled 'The digitalisation of money, payments and finance', outlining the Eurosystem’s payments strategy, including the digital euro and tokenised central bank money through Pontes and Appia. He noted that the digital euro pilot will run for 12 months from the second half of 2027 and that the ECB aims to be ready for a potential first issuance during 2029, subject to adoption of the digital euro Regulation.

Key dates

CASPs – Ireland

2026

Quarterly

Central Bank CA SP Return.

To be submitted via the Central Bank Portal within 6 weeks of calendar quarter end.

1 January 2026 - The reporting periods under the OECD's Crypto-Asset Reporting Framework ("CARF") and the update to the Common Reporting Standard ("CRS 2.0") as well as DAC8 commence in Ireland, with entities in scope expected to collect relevant information from 1 January 2026.

First CARF/DAC8 reporting due by 31 May 2027 and first CRS 2.0 reporting due by 30 June 2027.

10 February 2026 - New PCF-57, Head of Safeguarding, introduced.

Persons proposed for the PCF-57 role must submit a PCF application. Where the firm has identified an individual who is deemed to be already performing the PCF-57 role prior to 10 February 2026, the Central Bank in-situ process applies.

1 March 2026 - Transition period under the EBA No Action letter on the interplay between PSD2 and MICAR ends.

24 March 2026 - Revised Central Bank Consumer Protection Code (incorporating Business Standards Regulations) takes effect.

2 – 31 March 2026 - The Central Bank Portal window is open for DORA Register of Information submission.

2 April 2026 - Commencement of the Central Bank Portal for CASP authorisation application submissions.

28 July 2026 - ESMA Guidelines for the criteria on the assessment of knowledge and competence under MICAR start to apply.

Central Bank Minimum Competency Code will apply to persons giving information or providing advice on crypto-assets or crypto-asset services as defined in Article 3(1)(16) of MICAR.

31 July 2026 - Central Bank CASP AML REQ return due.

31 December 2026 - CASPs subject to CARF/DAC8 are required to register with the Irish Revenue by 31 December 2026.

2027

March 2027 - Central Bank CASP AML REQ return due.

10 July 2027 - Application of the new AML / CFT legislative framework under the EU Single AML Rulebook.

31 December 2027 - CASPs operating a trading platform shall ensure by 31 December 2027 that white papers, as required by MICAR, in notified and published for crypto-assets that were admitted to trading before 30 December 2024.