Ireland Central Bank Opens DLT and Tokenisation Consultation, March 2026

On 5 March 2026, the Central Bank of Ireland published Discussion Paper 12 (DP12) on Distributed Ledger Technology (DLT) and Tokenisation in Financial Services. The consultation is open and the deadline for responses is 5 June 2026. DP12 is not a rule or binding guidance; it is a public consultation through which the Central Bank seeks views on how DLT and tokenisation affect regulated financial services activities in Ireland and how the existing regulatory perimeter should respond.

The Central Bank exercises its authority to consult under the Central Bank Act 1942 (as amended) and the broader mandate conferred by European financial services legislation transposed into Irish law. DP12 raises questions under seven thematic areas, covering: the use of DLT in settlement and clearing; tokenisation of real-world assets by regulated firms; the treatment of smart contracts within existing licensing conditions; custody of tokenised instruments; investor protection considerations; cross-border activity involving DLT infrastructure; and interoperability with EU-level initiatives including MiCA, the DLT Pilot Regime under Regulation (EU) 2022/858, and the proposed EU digital euro framework.

For regulated firms operating or planning DLT-based services in Ireland, DP12 signals that the Central Bank is assessing whether current licensing categories adequately cover tokenised asset issuance, DLT-based trading, and custody functions. Firms should treat this as an early indicator that specific authorisation requirements or guidance conditions may follow. Responses to DP12 feed directly into the Central Bank's position on any future rule changes, making participation in the consultation a practical tool for shaping proportionate regulation. Asset managers, payment institutions, credit institutions, and investment firms holding or handling tokenised instruments should review the seven question areas and assess which apply to their current or planned activities.

DP12 does not pre-commit the Central Bank to any regulatory outcome. The paper explicitly states that no decision has been taken on whether existing rules require amendment. However, question 6 of DP12 specifically asks respondents whether current Central Bank codes of conduct apply appropriately to DLT-based service delivery, and question 7 asks whether a dedicated regulatory sandbox or innovation office function would be warranted. Responses are due by 5 June 2026. The Central Bank has not announced a timeline for publishing a feedback statement.

Our firm advises regulated financial institutions, fund managers, and fintech operators on DLT regulatory strategy, Central Bank of Ireland authorisation matters, and MiCA compliance. We maintain a partnership network with Irish-qualified counsel for matters requiring local regulatory representation before the Central Bank. We are available to assist with DP12 response drafting, regulatory mapping of DLT activities, and pre-authorisation planning. Areas of work include DLT Pilot Regime applications, tokenised asset structuring, MiCA Article 70 custody compliance, investment firm authorisation, payment institution licensing, and smart contract regulatory analysis.

Source: Central Bank of Ireland, Discussion Paper 12 – Distributed Ledger Technology (DLT) & Tokenisation in Financial Services, DP12, 05/03/2026, https://www.centralbank.ie/publication/discussion-papers/discussion-paper-detail/discussion-paper-12-dlt-tokenisation-in-financial-services (confirmed 27 March 2026).

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.