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| Dimension |
Pinned 🇮🇪 Ireland partly open Verified 2026-10-01
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🇬🇧 United Kingdom
Free in full
Verified 2026-10-01
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|---|---|---|
| Licence type | MiCA CASP authorisation granted by the Central Bank of Ireland; replaces the legacy VASP registration (CJA 2010, AML). No simplified VASP->CASP conversion - all applicants face the full process. | Today, FCA registration under the Money Laundering Regulations 2017 remains the AML and counter-terrorist financing route. Applications for full FSMA authorisation under SI 2026/102 opened on 30 September 2026 and close on 28 February 2027. The mandatory regime commences on 25 October 2027, and existing registrations and permissions do not convert automatically. |
| Regulator | Central Bank of Ireland (CBI) - sole competent authority; runs an Innovation Hub. Known as a demanding, gatekeeper-style regulator. | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | Ireland capital requirement is included in the £349 pass. | No minimum initial capital under the current MLR registration. The incoming FSMA regime's final prudential rules (PS26/12, 30 Jun 2026) set Permanent Minimum Requirements by activity: GBP 75,000 (arranging/dealing as agent), 150,000 (custody, trading platform, staking), 350,000 (stablecoin issuance), 750,000 (dealing as principal). |
| Timeline to authorisation | Ireland timeline to authorisation is included in the £349 pass. | MLR registration: 3-month statutory clock from a COMPLETE application, but realistically ~9-12 months including pre-application; historically low approval rate. |
| Local substance | Ireland local substance is included in the £349 pass. | Business must be carried on in the UK (UK entity in practice); an MLRO / nominated officer (Reg 21(3)) who is UK-based, genuinely competent, independent and closely involved. |
| Application cost | Ireland application cost is included in the £349 pass. | FCA application fee GBP 11,260 (Category 6, fee-block G23, non-refundable) plus typically GBP 50k-150k in professional fees; ~GBP 90k all-in representative (~EUR 105k at 1.16). |
| Ongoing cost | Ireland ongoing cost is included in the £349 pass. | Annual FCA periodic fee under fee-block G.30 for 2026/27: minimum GBP 2,251 plus GBP 6.01 per GBP 1,000 of cryptoasset income above GBP 100,000. Plus AML operations, annual audit and compliance headcount; costs rise materially under the incoming FSMA regime. |
| Passporting | Ireland passporting is included in the £349 pass. | No - post-Brexit the UK regime is standalone; no EU/EEA passport and no MiCA equivalence in either direction. |
| MiCA CASPs approved | Ireland mica casps approved is included in the £349 pass. | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. |
| Key restrictions | Ireland key restrictions is included in the £349 pass. | Cryptoasset financial promotions regime (since 8 Oct 2023): mandatory risk warnings, 24-hour cooling-off for first-timers, ban on incentives; plus significant bank de-risking / de-banking of crypto firms. |
| Recent changes | Transitional period ended 30 Dec 2025 (12 months; simplified route declined). ~10 CASPs authorised by late 2025 (Kraken Jun 2025, Coinbase, StoneX 10th). Revised Consumer Protection Code from 24 Mar 2026. | The FCA authorisation gateway opened on 30 September 2026. Firms can now apply for authorisation or vary existing permissions through Connect, and firms seeking the transitional arrangements must apply by 28 February 2027. The mandatory FSMA regime begins on 25 October 2027. The FCA also published final cryptoasset perimeter guidance, PS26/18, on 16 September 2026. |
| Difficulty rating | Ireland difficulty rating is included in the £349 pass. | 4 - rigorous AML bar, historically low approval rate and severe bank-access friction; the incoming FSMA prudential/conduct regime raises the bar further. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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