I am delighted to speak to you all this morning and many thanks to Mary for inviting me here today.1As my first speech in my new role as Deputy Governor, Financial Regulation, I wanted to:Share some perspectives on regulation and supervision, in particular in the context of the increasingly challenging environment which both regulators and industry are operating in.Set out what risk-based supervision means for me, and why and how we are moving to a new supervisory approach. Discuss our approach to the “simplification” agenda in the area of Financial Regulation, as Europe looks to improve its competitiveness and prosperity for the future.But first I would like to touch on the challenging macro-economic backdrop and risk landscape facing the financial sector.Backdrop – volatility and uncertainty, shocks and shiftsCentral banks, regulators, market participants and economists have all been speaking about heightened volatility, uncertainty and rapid change for a number of years now.Looking back on the last decade two things strike me. One: how true these pronouncements were. And two: that rather than abating, such uncertainty and change feels like it is accelerating, given the pace of change – political, economic, digital and environmental – underway.When King and Kay popularised the term “radical uncertainty” in early 2020,2 even they were unlikely to have foreseen how radical it would quickly become. And not just the global pandemic, and the return of war to Europe; but also the potentially significant geo-political shifts and geo-economic fragmentation that has emerged in the last few years – not to mention the potentially “radical” and indeed rapid technological transformation underway.The last few months alone have seen an acceleration in these structural shifts – leading many to cite the maxim, often attributed to Lenin, that “there are decades where nothing happens; and weeks where decades happen.” Wise words. Though I can’t remember a decade in my professional life where nothing happened; and I have already lived through too many decade-long weeks to last a few lifetimes!This period of profound change, and the increasingly fast-changing, uncertain and volatile world we are living through, informed our Regulatory and Supervisory Outlook which we published last month.3The RSO set out our view of the current risk landscape – shaped by a complex interplay of forces – and our corresponding priorities and expectations for the period ahead.While recognising the resilience built and demonstrated by the financial sector in recent years, the backdrop, outlook and uncertainty we are facing firmly leaves no room for complacency. Quite the opposite.In many ways we are transitioning to a structurally different world. This will provide opportunities and risks. But given the pace of change and the extent of potential fragmentation, firms and regulators need to be prepared for short term shocks as well as long term shifts, for novel as well as traditional risks, and for resilience – both financial and non-financial – to be tested in different ways.Regulation and Supervision – the whySo, this is the backdrop against which we are operating. And as I have been told by colleagues, and indeed some of my predecessors, I am taking up this important role at an important time. Luckily I do so leading and supported by an excellent team of regulatory and supervisory experts, dedicated to delivering in the public interest.But stepping back a bit, before I share my own perspectives on Regulation and Supervision, I want to address the question of why does financial regulation matter – for sometimes in the debate about the regulator and the regulations, we forget.Well, I don’t need to tell you that a well-functioning financial system is an integral part of a well-functioning economy, and plays a key role in the financial wellbeing of our citizens, our businesses and our country.Financial regulation in turn plays a crucial role in ensuring the financial system properly functions, and is delivering in the best interests of consumers and the wider economy.Financial regulation enables activity; it provides certainty and stability; and it delivers trust, which underpins the very concept of money itself. Through regulation and supervision we protect consumers, the system and the economy. We enable better outcomes for society, ensuring the system works in good times and bad – something that is in the interest of us all.Regulating and supervising well naturally has some costs, but in our view those costs are outweighed by  benefits. The costs of a financial crisis – in terms of costs to the State, the economic costs of the disruption, and the long tail of costs on households and businesses – are well understood, and dwarf the cost and burden of many 100s of years’ worth of regulation and supervision.4But the fact that the benefits of regulation and supervision outweigh the costs overall, does not mean that all regulation and supervision delivers more benefits than costs. Rules and requirements and supervisory interventions do need to be consistently considered and re-considered, in terms of costs vs benefits.Delivering regulation and supervision in a way that ensures the benefits are greater than the costs is not just the responsibility of good regulators, but is also in line with our mission of ensuring the financial system operates in the best interests of consumers and the wider economy, and indeed our mandate, which we must deliver in a way that is consistent with the proper and orderly functioning of financial markets. Risk based supervision in a radically uncertain worldRisk based supervision was introduced by the Central Bank in 2011, as part of our response to the lessons of the financial crisis. It allows us to get the most out of our finite resources, deploying them in a manner that will achieve the best outcomes and to the areas that pose the greatest risks.As former Deputy Governor Matthew Elderfield said at the time – “to make good use of our budget, we need to target the energy and expertise of our supervisors to where they will make the greatest difference… allocating scarce supervisory resources accordingly."5Risk based supervision is therefore not about eliminating all risks. The Central Bank does not operate a no-failures regime – this would not be cost effective, and would not deliver the best outcomes for society. The financial systems’ job is to take and manage risks; and in a properly functioning market firms will fail. As such we work to ensure firms are effectively managing their risks, and that impacts on consumers and the wider economy are minimised should risks crystallise.So what makes a good risk based supervisor?Risk-based supervision should – by definition – focus on the most material risks, what matters most. It should involve using data, judgement, insight, and challenge.It does not mean adopting a defensive or reactive strategy focused on risk elimination or preventing negative things from happening. On the contrary, supervisors must be comfortable accepting risk, as they make risk based decisions all the time.6 It means adopting a proactive and forward-looking approach – setting clear objectives and identifying and responding in a timely way to the risks that could prevent the achievement of those objectives. Risk based supervision should focus on remediating issues and delivering positive outcomes – underpinned by our full supervisory toolkit, up to and including the credible threat of enforcement. For this reason, in addition to being risk-based our supervisory principles include being:Outcomes Focused:  With clear communication of the outcomes we want to see and the timelines in which we expect them to be achieved – if necessary using our regulatory and supervisory powers proportionately to achieve these outcomes.Forward Looking: We take a longer-term view, anticipating the impact of current trends and emerging risks in a national and international context, so that we are better positioned to respond quickly and effectively;Judgement Led: Recognising of course, in an uncertain world we are always “looking through a glass, darkly”, our approach to supervision uses data, analysis and information we receive in the course of our activities and is informed by our professional judgement.And Firm Responsibilities – where responsibility for risk identification, management and mitigation rests first and foremost with the boards and management teams of firms themselves.Since we introduced risk-based supervision nearly a decade and a half ago many things have changed – though our risk-based approach has not.  Our regulatory responsibilities, and the sectors we supervise, have evolved significantly, however. This is particularly true in recent years, given the rapid change the financial sector has undergone, to become bigger, more complex, more interconnected and more digital.Innovation, digitalisation, and an increasingly interconnected risk landscape, are reshaping the risk environment of the sectors we supervise and the consumers we work to protect. When our responsibilities, the sector, and the risk context change, we need to change too – to ensure we continue to deliver on our mandate now and into the future.We recognised this in our strategy, and responded through the development of a new supervisory approach, guided by the desire to deliver an effective approach to supervision, which “remembers the lessons of the past, anticipates future risks, and seeks to continuously improve."7Our new approach builds on the strong foundations of our existing risk-based approach to supervision, incorporates our European and international supervisory responsibilities, and the domestic and European regulatory framework in which we operate. The approach does not change the safeguarding outcomes we are pursuing. Rather it recognises the changing nature of the financial system – which increasingly transcends traditional regulatory distinctions such as ‘prudential’, ‘conduct’, and ‘anti money laundering’.Recognising this we have moved to a more integrated approach to supervision, enabling our multi-disciplinary teams to better work together to deliver our supervisory priorities in a more effective and efficient way. This latter point is key – and essential to responding to the changing risk context facing the sector and its consumers.The inter-related and often interdependent nature of our four safeguarding outcomes – which are: safety and soundness of firms, consumer and investor protection, financial integrity and financial stability – requires an integrated approach.  And to maintain resilience and ensure consumers of financial services are protected in this changing and increasingly complex environment, our approach needs to be more agile, data-led and scalable.Through integration we will harness the variety of skills, expertise and experience of the supervisors and teams  across our broad mandate; and we will be more effective and efficient in our supervisory communications and interventions – speaking to you with one voice and dealing with risks in a more holistic way.This new approach is essential to ensuring we can continue to deliver our important role regulating and supervising the financial sector in the public’s interest. This was the case when we embarked on transforming regulation and supervision in the Central Bank a number of years ago. The intervening years, and indeed the last few months, have only served to strengthen this case – ensuring we have the risk-based supervisory approach we need for a radically uncertain world.Simplification – simpler standards, same outcomesHaving set out the challenging external backdrop, and the importance of regulation and supervision in the face of that backdrop, I would like to turn to a key topic on our collective agenda – namely “simplification”.As Europe looks to ensure its economy is productive and competitive into the future, there has been a lot of focus on the simplification of regulation, including financial regulation. While regulation is only one of many aspects of the necessary response to Europe’s economic and productivity challenges, for the people in this room it is an important one. From a financial regulation point of view, simplification is an agenda the Central Bank of Ireland welcomes.Precisely because financial regulation is so important, it is so important to get right. This means that Regulators should always be open to reviewing and considering existing frameworks, and seeing if we can deliver the same outcomes in different, and indeed “simpler”, ways. Indeed, sometimes simpler may actually be better, in terms of delivering what we are seeking to achieve.  Simpler standards should not, however, mean lower standards – and it should go without saying that simpler standards need to deliver the same outcomes.  The simplification agenda, done well, can deliver that. And so the Central Bank will proactively engage with these efforts, not least as simplifying our frameworks and processes is consistent with our current approach of regulating and supervising for outcomes, and indeed the six principles of regulation we have previously set out8 and our new supervisory approach.Done badly, however, the simplification agenda will – put simply – deliver more costs than benefits. And so it is important to call out the risks should the legitimate aims of simplifying our frameworks go too far – and indeed it is very much our responsibility to do so. For the financial sector plays too important a role in the economy and the financial well-being of our citizens for us to jeopardise long term stability in pursuit of short term growth.In that regard, regulators should be firm that we cannot sacrifice resilience on the altar of efficiency. The standards cannot become so simple that they do not address complex risks. And the burden cannot be alleviated to the detriment of important information regulators and the market need to do their jobs.Equally, simplification cannot mean no new rules – for the framework must evolve alongside the financial system, if it is to remain fit for purpose and not introduce undue risks.None of this is to say there aren’t areas where we can simplify requirements, obligations and approaches. Indeed there are.  We know that not all criticism is wrong. Humility is one of our core values, and therefore it is important for regulators to be humble and open – regularly ensuring our regulatory frameworks are up to date, proportionate, and meet their intended outcomes.9In this regard, we have already identified and indeed implemented areas where we could simplify and reduce the burden. This includes:Authorisation – whereas part of our ongoing commitment to efficiency and in the face of feedback that we could improve our clarity and responsiveness to incoming applications, we have increased engagement and significantly improved our processes10  and this work continues.   Fitness & Probity – as part of the implementation of the Enria review we have already or will introduce a number of changes, including the establishment of a Fitness and Probity unit and improving our processes. We will shortly consult on enhancing the clarity of our expectations (by consolidating our guidance) as well as a simplification of the PCF list – as an initial step ahead of a more substantial review.Operational resilience – whereby in implementing DORA, aspects of reporting requirements that risked duplication or overlap with the new framework are being removed. And of course our new supervisory approach, which as I have said delivers efficiency and effectiveness through integration, and should look and feel simpler for the firms we supervise.We have done all this while maintaining the high standards the public expects from Central Bank and regulated financial service providers. Throughout the rest of this year we will  engage  with you on where you feel simplification is merited or where the burden could be alleviated, while delivering the same outcomes. However, such changes must be done in a way that retains the hard won protections that have been built in the financial system over the last decade, and must ensure regulatory authorities can continue to perform their important role of supervising the financial sector.To sum up, in the period ahead the Central Bank as an organisation intends to take the following approach on this issue:We will proactively engage in the simplification agenda, identifying areas ourselves where regulation and supervision could be simplified, or the administrative burden eased – without compromising on the standards required to deliver on our mandate and maintain our safeguarding outcomes.We will openly engage with all stakeholders, making the case for the value of regulation, while listening to areas where there are unnecessary rules or complexity – or where the same outcomes could be achieved in simpler ways.  We will better explain and demonstrate the benefits of different aspects of the regulatory framework, including enhancing our use and approach to weighing the costs and benefits of regulatory interventions.We will continue to ensure that we are maximising our collective resources, living our risk appetite and being effective and efficient in our regulation and supervision – all of which our new supervisory approach will help us deliver.While proactively and openly engaging on these issues, however, we will remember – and remind others – of the lessons from past regulatory cycles and financial crises. This includes the importance of a strong regulatory framework, of broad-based resilience, of robust risk based supervision, and strong governance and culture in firms – not to mention the willingness of independent regulators to call out risks, and indeed to act.This last point is important. For financial systems, and the societies they serve, are at their most vulnerable when economic and regulatory cycles collide. When resilience is removed precisely when it is most needed. Or when vulnerabilities build, just as protections are removed. It is our job as a good policymakers to ensure our regulations are proportionate and appropriate. But it is also our job as an independent central bank and regulator to call out the risks should simplification slide into de-regulation and lower standards. This is critical to ensuring that we do not compromise on delivering the stability, resilience and protections that consumers and the wider economy needs – and indeed the public expects.11Thank you[1] Many thanks to Cian O’Laoide for help preparing these remarks, and to Steven Cull, Vasileios Madouros, and Gabriel Makhlouf for their helpful comments.[2] See Kay, J. A., & King, M. A. (2020). Radical uncertainty: decision-making beyond the numbers[3] See Regulatory and Supervisory Outlook 2025 February 2025[4] See also Donnery Maintaining stability in the face of volatility November 2023 and Carstens: Investing in banking supervision June 2023[5] See Elderfield Risk Based supervision in Ireland December 2011[6] See Gully What makes an effective prudential supervisor November 2023[7] See Sibley The Banking Crisis – A Decade On September 2018[8] (i) forward looking, (ii) connected, (iii) proportionate, (iv) predictable, (v) transparent and (vi) agile.[9] See also Makhlouf Progress, not regress – financial regulation in challenging times November 2024 [10] See also Donnery Authorisation and Gatekeeping Report May 2024[11] See also Makhlouf Financial Regulation Priorities February 2025 

Ben Loan Services - Central Bank of Ireland Issues Warning on Unauthorised Firm

Ben Loan Services - Central Bank of Ireland Issues Warning on Unauthorised Firm

Ben Loan Services - Central Bank of Ireland Issues Warning on Unauthorised Firm

Ben Loan Services - Central Bank of Ireland Issues Warning on Unauthorised Firm

Ben Loan Services - Central Bank of Ireland Issues Warning on Unauthorised Firm

 Good morning. I am delighted to welcome you to the Central Bank of Ireland today for an engagement on the Markets in Crypto Assets Regulation (MiCAR) and its implementation. And in particular on the path to success in MiCAR authorisation.Recent years have seen tremendous innovations in financial services. Amongst the most notable have been the development of blockchain-based technologies. Over the past five years, the European Commission has implemented its digital finance package. This has included legislation on crypto-assets: the Markets in Crypto Assets Regulation (MiCAR); and on digital resilience in the form of the Digital Operational Resilience Act (DORA). Both of these have recently come in to effect. This digital finance package reflected the EU’s ambition to embrace a digital transition for the benefit of citizens and to help modernise the European economy across sectors. And to turn Europe into a global digital player. In effect, to realise the opportunities within innovation, while managing the risks. This is something to be highly valued and to build on for the further success of the European economy in these challenging times. Times when technological innovation, effectively deployed, will be at the heart of future economic and societal success.At the Central Bank of Ireland, we have been strong supporters of the EU’s ambitions in this area and we have played very active, even leading roles, in the development and implementation of this legislation.MiCAR itself is a very important step forward in the regulation of crypto activities in Europe. It introduces for the first time, what aims to be comprehensive regulatory framework for crypto assets and their operational ecosystem. This morning’s event is an excellent opportunity for us all as participants with different roles in the innovation ecosystem to exchange views. It comes as we navigate an important moment in the MiCAR story: its initial phase of implementation including the first wave of authorisation applications from intending Crypto Asset Service Providers (CASPs). It builds on our last industry wide engagement on MiCAR last July.  A key purpose of our event this morning is to facilitate a conversation. It is designed in particular to provide further support to industry participants who are in the process towards obtaining Central Bank authorisation as MiCAR firms, or who may be thinking about applying for such authorisation.Importance of MiCARMiCAR aims to provide a clear and consistent framework for the regulation of crypto assets and related services across the EU. It also sets the benchmark at a global level, contributing to informing the work of other jurisdictions in their thinking and approaches to setting regulatory standards for crypto assets and related services. Delivering on MiCAR, in a timely outcomes-focused way, is a key focus for the Bank and supervisory authorities across the EU. For our part, we want the future financial system to deliver for consumers, investors, business and the wider economy.  A well-functioning and robust crypto sector that delivers on the promise of innovative products, can be part of that. Ireland as a financial centre could become an important location for crypto asset service providers, as it has been for virtual asset service providers (VASPs). This reflects our existing strengths in both the areas of digital technology and financial services. It reflects broader aspects such as our commitment to Europe, and can I also say, our reputation for, and commitment to, strong, well-designed and outcomes-focused financial regulation.The Regulatory PerspectiveI am often asked: how does the Central Bank of Ireland think about MiCAR and cryptoassets? When you stand back at the end of the day what is your perspective on this new area of regulated financial service? Let me take a moment to share some thoughts on this.Firstly, innovation, including technological innovation, is both very important and very hard. It may be amongst the most difficult things to do: to develop a new idea, to bring it to commercial viability, and then to scale it to being an economic success story. We only have to look at Mario Draghi’s report on EU competitiveness published in September 2024 to know both how important innovation will be to the future of European economic success and the challenges we need to overcome if we are to create the conditions in which this can happen.As I have mentioned crypto technology, the blockchain, distributed ledger, tokenisation, Web3 these are a set of related innovations, which, when we look back, are likely to have been at the heart of a very important wave of technological development. Both in themselves, and in what they will lead to, they represent a significant crossing of the technological frontier.The introduction of MiCAR places Europe in a very good position to benefit from this broad area of technological innovation. This of course requires that MiCAR is implemented well and in a way that is closely aligned with the delivery of its objectives. And this is very much where and how we see the role of the Central Bank of Ireland. We see our role as implementing MiCAR in a way that supports its successful delivery of the outcomes that it is seeking to deliver. And of course when we implement any regulatory framework, and in how we supervise, we are outcomes focused. The outcomes we seek at a general level are a financial system which functions well in support of consumers and users and the wider economy. It should be trusted to operate in customers’ interests, to be resilient, and to avoid being used for financial crime and money laundering. These are all things which the public expects of financial sector. And it is not only in their interests but in the interest of the sector itself that they are achieved.Guided by these outcomes, amongst the things that we are focusing on in implementing MiCAR are:Governance and culture: In 2022, we saw the “Crypto Winter” where investors and consumers experienced the negative impacts arising from a lack of good governance and poor culture in certain parts of the sector.Consumer interests. Our revised Consumer Protection Code was launched this week. At its heart is the obligation for regulated financial firms to secure their customer’ interests. This means that at all stages, from the development of a business model and strategy, through product design and marketing, and after sales, firms must ensure that what they are offering and doing is well aligned with their customers’ reasonable expectations and with their interests.Risks to consumers and investors are inherently high in some crypto and related services and crypto markets have been noteworthy for their significant volatility. While representing important progress, MiCAR will not provide the same levels of protection as exists for traditional financial investment products, nor will it enable mitigation of all the risks linked to crypto-assets.Regulators, including ESMA and ourselves, have issued a set of warnings to consumers concerning crypto markets. We have expressed scepticism about business models where profitability is driven from the heavy marketing, offering and distributing of unbacked crypto to retail customers for speculative purposes. Where we see higher inherent conduct and investor protection risks in the products offered to customers and investors, we will have higher expectations of firm’s ability to manage these risks.Crime and fraud. 2025 has already seen an enormous theft event of crypto assets in another part of the world. This underscores the importance of high levels of security, without which the sector will not flourish. More broadly it is essential that there is effective control of the risk of money laundering and other criminal activity.As a regulator, these are the factors influencing our thinking and our approach to regulating this sector. It is our objective to ensure the regulatory environment enables the potential benefits of innovation for consumers, businesses and society to be realised, while ensuring that the risks are effectively managed and mitigated. Consumer and investor protection begins with firms themselves. For the crypto sector to succeed, compliance and a customer centric approach should not be seen as a cost of doing business, but rather, they have the potential to be a competitive advantage. The provision of financial services is about helping others make financial decisions; it is also about the provision of choice for consumers and importantly, the provision of products that are appropriate and suitable for consumers. And the better firms’ own risk management, the better position they are in to understand, calculate and mitigate their risks, therefore strengthening their business model, and their relationship with their customers.MiCAR ReadinessAs the National Competent Authority for MiCAR in Ireland, we are well advanced in our authorisations pathway having regard to the twelve-month transitional period for VASPs to be authorised as CASPs under MiCAR. The Central Bank’s authorisation process is based on clarity, transparency, flexibility and predictability for firms seeking authorisation.  We are committed to delivering the benefits of the new EU regulatory framework for crypto assets. And we have been in continuous engagement with different players in the ecosystem, including of course, with many of you in the room today.To achieve this, we have a well-resourced and expert team handling the CASP authorisation process in a high quality and timely way. This is designed to ensure a good implementation of the new MiCAR regime in Ireland cognisant of business demands and the 12-month transition period. Key to our approach is the idea of a path to success - for firms engaging with the Central Bank on MiCAR Authorisation, and for the regulatory system as we move to the implementation of this new framework.Let me say a little about this. Sonia Weafer, who heads up the CASP Authorisation and Supervision teams, will delve into some of the aspects I mention in more detail in a few minutes.Firstly, our authorisation approach. This is two-phased, with phase 1 comprising of preliminary engagement and a Key Facts Document (KFD) stage and phase 2 comprising of formal authorisation. In order to move as quickly as possible, with maximum flexibility and adaptive engagement for firms, we are heavily frontloading work into phase 1. This will set firms up well for an efficient phase 2 process.We have designed this purposefully as we are extremely cognizant of the tight timelines of MiCAR and the 12 months transitional arrangements. By front-loading into the preliminary engagement and KFD, we are hopeful that we will unpack and resolve any issues, thus making the formal authorisation process smoother and more expeditious. We believe this approach will benefit firms as they engage with us during the authorisation process.I have mentioned the path to success for firms and there are a few considerations that can ensure this.We are dealing with a pipeline of diverse firms. Some are large global firms that have significant resources to hand, including the ability to leverage intra-group structures and entities. Others are smaller firms, perhaps indigenous, perhaps at an earlier stage in their business life cycle. Some are seeking authorisation for the full suite of activities under MiCAR, while some are seeking authorisation for a select few activities. It is a diverse context, and the issues we all are experiencing are diverse as we navigate this new regulation together.In the context of this diversity, I would like to highlight that we recognise the challenges you will be facing. And we want you to succeed, so that we have well-prepared and well-run firms on the other side of the gate. For those of you in the earlier stages of the business life cycle, we recognise that resourcing the lift on MiCAR is significant. Regulation should not be a barrier to innovation and we fully appreciate the need for proportionality in our approach. In this context, what we have found helpful is detailed engagement with you, and signposting from our side, partnered with your own reflections. MICAR is about enabling safe innovation, and I say to small firms here today, we will work with you to meet challenges in a constructive way.If I were to call out specific issues I would like to focus on:Substantive presence: We believe that MiCAR provides a constructive way forward to give legal clarity within a harmonised manner across the EU. We believe that building an EU crypto ecosystem demands commitment. As such, substance is of critical importance. I won’t focus on our lack of appetite for firms that seek to operate on a “brass plate” basis, rather I want to encourage firms to recognise the opportunity of investing appropriately in their EU entity seeking CASP Authorisation and the long term benefits to them of contributing to the development of the EU crypto ecosystem. Outsourcing: Outsourcing is part of every modern business and we recognise its benefits. Leveraging intra-group entities and functions can bring additional strength as well as efficiencies. There are, of course, limits to the level of outsourcing that works. A firm cannot outsource to the extent that it becomes an empty shell or in a manner that means a core activity and the effective accountability for it are moved outside the firm.Alignment with MiCAR and the ESMA Broker Model: A critical point of concern for us is that business models should align with MiCAR, including the ESMA Broker Model Opinion. We have and will continue to push strongly against business models that do not adhere to this, in line with our European counterparts. Clarity on the activities for which you need authorisation: An issue we are finding commonplace is that firms are not clear on their full business model and the activities they need authorisation for. Here we have worked with firms to unpack elements of their proposals, bringing questions to the table to help drive clarity.Governance and Safeguarding: Regardless of the services, the target customer base, or whether the business is retail focused or aimed at institutional clients, governance and safeguarding of client assets are critical considerations for the Central Bank.Finally, we appreciate that MiCAR is new, and that we are all navigating new scenarios. In this regard, we recognise that we have a role in facilitating greater clarity, and I reiterate that we are fully open to constructive discussion with firms to work through challenges. For any firm considering seeking authorisation as a CASP, our website has information on our authorisation process, including the CASP application form and information on our expectations on authorisation.Our Work in EuropeNow I want to mention an aspect that has been fundamental to our approach to MiCAR and its implementation. That is that it is a European framework designed to operate consistently across Europe. Fundamentally, many of its benefits derive from the fact that it is a regulatory framework designed for the large European market.As I have said, at the Central Bank we have played a very active role at European level in the development and implementation of the new framework. We continue to focus a significant part of our effort to work at an EU level. It is of critical importance that together we achieve a harmonised and convergent approach to implementing MiCAR across the EU. Avoidance of divergent approaches or the potential for regulatory arbitrage is a key goal for us, the European Supervisory Authorities (ESAs), and other National Competent Authorities (NCAs). Without this, the MiCAR framework will be undermined and its benefits significantly reduced.We are working as part of both the EBA and ESMA supervisory communities in this regard. ESMA is charged with driving a convergent approach to MiCAR implementation for CASPs and through its Digital Finance Standing Committee (DFSC) is facilitating an impactful and real-time sharing of authorisation experiences and approaches among NCAs. This includes building convergence on whether firm proposals, business models, and their component parts are fully compliant with MiCAR and any ESMA opinions. We are finding this to be a very useful and valuable process. It draws on, and builds on, a similar approach that was adopted during the Brexit-related relocation process. It is delivering real results.Furthermore, we are engaging with other NCA’s on a bilateral basis to unpack specific issues and challenges. This engagement not only allows us to engage with other experts across the EU but also help to drive a convergent approach to applying MiCAR. We want to build a path for success so that we can help deliver positive outcomes for the ecosystem, and our EU engagement is critical for this. The result is that we do not expect to see divergent approaches across the different EU jurisdictions.ConclusionBefore I hand over to Sonia, I want to reiterate the purpose for today. We hope that today will facilitate a conversation, to help you as industry participants, navigate the next steps to success in your MiCAR journey with us here in the Central Bank. We find such engagement very valuable and hope that you do also. We want to see firms move successfully through the authorisation process. We are committed to achieving the benefits of the new EU regulatory framework for crypto assets while ensuring the risks are well managed. To achieve this, firms should focus on good quality submissions, timely engagement with us, full alignment with MiCAR and ESMA Broker Model Opinion, an openness to reflect on feedback, and a clear commitment to their European and Irish presence.Thank you for your attention and I shall now handover to Sonia Weafer.

 Good morning. I am delighted to welcome you to the Central Bank of Ireland today for an engagement on the Markets in Crypto Assets Regulation (MiCAR) and its implementation. And in particular on the path to success in MiCAR authorisation.Recent years have seen tremendous innovations in financial services. Amongst the most notable have been the development of blockchain-based technologies. Over the past five years, the European Commission has implemented its digital finance package. This has included legislation on crypto-assets: the Markets in Crypto Assets Regulation (MiCAR); and on digital resilience in the form of the Digital Operational Resilience Act (DORA). Both of these have recently come in to effect. This digital finance package reflected the EU’s ambition to embrace a digital transition for the benefit of citizens and to help modernise the European economy across sectors. And to turn Europe into a global digital player. In effect, to realise the opportunities within innovation, while managing the risks. This is something to be highly valued and to build on for the further success of the European economy in these challenging times. Times when technological innovation, effectively deployed, will be at the heart of future economic and societal success.At the Central Bank of Ireland, we have been strong supporters of the EU’s ambitions in this area and we have played very active, even leading roles, in the development and implementation of this legislation.MiCAR itself is a very important step forward in the regulation of crypto activities in Europe. It introduces for the first time, what aims to be comprehensive regulatory framework for crypto assets and their operational ecosystem. This morning’s event is an excellent opportunity for us all as participants with different roles in the innovation ecosystem to exchange views. It comes as we navigate an important moment in the MiCAR story: its initial phase of implementation including the first wave of authorisation applications from intending Crypto Asset Service Providers (CASPs). It builds on our last industry wide engagement on MiCAR last July.  A key purpose of our event this morning is to facilitate a conversation. It is designed in particular to provide further support to industry participants who are in the process towards obtaining Central Bank authorisation as MiCAR firms, or who may be thinking about applying for such authorisation.Importance of MiCARMiCAR aims to provide a clear and consistent framework for the regulation of crypto assets and related services across the EU. It also sets the benchmark at a global level, contributing to informing the work of other jurisdictions in their thinking and approaches to setting regulatory standards for crypto assets and related services. Delivering on MiCAR, in a timely outcomes-focused way, is a key focus for the Bank and supervisory authorities across the EU. For our part, we want the future financial system to deliver for consumers, investors, business and the wider economy.  A well-functioning and robust crypto sector that delivers on the promise of innovative products, can be part of that. Ireland as a financial centre could become an important location for crypto asset service providers, as it has been for virtual asset service providers (VASPs). This reflects our existing strengths in both the areas of digital technology and financial services. It reflects broader aspects such as our commitment to Europe, and can I also say, our reputation for, and commitment to, strong, well-designed and outcomes-focused financial regulation.The Regulatory PerspectiveI am often asked: how does the Central Bank of Ireland think about MiCAR and cryptoassets? When you stand back at the end of the day what is your perspective on this new area of regulated financial service? Let me take a moment to share some thoughts on this.Firstly, innovation, including technological innovation, is both very important and very hard. It may be amongst the most difficult things to do: to develop a new idea, to bring it to commercial viability, and then to scale it to being an economic success story. We only have to look at Mario Draghi’s report on EU competitiveness published in September 2024 to know both how important innovation will be to the future of European economic success and the challenges we need to overcome if we are to create the conditions in which this can happen.As I have mentioned crypto technology, the blockchain, distributed ledger, tokenisation, Web3 these are a set of related innovations, which, when we look back, are likely to have been at the heart of a very important wave of technological development. Both in themselves, and in what they will lead to, they represent a significant crossing of the technological frontier.The introduction of MiCAR places Europe in a very good position to benefit from this broad area of technological innovation. This of course requires that MiCAR is implemented well and in a way that is closely aligned with the delivery of its objectives. And this is very much where and how we see the role of the Central Bank of Ireland. We see our role as implementing MiCAR in a way that supports its successful delivery of the outcomes that it is seeking to deliver. And of course when we implement any regulatory framework, and in how we supervise, we are outcomes focused. The outcomes we seek at a general level are a financial system which functions well in support of consumers and users and the wider economy. It should be trusted to operate in customers’ interests, to be resilient, and to avoid being used for financial crime and money laundering. These are all things which the public expects of financial sector. And it is not only in their interests but in the interest of the sector itself that they are achieved.Guided by these outcomes, amongst the things that we are focusing on in implementing MiCAR are:Governance and culture: In 2022, we saw the “Crypto Winter” where investors and consumers experienced the negative impacts arising from a lack of good governance and poor culture in certain parts of the sector.Consumer interests. Our revised Consumer Protection Code was launched this week. At its heart is the obligation for regulated financial firms to secure their customer’ interests. This means that at all stages, from the development of a business model and strategy, through product design and marketing, and after sales, firms must ensure that what they are offering and doing is well aligned with their customers’ reasonable expectations and with their interests.Risks to consumers and investors are inherently high in some crypto and related services and crypto markets have been noteworthy for their significant volatility. While representing important progress, MiCAR will not provide the same levels of protection as exists for traditional financial investment products, nor will it enable mitigation of all the risks linked to crypto-assets.Regulators, including ESMA and ourselves, have issued a set of warnings to consumers concerning crypto markets. We have expressed scepticism about business models where profitability is driven from the heavy marketing, offering and distributing of unbacked crypto to retail customers for speculative purposes. Where we see higher inherent conduct and investor protection risks in the products offered to customers and investors, we will have higher expectations of firm’s ability to manage these risks.Crime and fraud. 2025 has already seen an enormous theft event of crypto assets in another part of the world. This underscores the importance of high levels of security, without which the sector will not flourish. More broadly it is essential that there is effective control of the risk of money laundering and other criminal activity.As a regulator, these are the factors influencing our thinking and our approach to regulating this sector. It is our objective to ensure the regulatory environment enables the potential benefits of innovation for consumers, businesses and society to be realised, while ensuring that the risks are effectively managed and mitigated. Consumer and investor protection begins with firms themselves. For the crypto sector to succeed, compliance and a customer centric approach should not be seen as a cost of doing business, but rather, they have the potential to be a competitive advantage. The provision of financial services is about helping others make financial decisions; it is also about the provision of choice for consumers and importantly, the provision of products that are appropriate and suitable for consumers. And the better firms’ own risk management, the better position they are in to understand, calculate and mitigate their risks, therefore strengthening their business model, and their relationship with their customers.MiCAR ReadinessAs the National Competent Authority for MiCAR in Ireland, we are well advanced in our authorisations pathway having regard to the twelve-month transitional period for VASPs to be authorised as CASPs under MiCAR. The Central Bank’s authorisation process is based on clarity, transparency, flexibility and predictability for firms seeking authorisation.  We are committed to delivering the benefits of the new EU regulatory framework for crypto assets. And we have been in continuous engagement with different players in the ecosystem, including of course, with many of you in the room today.To achieve this, we have a well-resourced and expert team handling the CASP authorisation process in a high quality and timely way. This is designed to ensure a good implementation of the new MiCAR regime in Ireland cognisant of business demands and the 12-month transition period. Key to our approach is the idea of a path to success - for firms engaging with the Central Bank on MiCAR Authorisation, and for the regulatory system as we move to the implementation of this new framework.Let me say a little about this. Sonia Weafer, who heads up the CASP Authorisation and Supervision teams, will delve into some of the aspects I mention in more detail in a few minutes.Firstly, our authorisation approach. This is two-phased, with phase 1 comprising of preliminary engagement and a Key Facts Document (KFD) stage and phase 2 comprising of formal authorisation. In order to move as quickly as possible, with maximum flexibility and adaptive engagement for firms, we are heavily frontloading work into phase 1. This will set firms up well for an efficient phase 2 process.We have designed this purposefully as we are extremely cognizant of the tight timelines of MiCAR and the 12 months transitional arrangements. By front-loading into the preliminary engagement and KFD, we are hopeful that we will unpack and resolve any issues, thus making the formal authorisation process smoother and more expeditious. We believe this approach will benefit firms as they engage with us during the authorisation process.I have mentioned the path to success for firms and there are a few considerations that can ensure this.We are dealing with a pipeline of diverse firms. Some are large global firms that have significant resources to hand, including the ability to leverage intra-group structures and entities. Others are smaller firms, perhaps indigenous, perhaps at an earlier stage in their business life cycle. Some are seeking authorisation for the full suite of activities under MiCAR, while some are seeking authorisation for a select few activities. It is a diverse context, and the issues we all are experiencing are diverse as we navigate this new regulation together.In the context of this diversity, I would like to highlight that we recognise the challenges you will be facing. And we want you to succeed, so that we have well-prepared and well-run firms on the other side of the gate. For those of you in the earlier stages of the business life cycle, we recognise that resourcing the lift on MiCAR is significant. Regulation should not be a barrier to innovation and we fully appreciate the need for proportionality in our approach. In this context, what we have found helpful is detailed engagement with you, and signposting from our side, partnered with your own reflections. MICAR is about enabling safe innovation, and I say to small firms here today, we will work with you to meet challenges in a constructive way.If I were to call out specific issues I would like to focus on:Substantive presence: We believe that MiCAR provides a constructive way forward to give legal clarity within a harmonised manner across the EU. We believe that building an EU crypto ecosystem demands commitment. As such, substance is of critical importance. I won’t focus on our lack of appetite for firms that seek to operate on a “brass plate” basis, rather I want to encourage firms to recognise the opportunity of investing appropriately in their EU entity seeking CASP Authorisation and the long term benefits to them of contributing to the development of the EU crypto ecosystem. Outsourcing: Outsourcing is part of every modern business and we recognise its benefits. Leveraging intra-group entities and functions can bring additional strength as well as efficiencies. There are, of course, limits to the level of outsourcing that works. A firm cannot outsource to the extent that it becomes an empty shell or in a manner that means a core activity and the effective accountability for it are moved outside the firm.Alignment with MiCAR and the ESMA Broker Model: A critical point of concern for us is that business models should align with MiCAR, including the ESMA Broker Model Opinion. We have and will continue to push strongly against business models that do not adhere to this, in line with our European counterparts. Clarity on the activities for which you need authorisation: An issue we are finding commonplace is that firms are not clear on their full business model and the activities they need authorisation for. Here we have worked with firms to unpack elements of their proposals, bringing questions to the table to help drive clarity.Governance and Safeguarding: Regardless of the services, the target customer base, or whether the business is retail focused or aimed at institutional clients, governance and safeguarding of client assets are critical considerations for the Central Bank.Finally, we appreciate that MiCAR is new, and that we are all navigating new scenarios. In this regard, we recognise that we have a role in facilitating greater clarity, and I reiterate that we are fully open to constructive discussion with firms to work through challenges. For any firm considering seeking authorisation as a CASP, our website has information on our authorisation process, including the CASP application form and information on our expectations on authorisation.Our Work in EuropeNow I want to mention an aspect that has been fundamental to our approach to MiCAR and its implementation. That is that it is a European framework designed to operate consistently across Europe. Fundamentally, many of its benefits derive from the fact that it is a regulatory framework designed for the large European market.As I have said, at the Central Bank we have played a very active role at European level in the development and implementation of the new framework. We continue to focus a significant part of our effort to work at an EU level. It is of critical importance that together we achieve a harmonised and convergent approach to implementing MiCAR across the EU. Avoidance of divergent approaches or the potential for regulatory arbitrage is a key goal for us, the European Supervisory Authorities (ESAs), and other National Competent Authorities (NCAs). Without this, the MiCAR framework will be undermined and its benefits significantly reduced.We are working as part of both the EBA and ESMA supervisory communities in this regard. ESMA is charged with driving a convergent approach to MiCAR implementation for CASPs and through its Digital Finance Standing Committee (DFSC) is facilitating an impactful and real-time sharing of authorisation experiences and approaches among NCAs. This includes building convergence on whether firm proposals, business models, and their component parts are fully compliant with MiCAR and any ESMA opinions. We are finding this to be a very useful and valuable process. It draws on, and builds on, a similar approach that was adopted during the Brexit-related relocation process. It is delivering real results.Furthermore, we are engaging with other NCA’s on a bilateral basis to unpack specific issues and challenges. This engagement not only allows us to engage with other experts across the EU but also help to drive a convergent approach to applying MiCAR. We want to build a path for success so that we can help deliver positive outcomes for the ecosystem, and our EU engagement is critical for this. The result is that we do not expect to see divergent approaches across the different EU jurisdictions.ConclusionBefore I hand over to Sonia, I want to reiterate the purpose for today. We hope that today will facilitate a conversation, to help you as industry participants, navigate the next steps to success in your MiCAR journey with us here in the Central Bank. We find such engagement very valuable and hope that you do also. We want to see firms move successfully through the authorisation process. We are committed to achieving the benefits of the new EU regulatory framework for crypto assets while ensuring the risks are well managed. To achieve this, firms should focus on good quality submissions, timely engagement with us, full alignment with MiCAR and ESMA Broker Model Opinion, an openness to reflect on feedback, and a clear commitment to their European and Irish presence.Thank you for your attention and I shall now handover to Sonia Weafer.

 Good morning. I am delighted to welcome you to the Central Bank of Ireland today for an engagement on the Markets in Crypto Assets Regulation (MiCAR) and its implementation. And in particular on the path to success in MiCAR authorisation.Recent years have seen tremendous innovations in financial services. Amongst the most notable have been the development of blockchain-based technologies. Over the past five years, the European Commission has implemented its digital finance package. This has included legislation on crypto-assets: the Markets in Crypto Assets Regulation (MiCAR); and on digital resilience in the form of the Digital Operational Resilience Act (DORA). Both of these have recently come in to effect. This digital finance package reflected the EU’s ambition to embrace a digital transition for the benefit of citizens and to help modernise the European economy across sectors. And to turn Europe into a global digital player. In effect, to realise the opportunities within innovation, while managing the risks. This is something to be highly valued and to build on for the further success of the European economy in these challenging times. Times when technological innovation, effectively deployed, will be at the heart of future economic and societal success.At the Central Bank of Ireland, we have been strong supporters of the EU’s ambitions in this area and we have played very active, even leading roles, in the development and implementation of this legislation.MiCAR itself is a very important step forward in the regulation of crypto activities in Europe. It introduces for the first time, what aims to be comprehensive regulatory framework for crypto assets and their operational ecosystem. This morning’s event is an excellent opportunity for us all as participants with different roles in the innovation ecosystem to exchange views. It comes as we navigate an important moment in the MiCAR story: its initial phase of implementation including the first wave of authorisation applications from intending Crypto Asset Service Providers (CASPs). It builds on our last industry wide engagement on MiCAR last July.  A key purpose of our event this morning is to facilitate a conversation. It is designed in particular to provide further support to industry participants who are in the process towards obtaining Central Bank authorisation as MiCAR firms, or who may be thinking about applying for such authorisation.Importance of MiCARMiCAR aims to provide a clear and consistent framework for the regulation of crypto assets and related services across the EU. It also sets the benchmark at a global level, contributing to informing the work of other jurisdictions in their thinking and approaches to setting regulatory standards for crypto assets and related services. Delivering on MiCAR, in a timely outcomes-focused way, is a key focus for the Bank and supervisory authorities across the EU. For our part, we want the future financial system to deliver for consumers, investors, business and the wider economy.  A well-functioning and robust crypto sector that delivers on the promise of innovative products, can be part of that. Ireland as a financial centre could become an important location for crypto asset service providers, as it has been for virtual asset service providers (VASPs). This reflects our existing strengths in both the areas of digital technology and financial services. It reflects broader aspects such as our commitment to Europe, and can I also say, our reputation for, and commitment to, strong, well-designed and outcomes-focused financial regulation.The Regulatory PerspectiveI am often asked: how does the Central Bank of Ireland think about MiCAR and cryptoassets? When you stand back at the end of the day what is your perspective on this new area of regulated financial service? Let me take a moment to share some thoughts on this.Firstly, innovation, including technological innovation, is both very important and very hard. It may be amongst the most difficult things to do: to develop a new idea, to bring it to commercial viability, and then to scale it to being an economic success story. We only have to look at Mario Draghi’s report on EU competitiveness published in September 2024 to know both how important innovation will be to the future of European economic success and the challenges we need to overcome if we are to create the conditions in which this can happen.As I have mentioned crypto technology, the blockchain, distributed ledger, tokenisation, Web3 these are a set of related innovations, which, when we look back, are likely to have been at the heart of a very important wave of technological development. Both in themselves, and in what they will lead to, they represent a significant crossing of the technological frontier.The introduction of MiCAR places Europe in a very good position to benefit from this broad area of technological innovation. This of course requires that MiCAR is implemented well and in a way that is closely aligned with the delivery of its objectives. And this is very much where and how we see the role of the Central Bank of Ireland. We see our role as implementing MiCAR in a way that supports its successful delivery of the outcomes that it is seeking to deliver. And of course when we implement any regulatory framework, and in how we supervise, we are outcomes focused. The outcomes we seek at a general level are a financial system which functions well in support of consumers and users and the wider economy. It should be trusted to operate in customers’ interests, to be resilient, and to avoid being used for financial crime and money laundering. These are all things which the public expects of financial sector. And it is not only in their interests but in the interest of the sector itself that they are achieved.Guided by these outcomes, amongst the things that we are focusing on in implementing MiCAR are:Governance and culture: In 2022, we saw the “Crypto Winter” where investors and consumers experienced the negative impacts arising from a lack of good governance and poor culture in certain parts of the sector.Consumer interests. Our revised Consumer Protection Code was launched this week. At its heart is the obligation for regulated financial firms to secure their customer’ interests. This means that at all stages, from the development of a business model and strategy, through product design and marketing, and after sales, firms must ensure that what they are offering and doing is well aligned with their customers’ reasonable expectations and with their interests.Risks to consumers and investors are inherently high in some crypto and related services and crypto markets have been noteworthy for their significant volatility. While representing important progress, MiCAR will not provide the same levels of protection as exists for traditional financial investment products, nor will it enable mitigation of all the risks linked to crypto-assets.Regulators, including ESMA and ourselves, have issued a set of warnings to consumers concerning crypto markets. We have expressed scepticism about business models where profitability is driven from the heavy marketing, offering and distributing of unbacked crypto to retail customers for speculative purposes. Where we see higher inherent conduct and investor protection risks in the products offered to customers and investors, we will have higher expectations of firm’s ability to manage these risks.Crime and fraud. 2025 has already seen an enormous theft event of crypto assets in another part of the world. This underscores the importance of high levels of security, without which the sector will not flourish. More broadly it is essential that there is effective control of the risk of money laundering and other criminal activity.As a regulator, these are the factors influencing our thinking and our approach to regulating this sector. It is our objective to ensure the regulatory environment enables the potential benefits of innovation for consumers, businesses and society to be realised, while ensuring that the risks are effectively managed and mitigated. Consumer and investor protection begins with firms themselves. For the crypto sector to succeed, compliance and a customer centric approach should not be seen as a cost of doing business, but rather, they have the potential to be a competitive advantage. The provision of financial services is about helping others make financial decisions; it is also about the provision of choice for consumers and importantly, the provision of products that are appropriate and suitable for consumers. And the better firms’ own risk management, the better position they are in to understand, calculate and mitigate their risks, therefore strengthening their business model, and their relationship with their customers.MiCAR ReadinessAs the National Competent Authority for MiCAR in Ireland, we are well advanced in our authorisations pathway having regard to the twelve-month transitional period for VASPs to be authorised as CASPs under MiCAR. The Central Bank’s authorisation process is based on clarity, transparency, flexibility and predictability for firms seeking authorisation.  We are committed to delivering the benefits of the new EU regulatory framework for crypto assets. And we have been in continuous engagement with different players in the ecosystem, including of course, with many of you in the room today.To achieve this, we have a well-resourced and expert team handling the CASP authorisation process in a high quality and timely way. This is designed to ensure a good implementation of the new MiCAR regime in Ireland cognisant of business demands and the 12-month transition period. Key to our approach is the idea of a path to success - for firms engaging with the Central Bank on MiCAR Authorisation, and for the regulatory system as we move to the implementation of this new framework.Let me say a little about this. Sonia Weafer, who heads up the CASP Authorisation and Supervision teams, will delve into some of the aspects I mention in more detail in a few minutes.Firstly, our authorisation approach. This is two-phased, with phase 1 comprising of preliminary engagement and a Key Facts Document (KFD) stage and phase 2 comprising of formal authorisation. In order to move as quickly as possible, with maximum flexibility and adaptive engagement for firms, we are heavily frontloading work into phase 1. This will set firms up well for an efficient phase 2 process.We have designed this purposefully as we are extremely cognizant of the tight timelines of MiCAR and the 12 months transitional arrangements. By front-loading into the preliminary engagement and KFD, we are hopeful that we will unpack and resolve any issues, thus making the formal authorisation process smoother and more expeditious. We believe this approach will benefit firms as they engage with us during the authorisation process.I have mentioned the path to success for firms and there are a few considerations that can ensure this.We are dealing with a pipeline of diverse firms. Some are large global firms that have significant resources to hand, including the ability to leverage intra-group structures and entities. Others are smaller firms, perhaps indigenous, perhaps at an earlier stage in their business life cycle. Some are seeking authorisation for the full suite of activities under MiCAR, while some are seeking authorisation for a select few activities. It is a diverse context, and the issues we all are experiencing are diverse as we navigate this new regulation together.In the context of this diversity, I would like to highlight that we recognise the challenges you will be facing. And we want you to succeed, so that we have well-prepared and well-run firms on the other side of the gate. For those of you in the earlier stages of the business life cycle, we recognise that resourcing the lift on MiCAR is significant. Regulation should not be a barrier to innovation and we fully appreciate the need for proportionality in our approach. In this context, what we have found helpful is detailed engagement with you, and signposting from our side, partnered with your own reflections. MICAR is about enabling safe innovation, and I say to small firms here today, we will work with you to meet challenges in a constructive way.If I were to call out specific issues I would like to focus on:Substantive presence: We believe that MiCAR provides a constructive way forward to give legal clarity within a harmonised manner across the EU. We believe that building an EU crypto ecosystem demands commitment. As such, substance is of critical importance. I won’t focus on our lack of appetite for firms that seek to operate on a “brass plate” basis, rather I want to encourage firms to recognise the opportunity of investing appropriately in their EU entity seeking CASP Authorisation and the long term benefits to them of contributing to the development of the EU crypto ecosystem. Outsourcing: Outsourcing is part of every modern business and we recognise its benefits. Leveraging intra-group entities and functions can bring additional strength as well as efficiencies. There are, of course, limits to the level of outsourcing that works. A firm cannot outsource to the extent that it becomes an empty shell or in a manner that means a core activity and the effective accountability for it are moved outside the firm.Alignment with MiCAR and the ESMA Broker Model: A critical point of concern for us is that business models should align with MiCAR, including the ESMA Broker Model Opinion. We have and will continue to push strongly against business models that do not adhere to this, in line with our European counterparts. Clarity on the activities for which you need authorisation: An issue we are finding commonplace is that firms are not clear on their full business model and the activities they need authorisation for. Here we have worked with firms to unpack elements of their proposals, bringing questions to the table to help drive clarity.Governance and Safeguarding: Regardless of the services, the target customer base, or whether the business is retail focused or aimed at institutional clients, governance and safeguarding of client assets are critical considerations for the Central Bank.Finally, we appreciate that MiCAR is new, and that we are all navigating new scenarios. In this regard, we recognise that we have a role in facilitating greater clarity, and I reiterate that we are fully open to constructive discussion with firms to work through challenges. For any firm considering seeking authorisation as a CASP, our website has information on our authorisation process, including the CASP application form and information on our expectations on authorisation.Our Work in EuropeNow I want to mention an aspect that has been fundamental to our approach to MiCAR and its implementation. That is that it is a European framework designed to operate consistently across Europe. Fundamentally, many of its benefits derive from the fact that it is a regulatory framework designed for the large European market.As I have said, at the Central Bank we have played a very active role at European level in the development and implementation of the new framework. We continue to focus a significant part of our effort to work at an EU level. It is of critical importance that together we achieve a harmonised and convergent approach to implementing MiCAR across the EU. Avoidance of divergent approaches or the potential for regulatory arbitrage is a key goal for us, the European Supervisory Authorities (ESAs), and other National Competent Authorities (NCAs). Without this, the MiCAR framework will be undermined and its benefits significantly reduced.We are working as part of both the EBA and ESMA supervisory communities in this regard. ESMA is charged with driving a convergent approach to MiCAR implementation for CASPs and through its Digital Finance Standing Committee (DFSC) is facilitating an impactful and real-time sharing of authorisation experiences and approaches among NCAs. This includes building convergence on whether firm proposals, business models, and their component parts are fully compliant with MiCAR and any ESMA opinions. We are finding this to be a very useful and valuable process. It draws on, and builds on, a similar approach that was adopted during the Brexit-related relocation process. It is delivering real results.Furthermore, we are engaging with other NCA’s on a bilateral basis to unpack specific issues and challenges. This engagement not only allows us to engage with other experts across the EU but also help to drive a convergent approach to applying MiCAR. We want to build a path for success so that we can help deliver positive outcomes for the ecosystem, and our EU engagement is critical for this. The result is that we do not expect to see divergent approaches across the different EU jurisdictions.ConclusionBefore I hand over to Sonia, I want to reiterate the purpose for today. We hope that today will facilitate a conversation, to help you as industry participants, navigate the next steps to success in your MiCAR journey with us here in the Central Bank. We find such engagement very valuable and hope that you do also. We want to see firms move successfully through the authorisation process. We are committed to achieving the benefits of the new EU regulatory framework for crypto assets while ensuring the risks are well managed. To achieve this, firms should focus on good quality submissions, timely engagement with us, full alignment with MiCAR and ESMA Broker Model Opinion, an openness to reflect on feedback, and a clear commitment to their European and Irish presence.Thank you for your attention and I shall now handover to Sonia Weafer.

 Good morning. I am delighted to welcome you to the Central Bank of Ireland today for an engagement on the Markets in Crypto Assets Regulation (MiCAR) and its implementation. And in particular on the path to success in MiCAR authorisation.Recent years have seen tremendous innovations in financial services. Amongst the most notable have been the development of blockchain-based technologies. Over the past five years, the European Commission has implemented its digital finance package. This has included legislation on crypto-assets: the Markets in Crypto Assets Regulation (MiCAR); and on digital resilience in the form of the Digital Operational Resilience Act (DORA). Both of these have recently come in to effect. This digital finance package reflected the EU’s ambition to embrace a digital transition for the benefit of citizens and to help modernise the European economy across sectors. And to turn Europe into a global digital player. In effect, to realise the opportunities within innovation, while managing the risks. This is something to be highly valued and to build on for the further success of the European economy in these challenging times. Times when technological innovation, effectively deployed, will be at the heart of future economic and societal success.At the Central Bank of Ireland, we have been strong supporters of the EU’s ambitions in this area and we have played very active, even leading roles, in the development and implementation of this legislation.MiCAR itself is a very important step forward in the regulation of crypto activities in Europe. It introduces for the first time, what aims to be comprehensive regulatory framework for crypto assets and their operational ecosystem. This morning’s event is an excellent opportunity for us all as participants with different roles in the innovation ecosystem to exchange views. It comes as we navigate an important moment in the MiCAR story: its initial phase of implementation including the first wave of authorisation applications from intending Crypto Asset Service Providers (CASPs). It builds on our last industry wide engagement on MiCAR last July.  A key purpose of our event this morning is to facilitate a conversation. It is designed in particular to provide further support to industry participants who are in the process towards obtaining Central Bank authorisation as MiCAR firms, or who may be thinking about applying for such authorisation.Importance of MiCARMiCAR aims to provide a clear and consistent framework for the regulation of crypto assets and related services across the EU. It also sets the benchmark at a global level, contributing to informing the work of other jurisdictions in their thinking and approaches to setting regulatory standards for crypto assets and related services. Delivering on MiCAR, in a timely outcomes-focused way, is a key focus for the Bank and supervisory authorities across the EU. For our part, we want the future financial system to deliver for consumers, investors, business and the wider economy.  A well-functioning and robust crypto sector that delivers on the promise of innovative products, can be part of that. Ireland as a financial centre could become an important location for crypto asset service providers, as it has been for virtual asset service providers (VASPs). This reflects our existing strengths in both the areas of digital technology and financial services. It reflects broader aspects such as our commitment to Europe, and can I also say, our reputation for, and commitment to, strong, well-designed and outcomes-focused financial regulation.The Regulatory PerspectiveI am often asked: how does the Central Bank of Ireland think about MiCAR and cryptoassets? When you stand back at the end of the day what is your perspective on this new area of regulated financial service? Let me take a moment to share some thoughts on this.Firstly, innovation, including technological innovation, is both very important and very hard. It may be amongst the most difficult things to do: to develop a new idea, to bring it to commercial viability, and then to scale it to being an economic success story. We only have to look at Mario Draghi’s report on EU competitiveness published in September 2024 to know both how important innovation will be to the future of European economic success and the challenges we need to overcome if we are to create the conditions in which this can happen.As I have mentioned crypto technology, the blockchain, distributed ledger, tokenisation, Web3 these are a set of related innovations, which, when we look back, are likely to have been at the heart of a very important wave of technological development. Both in themselves, and in what they will lead to, they represent a significant crossing of the technological frontier.The introduction of MiCAR places Europe in a very good position to benefit from this broad area of technological innovation. This of course requires that MiCAR is implemented well and in a way that is closely aligned with the delivery of its objectives. And this is very much where and how we see the role of the Central Bank of Ireland. We see our role as implementing MiCAR in a way that supports its successful delivery of the outcomes that it is seeking to deliver. And of course when we implement any regulatory framework, and in how we supervise, we are outcomes focused. The outcomes we seek at a general level are a financial system which functions well in support of consumers and users and the wider economy. It should be trusted to operate in customers’ interests, to be resilient, and to avoid being used for financial crime and money laundering. These are all things which the public expects of financial sector. And it is not only in their interests but in the interest of the sector itself that they are achieved.Guided by these outcomes, amongst the things that we are focusing on in implementing MiCAR are:Governance and culture: In 2022, we saw the “Crypto Winter” where investors and consumers experienced the negative impacts arising from a lack of good governance and poor culture in certain parts of the sector.Consumer interests. Our revised Consumer Protection Code was launched this week. At its heart is the obligation for regulated financial firms to secure their customer’ interests. This means that at all stages, from the development of a business model and strategy, through product design and marketing, and after sales, firms must ensure that what they are offering and doing is well aligned with their customers’ reasonable expectations and with their interests.Risks to consumers and investors are inherently high in some crypto and related services and crypto markets have been noteworthy for their significant volatility. While representing important progress, MiCAR will not provide the same levels of protection as exists for traditional financial investment products, nor will it enable mitigation of all the risks linked to crypto-assets.Regulators, including ESMA and ourselves, have issued a set of warnings to consumers concerning crypto markets. We have expressed scepticism about business models where profitability is driven from the heavy marketing, offering and distributing of unbacked crypto to retail customers for speculative purposes. Where we see higher inherent conduct and investor protection risks in the products offered to customers and investors, we will have higher expectations of firm’s ability to manage these risks.Crime and fraud. 2025 has already seen an enormous theft event of crypto assets in another part of the world. This underscores the importance of high levels of security, without which the sector will not flourish. More broadly it is essential that there is effective control of the risk of money laundering and other criminal activity.As a regulator, these are the factors influencing our thinking and our approach to regulating this sector. It is our objective to ensure the regulatory environment enables the potential benefits of innovation for consumers, businesses and society to be realised, while ensuring that the risks are effectively managed and mitigated. Consumer and investor protection begins with firms themselves. For the crypto sector to succeed, compliance and a customer centric approach should not be seen as a cost of doing business, but rather, they have the potential to be a competitive advantage. The provision of financial services is about helping others make financial decisions; it is also about the provision of choice for consumers and importantly, the provision of products that are appropriate and suitable for consumers. And the better firms’ own risk management, the better position they are in to understand, calculate and mitigate their risks, therefore strengthening their business model, and their relationship with their customers.MiCAR ReadinessAs the National Competent Authority for MiCAR in Ireland, we are well advanced in our authorisations pathway having regard to the twelve-month transitional period for VASPs to be authorised as CASPs under MiCAR. The Central Bank’s authorisation process is based on clarity, transparency, flexibility and predictability for firms seeking authorisation.  We are committed to delivering the benefits of the new EU regulatory framework for crypto assets. And we have been in continuous engagement with different players in the ecosystem, including of course, with many of you in the room today.To achieve this, we have a well-resourced and expert team handling the CASP authorisation process in a high quality and timely way. This is designed to ensure a good implementation of the new MiCAR regime in Ireland cognisant of business demands and the 12-month transition period. Key to our approach is the idea of a path to success - for firms engaging with the Central Bank on MiCAR Authorisation, and for the regulatory system as we move to the implementation of this new framework.Let me say a little about this. Sonia Weafer, who heads up the CASP Authorisation and Supervision teams, will delve into some of the aspects I mention in more detail in a few minutes.Firstly, our authorisation approach. This is two-phased, with phase 1 comprising of preliminary engagement and a Key Facts Document (KFD) stage and phase 2 comprising of formal authorisation. In order to move as quickly as possible, with maximum flexibility and adaptive engagement for firms, we are heavily frontloading work into phase 1. This will set firms up well for an efficient phase 2 process.We have designed this purposefully as we are extremely cognizant of the tight timelines of MiCAR and the 12 months transitional arrangements. By front-loading into the preliminary engagement and KFD, we are hopeful that we will unpack and resolve any issues, thus making the formal authorisation process smoother and more expeditious. We believe this approach will benefit firms as they engage with us during the authorisation process.I have mentioned the path to success for firms and there are a few considerations that can ensure this.We are dealing with a pipeline of diverse firms. Some are large global firms that have significant resources to hand, including the ability to leverage intra-group structures and entities. Others are smaller firms, perhaps indigenous, perhaps at an earlier stage in their business life cycle. Some are seeking authorisation for the full suite of activities under MiCAR, while some are seeking authorisation for a select few activities. It is a diverse context, and the issues we all are experiencing are diverse as we navigate this new regulation together.In the context of this diversity, I would like to highlight that we recognise the challenges you will be facing. And we want you to succeed, so that we have well-prepared and well-run firms on the other side of the gate. For those of you in the earlier stages of the business life cycle, we recognise that resourcing the lift on MiCAR is significant. Regulation should not be a barrier to innovation and we fully appreciate the need for proportionality in our approach. In this context, what we have found helpful is detailed engagement with you, and signposting from our side, partnered with your own reflections. MICAR is about enabling safe innovation, and I say to small firms here today, we will work with you to meet challenges in a constructive way.If I were to call out specific issues I would like to focus on:Substantive presence: We believe that MiCAR provides a constructive way forward to give legal clarity within a harmonised manner across the EU. We believe that building an EU crypto ecosystem demands commitment. As such, substance is of critical importance. I won’t focus on our lack of appetite for firms that seek to operate on a “brass plate” basis, rather I want to encourage firms to recognise the opportunity of investing appropriately in their EU entity seeking CASP Authorisation and the long term benefits to them of contributing to the development of the EU crypto ecosystem. Outsourcing: Outsourcing is part of every modern business and we recognise its benefits. Leveraging intra-group entities and functions can bring additional strength as well as efficiencies. There are, of course, limits to the level of outsourcing that works. A firm cannot outsource to the extent that it becomes an empty shell or in a manner that means a core activity and the effective accountability for it are moved outside the firm.Alignment with MiCAR and the ESMA Broker Model: A critical point of concern for us is that business models should align with MiCAR, including the ESMA Broker Model Opinion. We have and will continue to push strongly against business models that do not adhere to this, in line with our European counterparts. Clarity on the activities for which you need authorisation: An issue we are finding commonplace is that firms are not clear on their full business model and the activities they need authorisation for. Here we have worked with firms to unpack elements of their proposals, bringing questions to the table to help drive clarity.Governance and Safeguarding: Regardless of the services, the target customer base, or whether the business is retail focused or aimed at institutional clients, governance and safeguarding of client assets are critical considerations for the Central Bank.Finally, we appreciate that MiCAR is new, and that we are all navigating new scenarios. In this regard, we recognise that we have a role in facilitating greater clarity, and I reiterate that we are fully open to constructive discussion with firms to work through challenges. For any firm considering seeking authorisation as a CASP, our website has information on our authorisation process, including the CASP application form and information on our expectations on authorisation.Our Work in EuropeNow I want to mention an aspect that has been fundamental to our approach to MiCAR and its implementation. That is that it is a European framework designed to operate consistently across Europe. Fundamentally, many of its benefits derive from the fact that it is a regulatory framework designed for the large European market.As I have said, at the Central Bank we have played a very active role at European level in the development and implementation of the new framework. We continue to focus a significant part of our effort to work at an EU level. It is of critical importance that together we achieve a harmonised and convergent approach to implementing MiCAR across the EU. Avoidance of divergent approaches or the potential for regulatory arbitrage is a key goal for us, the European Supervisory Authorities (ESAs), and other National Competent Authorities (NCAs). Without this, the MiCAR framework will be undermined and its benefits significantly reduced.We are working as part of both the EBA and ESMA supervisory communities in this regard. ESMA is charged with driving a convergent approach to MiCAR implementation for CASPs and through its Digital Finance Standing Committee (DFSC) is facilitating an impactful and real-time sharing of authorisation experiences and approaches among NCAs. This includes building convergence on whether firm proposals, business models, and their component parts are fully compliant with MiCAR and any ESMA opinions. We are finding this to be a very useful and valuable process. It draws on, and builds on, a similar approach that was adopted during the Brexit-related relocation process. It is delivering real results.Furthermore, we are engaging with other NCA’s on a bilateral basis to unpack specific issues and challenges. This engagement not only allows us to engage with other experts across the EU but also help to drive a convergent approach to applying MiCAR. We want to build a path for success so that we can help deliver positive outcomes for the ecosystem, and our EU engagement is critical for this. The result is that we do not expect to see divergent approaches across the different EU jurisdictions.ConclusionBefore I hand over to Sonia, I want to reiterate the purpose for today. We hope that today will facilitate a conversation, to help you as industry participants, navigate the next steps to success in your MiCAR journey with us here in the Central Bank. We find such engagement very valuable and hope that you do also. We want to see firms move successfully through the authorisation process. We are committed to achieving the benefits of the new EU regulatory framework for crypto assets while ensuring the risks are well managed. To achieve this, firms should focus on good quality submissions, timely engagement with us, full alignment with MiCAR and ESMA Broker Model Opinion, an openness to reflect on feedback, and a clear commitment to their European and Irish presence.Thank you for your attention and I shall now handover to Sonia Weafer.

 Good morning. I am delighted to welcome you to the Central Bank of Ireland today for an engagement on the Markets in Crypto Assets Regulation (MiCAR) and its implementation. And in particular on the path to success in MiCAR authorisation.Recent years have seen tremendous innovations in financial services. Amongst the most notable have been the development of blockchain-based technologies. Over the past five years, the European Commission has implemented its digital finance package. This has included legislation on crypto-assets: the Markets in Crypto Assets Regulation (MiCAR); and on digital resilience in the form of the Digital Operational Resilience Act (DORA). Both of these have recently come in to effect. This digital finance package reflected the EU’s ambition to embrace a digital transition for the benefit of citizens and to help modernise the European economy across sectors. And to turn Europe into a global digital player. In effect, to realise the opportunities within innovation, while managing the risks. This is something to be highly valued and to build on for the further success of the European economy in these challenging times. Times when technological innovation, effectively deployed, will be at the heart of future economic and societal success.At the Central Bank of Ireland, we have been strong supporters of the EU’s ambitions in this area and we have played very active, even leading roles, in the development and implementation of this legislation.MiCAR itself is a very important step forward in the regulation of crypto activities in Europe. It introduces for the first time, what aims to be comprehensive regulatory framework for crypto assets and their operational ecosystem. This morning’s event is an excellent opportunity for us all as participants with different roles in the innovation ecosystem to exchange views. It comes as we navigate an important moment in the MiCAR story: its initial phase of implementation including the first wave of authorisation applications from intending Crypto Asset Service Providers (CASPs). It builds on our last industry wide engagement on MiCAR last July.  A key purpose of our event this morning is to facilitate a conversation. It is designed in particular to provide further support to industry participants who are in the process towards obtaining Central Bank authorisation as MiCAR firms, or who may be thinking about applying for such authorisation.Importance of MiCARMiCAR aims to provide a clear and consistent framework for the regulation of crypto assets and related services across the EU. It also sets the benchmark at a global level, contributing to informing the work of other jurisdictions in their thinking and approaches to setting regulatory standards for crypto assets and related services. Delivering on MiCAR, in a timely outcomes-focused way, is a key focus for the Bank and supervisory authorities across the EU. For our part, we want the future financial system to deliver for consumers, investors, business and the wider economy.  A well-functioning and robust crypto sector that delivers on the promise of innovative products, can be part of that. Ireland as a financial centre could become an important location for crypto asset service providers, as it has been for virtual asset service providers (VASPs). This reflects our existing strengths in both the areas of digital technology and financial services. It reflects broader aspects such as our commitment to Europe, and can I also say, our reputation for, and commitment to, strong, well-designed and outcomes-focused financial regulation.The Regulatory PerspectiveI am often asked: how does the Central Bank of Ireland think about MiCAR and cryptoassets? When you stand back at the end of the day what is your perspective on this new area of regulated financial service? Let me take a moment to share some thoughts on this.Firstly, innovation, including technological innovation, is both very important and very hard. It may be amongst the most difficult things to do: to develop a new idea, to bring it to commercial viability, and then to scale it to being an economic success story. We only have to look at Mario Draghi’s report on EU competitiveness published in September 2024 to know both how important innovation will be to the future of European economic success and the challenges we need to overcome if we are to create the conditions in which this can happen.As I have mentioned crypto technology, the blockchain, distributed ledger, tokenisation, Web3 these are a set of related innovations, which, when we look back, are likely to have been at the heart of a very important wave of technological development. Both in themselves, and in what they will lead to, they represent a significant crossing of the technological frontier.The introduction of MiCAR places Europe in a very good position to benefit from this broad area of technological innovation. This of course requires that MiCAR is implemented well and in a way that is closely aligned with the delivery of its objectives. And this is very much where and how we see the role of the Central Bank of Ireland. We see our role as implementing MiCAR in a way that supports its successful delivery of the outcomes that it is seeking to deliver. And of course when we implement any regulatory framework, and in how we supervise, we are outcomes focused. The outcomes we seek at a general level are a financial system which functions well in support of consumers and users and the wider economy. It should be trusted to operate in customers’ interests, to be resilient, and to avoid being used for financial crime and money laundering. These are all things which the public expects of financial sector. And it is not only in their interests but in the interest of the sector itself that they are achieved.Guided by these outcomes, amongst the things that we are focusing on in implementing MiCAR are:Governance and culture: In 2022, we saw the “Crypto Winter” where investors and consumers experienced the negative impacts arising from a lack of good governance and poor culture in certain parts of the sector.Consumer interests. Our revised Consumer Protection Code was launched this week. At its heart is the obligation for regulated financial firms to secure their customer’ interests. This means that at all stages, from the development of a business model and strategy, through product design and marketing, and after sales, firms must ensure that what they are offering and doing is well aligned with their customers’ reasonable expectations and with their interests.Risks to consumers and investors are inherently high in some crypto and related services and crypto markets have been noteworthy for their significant volatility. While representing important progress, MiCAR will not provide the same levels of protection as exists for traditional financial investment products, nor will it enable mitigation of all the risks linked to crypto-assets.Regulators, including ESMA and ourselves, have issued a set of warnings to consumers concerning crypto markets. We have expressed scepticism about business models where profitability is driven from the heavy marketing, offering and distributing of unbacked crypto to retail customers for speculative purposes. Where we see higher inherent conduct and investor protection risks in the products offered to customers and investors, we will have higher expectations of firm’s ability to manage these risks.Crime and fraud. 2025 has already seen an enormous theft event of crypto assets in another part of the world. This underscores the importance of high levels of security, without which the sector will not flourish. More broadly it is essential that there is effective control of the risk of money laundering and other criminal activity.As a regulator, these are the factors influencing our thinking and our approach to regulating this sector. It is our objective to ensure the regulatory environment enables the potential benefits of innovation for consumers, businesses and society to be realised, while ensuring that the risks are effectively managed and mitigated. Consumer and investor protection begins with firms themselves. For the crypto sector to succeed, compliance and a customer centric approach should not be seen as a cost of doing business, but rather, they have the potential to be a competitive advantage. The provision of financial services is about helping others make financial decisions; it is also about the provision of choice for consumers and importantly, the provision of products that are appropriate and suitable for consumers. And the better firms’ own risk management, the better position they are in to understand, calculate and mitigate their risks, therefore strengthening their business model, and their relationship with their customers.MiCAR ReadinessAs the National Competent Authority for MiCAR in Ireland, we are well advanced in our authorisations pathway having regard to the twelve-month transitional period for VASPs to be authorised as CASPs under MiCAR. The Central Bank’s authorisation process is based on clarity, transparency, flexibility and predictability for firms seeking authorisation.  We are committed to delivering the benefits of the new EU regulatory framework for crypto assets. And we have been in continuous engagement with different players in the ecosystem, including of course, with many of you in the room today.To achieve this, we have a well-resourced and expert team handling the CASP authorisation process in a high quality and timely way. This is designed to ensure a good implementation of the new MiCAR regime in Ireland cognisant of business demands and the 12-month transition period. Key to our approach is the idea of a path to success - for firms engaging with the Central Bank on MiCAR Authorisation, and for the regulatory system as we move to the implementation of this new framework.Let me say a little about this. Sonia Weafer, who heads up the CASP Authorisation and Supervision teams, will delve into some of the aspects I mention in more detail in a few minutes.Firstly, our authorisation approach. This is two-phased, with phase 1 comprising of preliminary engagement and a Key Facts Document (KFD) stage and phase 2 comprising of formal authorisation. In order to move as quickly as possible, with maximum flexibility and adaptive engagement for firms, we are heavily frontloading work into phase 1. This will set firms up well for an efficient phase 2 process.We have designed this purposefully as we are extremely cognizant of the tight timelines of MiCAR and the 12 months transitional arrangements. By front-loading into the preliminary engagement and KFD, we are hopeful that we will unpack and resolve any issues, thus making the formal authorisation process smoother and more expeditious. We believe this approach will benefit firms as they engage with us during the authorisation process.I have mentioned the path to success for firms and there are a few considerations that can ensure this.We are dealing with a pipeline of diverse firms. Some are large global firms that have significant resources to hand, including the ability to leverage intra-group structures and entities. Others are smaller firms, perhaps indigenous, perhaps at an earlier stage in their business life cycle. Some are seeking authorisation for the full suite of activities under MiCAR, while some are seeking authorisation for a select few activities. It is a diverse context, and the issues we all are experiencing are diverse as we navigate this new regulation together.In the context of this diversity, I would like to highlight that we recognise the challenges you will be facing. And we want you to succeed, so that we have well-prepared and well-run firms on the other side of the gate. For those of you in the earlier stages of the business life cycle, we recognise that resourcing the lift on MiCAR is significant. Regulation should not be a barrier to innovation and we fully appreciate the need for proportionality in our approach. In this context, what we have found helpful is detailed engagement with you, and signposting from our side, partnered with your own reflections. MICAR is about enabling safe innovation, and I say to small firms here today, we will work with you to meet challenges in a constructive way.If I were to call out specific issues I would like to focus on:Substantive presence: We believe that MiCAR provides a constructive way forward to give legal clarity within a harmonised manner across the EU. We believe that building an EU crypto ecosystem demands commitment. As such, substance is of critical importance. I won’t focus on our lack of appetite for firms that seek to operate on a “brass plate” basis, rather I want to encourage firms to recognise the opportunity of investing appropriately in their EU entity seeking CASP Authorisation and the long term benefits to them of contributing to the development of the EU crypto ecosystem. Outsourcing: Outsourcing is part of every modern business and we recognise its benefits. Leveraging intra-group entities and functions can bring additional strength as well as efficiencies. There are, of course, limits to the level of outsourcing that works. A firm cannot outsource to the extent that it becomes an empty shell or in a manner that means a core activity and the effective accountability for it are moved outside the firm.Alignment with MiCAR and the ESMA Broker Model: A critical point of concern for us is that business models should align with MiCAR, including the ESMA Broker Model Opinion. We have and will continue to push strongly against business models that do not adhere to this, in line with our European counterparts. Clarity on the activities for which you need authorisation: An issue we are finding commonplace is that firms are not clear on their full business model and the activities they need authorisation for. Here we have worked with firms to unpack elements of their proposals, bringing questions to the table to help drive clarity.Governance and Safeguarding: Regardless of the services, the target customer base, or whether the business is retail focused or aimed at institutional clients, governance and safeguarding of client assets are critical considerations for the Central Bank.Finally, we appreciate that MiCAR is new, and that we are all navigating new scenarios. In this regard, we recognise that we have a role in facilitating greater clarity, and I reiterate that we are fully open to constructive discussion with firms to work through challenges. For any firm considering seeking authorisation as a CASP, our website has information on our authorisation process, including the CASP application form and information on our expectations on authorisation.Our Work in EuropeNow I want to mention an aspect that has been fundamental to our approach to MiCAR and its implementation. That is that it is a European framework designed to operate consistently across Europe. Fundamentally, many of its benefits derive from the fact that it is a regulatory framework designed for the large European market.As I have said, at the Central Bank we have played a very active role at European level in the development and implementation of the new framework. We continue to focus a significant part of our effort to work at an EU level. It is of critical importance that together we achieve a harmonised and convergent approach to implementing MiCAR across the EU. Avoidance of divergent approaches or the potential for regulatory arbitrage is a key goal for us, the European Supervisory Authorities (ESAs), and other National Competent Authorities (NCAs). Without this, the MiCAR framework will be undermined and its benefits significantly reduced.We are working as part of both the EBA and ESMA supervisory communities in this regard. ESMA is charged with driving a convergent approach to MiCAR implementation for CASPs and through its Digital Finance Standing Committee (DFSC) is facilitating an impactful and real-time sharing of authorisation experiences and approaches among NCAs. This includes building convergence on whether firm proposals, business models, and their component parts are fully compliant with MiCAR and any ESMA opinions. We are finding this to be a very useful and valuable process. It draws on, and builds on, a similar approach that was adopted during the Brexit-related relocation process. It is delivering real results.Furthermore, we are engaging with other NCA’s on a bilateral basis to unpack specific issues and challenges. This engagement not only allows us to engage with other experts across the EU but also help to drive a convergent approach to applying MiCAR. We want to build a path for success so that we can help deliver positive outcomes for the ecosystem, and our EU engagement is critical for this. The result is that we do not expect to see divergent approaches across the different EU jurisdictions.ConclusionBefore I hand over to Sonia, I want to reiterate the purpose for today. We hope that today will facilitate a conversation, to help you as industry participants, navigate the next steps to success in your MiCAR journey with us here in the Central Bank. We find such engagement very valuable and hope that you do also. We want to see firms move successfully through the authorisation process. We are committed to achieving the benefits of the new EU regulatory framework for crypto assets while ensuring the risks are well managed. To achieve this, firms should focus on good quality submissions, timely engagement with us, full alignment with MiCAR and ESMA Broker Model Opinion, an openness to reflect on feedback, and a clear commitment to their European and Irish presence.Thank you for your attention and I shall now handover to Sonia Weafer.

 Good morning. I am delighted to welcome you to the Central Bank of Ireland today for an engagement on the Markets in Crypto Assets Regulation (MiCAR) and its implementation. And in particular on the path to success in MiCAR authorisation.Recent years have seen tremendous innovations in financial services. Amongst the most notable have been the development of blockchain-based technologies. Over the past five years, the European Commission has implemented its digital finance package. This has included legislation on crypto-assets: the Markets in Crypto Assets Regulation (MiCAR); and on digital resilience in the form of the Digital Operational Resilience Act (DORA). Both of these have recently come in to effect. This digital finance package reflected the EU’s ambition to embrace a digital transition for the benefit of citizens and to help modernise the European economy across sectors. And to turn Europe into a global digital player. In effect, to realise the opportunities within innovation, while managing the risks. This is something to be highly valued and to build on for the further success of the European economy in these challenging times. Times when technological innovation, effectively deployed, will be at the heart of future economic and societal success.At the Central Bank of Ireland, we have been strong supporters of the EU’s ambitions in this area and we have played very active, even leading roles, in the development and implementation of this legislation.MiCAR itself is a very important step forward in the regulation of crypto activities in Europe. It introduces for the first time, what aims to be comprehensive regulatory framework for crypto assets and their operational ecosystem. This morning’s event is an excellent opportunity for us all as participants with different roles in the innovation ecosystem to exchange views. It comes as we navigate an important moment in the MiCAR story: its initial phase of implementation including the first wave of authorisation applications from intending Crypto Asset Service Providers (CASPs). It builds on our last industry wide engagement on MiCAR last July.  A key purpose of our event this morning is to facilitate a conversation. It is designed in particular to provide further support to industry participants who are in the process towards obtaining Central Bank authorisation as MiCAR firms, or who may be thinking about applying for such authorisation.Importance of MiCARMiCAR aims to provide a clear and consistent framework for the regulation of crypto assets and related services across the EU. It also sets the benchmark at a global level, contributing to informing the work of other jurisdictions in their thinking and approaches to setting regulatory standards for crypto assets and related services. Delivering on MiCAR, in a timely outcomes-focused way, is a key focus for the Bank and supervisory authorities across the EU. For our part, we want the future financial system to deliver for consumers, investors, business and the wider economy.  A well-functioning and robust crypto sector that delivers on the promise of innovative products, can be part of that. Ireland as a financial centre could become an important location for crypto asset service providers, as it has been for virtual asset service providers (VASPs). This reflects our existing strengths in both the areas of digital technology and financial services. It reflects broader aspects such as our commitment to Europe, and can I also say, our reputation for, and commitment to, strong, well-designed and outcomes-focused financial regulation.The Regulatory PerspectiveI am often asked: how does the Central Bank of Ireland think about MiCAR and cryptoassets? When you stand back at the end of the day what is your perspective on this new area of regulated financial service? Let me take a moment to share some thoughts on this.Firstly, innovation, including technological innovation, is both very important and very hard. It may be amongst the most difficult things to do: to develop a new idea, to bring it to commercial viability, and then to scale it to being an economic success story. We only have to look at Mario Draghi’s report on EU competitiveness published in September 2024 to know both how important innovation will be to the future of European economic success and the challenges we need to overcome if we are to create the conditions in which this can happen.As I have mentioned crypto technology, the blockchain, distributed ledger, tokenisation, Web3 these are a set of related innovations, which, when we look back, are likely to have been at the heart of a very important wave of technological development. Both in themselves, and in what they will lead to, they represent a significant crossing of the technological frontier.The introduction of MiCAR places Europe in a very good position to benefit from this broad area of technological innovation. This of course requires that MiCAR is implemented well and in a way that is closely aligned with the delivery of its objectives. And this is very much where and how we see the role of the Central Bank of Ireland. We see our role as implementing MiCAR in a way that supports its successful delivery of the outcomes that it is seeking to deliver. And of course when we implement any regulatory framework, and in how we supervise, we are outcomes focused. The outcomes we seek at a general level are a financial system which functions well in support of consumers and users and the wider economy. It should be trusted to operate in customers’ interests, to be resilient, and to avoid being used for financial crime and money laundering. These are all things which the public expects of financial sector. And it is not only in their interests but in the interest of the sector itself that they are achieved.Guided by these outcomes, amongst the things that we are focusing on in implementing MiCAR are:Governance and culture: In 2022, we saw the “Crypto Winter” where investors and consumers experienced the negative impacts arising from a lack of good governance and poor culture in certain parts of the sector.Consumer interests. Our revised Consumer Protection Code was launched this week. At its heart is the obligation for regulated financial firms to secure their customer’ interests. This means that at all stages, from the development of a business model and strategy, through product design and marketing, and after sales, firms must ensure that what they are offering and doing is well aligned with their customers’ reasonable expectations and with their interests.Risks to consumers and investors are inherently high in some crypto and related services and crypto markets have been noteworthy for their significant volatility. While representing important progress, MiCAR will not provide the same levels of protection as exists for traditional financial investment products, nor will it enable mitigation of all the risks linked to crypto-assets.Regulators, including ESMA and ourselves, have issued a set of warnings to consumers concerning crypto markets. We have expressed scepticism about business models where profitability is driven from the heavy marketing, offering and distributing of unbacked crypto to retail customers for speculative purposes. Where we see higher inherent conduct and investor protection risks in the products offered to customers and investors, we will have higher expectations of firm’s ability to manage these risks.Crime and fraud. 2025 has already seen an enormous theft event of crypto assets in another part of the world. This underscores the importance of high levels of security, without which the sector will not flourish. More broadly it is essential that there is effective control of the risk of money laundering and other criminal activity.As a regulator, these are the factors influencing our thinking and our approach to regulating this sector. It is our objective to ensure the regulatory environment enables the potential benefits of innovation for consumers, businesses and society to be realised, while ensuring that the risks are effectively managed and mitigated. Consumer and investor protection begins with firms themselves. For the crypto sector to succeed, compliance and a customer centric approach should not be seen as a cost of doing business, but rather, they have the potential to be a competitive advantage. The provision of financial services is about helping others make financial decisions; it is also about the provision of choice for consumers and importantly, the provision of products that are appropriate and suitable for consumers. And the better firms’ own risk management, the better position they are in to understand, calculate and mitigate their risks, therefore strengthening their business model, and their relationship with their customers.MiCAR ReadinessAs the National Competent Authority for MiCAR in Ireland, we are well advanced in our authorisations pathway having regard to the twelve-month transitional period for VASPs to be authorised as CASPs under MiCAR. The Central Bank’s authorisation process is based on clarity, transparency, flexibility and predictability for firms seeking authorisation.  We are committed to delivering the benefits of the new EU regulatory framework for crypto assets. And we have been in continuous engagement with different players in the ecosystem, including of course, with many of you in the room today.To achieve this, we have a well-resourced and expert team handling the CASP authorisation process in a high quality and timely way. This is designed to ensure a good implementation of the new MiCAR regime in Ireland cognisant of business demands and the 12-month transition period. Key to our approach is the idea of a path to success - for firms engaging with the Central Bank on MiCAR Authorisation, and for the regulatory system as we move to the implementation of this new framework.Let me say a little about this. Sonia Weafer, who heads up the CASP Authorisation and Supervision teams, will delve into some of the aspects I mention in more detail in a few minutes.Firstly, our authorisation approach. This is two-phased, with phase 1 comprising of preliminary engagement and a Key Facts Document (KFD) stage and phase 2 comprising of formal authorisation. In order to move as quickly as possible, with maximum flexibility and adaptive engagement for firms, we are heavily frontloading work into phase 1. This will set firms up well for an efficient phase 2 process.We have designed this purposefully as we are extremely cognizant of the tight timelines of MiCAR and the 12 months transitional arrangements. By front-loading into the preliminary engagement and KFD, we are hopeful that we will unpack and resolve any issues, thus making the formal authorisation process smoother and more expeditious. We believe this approach will benefit firms as they engage with us during the authorisation process.I have mentioned the path to success for firms and there are a few considerations that can ensure this.We are dealing with a pipeline of diverse firms. Some are large global firms that have significant resources to hand, including the ability to leverage intra-group structures and entities. Others are smaller firms, perhaps indigenous, perhaps at an earlier stage in their business life cycle. Some are seeking authorisation for the full suite of activities under MiCAR, while some are seeking authorisation for a select few activities. It is a diverse context, and the issues we all are experiencing are diverse as we navigate this new regulation together.In the context of this diversity, I would like to highlight that we recognise the challenges you will be facing. And we want you to succeed, so that we have well-prepared and well-run firms on the other side of the gate. For those of you in the earlier stages of the business life cycle, we recognise that resourcing the lift on MiCAR is significant. Regulation should not be a barrier to innovation and we fully appreciate the need for proportionality in our approach. In this context, what we have found helpful is detailed engagement with you, and signposting from our side, partnered with your own reflections. MICAR is about enabling safe innovation, and I say to small firms here today, we will work with you to meet challenges in a constructive way.If I were to call out specific issues I would like to focus on:Substantive presence: We believe that MiCAR provides a constructive way forward to give legal clarity within a harmonised manner across the EU. We believe that building an EU crypto ecosystem demands commitment. As such, substance is of critical importance. I won’t focus on our lack of appetite for firms that seek to operate on a “brass plate” basis, rather I want to encourage firms to recognise the opportunity of investing appropriately in their EU entity seeking CASP Authorisation and the long term benefits to them of contributing to the development of the EU crypto ecosystem. Outsourcing: Outsourcing is part of every modern business and we recognise its benefits. Leveraging intra-group entities and functions can bring additional strength as well as efficiencies. There are, of course, limits to the level of outsourcing that works. A firm cannot outsource to the extent that it becomes an empty shell or in a manner that means a core activity and the effective accountability for it are moved outside the firm.Alignment with MiCAR and the ESMA Broker Model: A critical point of concern for us is that business models should align with MiCAR, including the ESMA Broker Model Opinion. We have and will continue to push strongly against business models that do not adhere to this, in line with our European counterparts. Clarity on the activities for which you need authorisation: An issue we are finding commonplace is that firms are not clear on their full business model and the activities they need authorisation for. Here we have worked with firms to unpack elements of their proposals, bringing questions to the table to help drive clarity.Governance and Safeguarding: Regardless of the services, the target customer base, or whether the business is retail focused or aimed at institutional clients, governance and safeguarding of client assets are critical considerations for the Central Bank.Finally, we appreciate that MiCAR is new, and that we are all navigating new scenarios. In this regard, we recognise that we have a role in facilitating greater clarity, and I reiterate that we are fully open to constructive discussion with firms to work through challenges. For any firm considering seeking authorisation as a CASP, our website has information on our authorisation process, including the CASP application form and information on our expectations on authorisation.Our Work in EuropeNow I want to mention an aspect that has been fundamental to our approach to MiCAR and its implementation. That is that it is a European framework designed to operate consistently across Europe. Fundamentally, many of its benefits derive from the fact that it is a regulatory framework designed for the large European market.As I have said, at the Central Bank we have played a very active role at European level in the development and implementation of the new framework. We continue to focus a significant part of our effort to work at an EU level. It is of critical importance that together we achieve a harmonised and convergent approach to implementing MiCAR across the EU. Avoidance of divergent approaches or the potential for regulatory arbitrage is a key goal for us, the European Supervisory Authorities (ESAs), and other National Competent Authorities (NCAs). Without this, the MiCAR framework will be undermined and its benefits significantly reduced.We are working as part of both the EBA and ESMA supervisory communities in this regard. ESMA is charged with driving a convergent approach to MiCAR implementation for CASPs and through its Digital Finance Standing Committee (DFSC) is facilitating an impactful and real-time sharing of authorisation experiences and approaches among NCAs. This includes building convergence on whether firm proposals, business models, and their component parts are fully compliant with MiCAR and any ESMA opinions. We are finding this to be a very useful and valuable process. It draws on, and builds on, a similar approach that was adopted during the Brexit-related relocation process. It is delivering real results.Furthermore, we are engaging with other NCA’s on a bilateral basis to unpack specific issues and challenges. This engagement not only allows us to engage with other experts across the EU but also help to drive a convergent approach to applying MiCAR. We want to build a path for success so that we can help deliver positive outcomes for the ecosystem, and our EU engagement is critical for this. The result is that we do not expect to see divergent approaches across the different EU jurisdictions.ConclusionBefore I hand over to Sonia, I want to reiterate the purpose for today. We hope that today will facilitate a conversation, to help you as industry participants, navigate the next steps to success in your MiCAR journey with us here in the Central Bank. We find such engagement very valuable and hope that you do also. We want to see firms move successfully through the authorisation process. We are committed to achieving the benefits of the new EU regulatory framework for crypto assets while ensuring the risks are well managed. To achieve this, firms should focus on good quality submissions, timely engagement with us, full alignment with MiCAR and ESMA Broker Model Opinion, an openness to reflect on feedback, and a clear commitment to their European and Irish presence.Thank you for your attention and I shall now handover to Sonia Weafer.

 Good morning. I am delighted to welcome you to the Central Bank of Ireland today for an engagement on the Markets in Crypto Assets Regulation (MiCAR) and its implementation. And in particular on the path to success in MiCAR authorisation.Recent years have seen tremendous innovations in financial services. Amongst the most notable have been the development of blockchain-based technologies. Over the past five years, the European Commission has implemented its digital finance package. This has included legislation on crypto-assets: the Markets in Crypto Assets Regulation (MiCAR); and on digital resilience in the form of the Digital Operational Resilience Act (DORA). Both of these have recently come in to effect. This digital finance package reflected the EU’s ambition to embrace a digital transition for the benefit of citizens and to help modernise the European economy across sectors. And to turn Europe into a global digital player. In effect, to realise the opportunities within innovation, while managing the risks. This is something to be highly valued and to build on for the further success of the European economy in these challenging times. Times when technological innovation, effectively deployed, will be at the heart of future economic and societal success.At the Central Bank of Ireland, we have been strong supporters of the EU’s ambitions in this area and we have played very active, even leading roles, in the development and implementation of this legislation.MiCAR itself is a very important step forward in the regulation of crypto activities in Europe. It introduces for the first time, what aims to be comprehensive regulatory framework for crypto assets and their operational ecosystem. This morning’s event is an excellent opportunity for us all as participants with different roles in the innovation ecosystem to exchange views. It comes as we navigate an important moment in the MiCAR story: its initial phase of implementation including the first wave of authorisation applications from intending Crypto Asset Service Providers (CASPs). It builds on our last industry wide engagement on MiCAR last July.  A key purpose of our event this morning is to facilitate a conversation. It is designed in particular to provide further support to industry participants who are in the process towards obtaining Central Bank authorisation as MiCAR firms, or who may be thinking about applying for such authorisation.Importance of MiCARMiCAR aims to provide a clear and consistent framework for the regulation of crypto assets and related services across the EU. It also sets the benchmark at a global level, contributing to informing the work of other jurisdictions in their thinking and approaches to setting regulatory standards for crypto assets and related services. Delivering on MiCAR, in a timely outcomes-focused way, is a key focus for the Bank and supervisory authorities across the EU. For our part, we want the future financial system to deliver for consumers, investors, business and the wider economy.  A well-functioning and robust crypto sector that delivers on the promise of innovative products, can be part of that. Ireland as a financial centre could become an important location for crypto asset service providers, as it has been for virtual asset service providers (VASPs). This reflects our existing strengths in both the areas of digital technology and financial services. It reflects broader aspects such as our commitment to Europe, and can I also say, our reputation for, and commitment to, strong, well-designed and outcomes-focused financial regulation.The Regulatory PerspectiveI am often asked: how does the Central Bank of Ireland think about MiCAR and cryptoassets? When you stand back at the end of the day what is your perspective on this new area of regulated financial service? Let me take a moment to share some thoughts on this.Firstly, innovation, including technological innovation, is both very important and very hard. It may be amongst the most difficult things to do: to develop a new idea, to bring it to commercial viability, and then to scale it to being an economic success story. We only have to look at Mario Draghi’s report on EU competitiveness published in September 2024 to know both how important innovation will be to the future of European economic success and the challenges we need to overcome if we are to create the conditions in which this can happen.As I have mentioned crypto technology, the blockchain, distributed ledger, tokenisation, Web3 these are a set of related innovations, which, when we look back, are likely to have been at the heart of a very important wave of technological development. Both in themselves, and in what they will lead to, they represent a significant crossing of the technological frontier.The introduction of MiCAR places Europe in a very good position to benefit from this broad area of technological innovation. This of course requires that MiCAR is implemented well and in a way that is closely aligned with the delivery of its objectives. And this is very much where and how we see the role of the Central Bank of Ireland. We see our role as implementing MiCAR in a way that supports its successful delivery of the outcomes that it is seeking to deliver. And of course when we implement any regulatory framework, and in how we supervise, we are outcomes focused. The outcomes we seek at a general level are a financial system which functions well in support of consumers and users and the wider economy. It should be trusted to operate in customers’ interests, to be resilient, and to avoid being used for financial crime and money laundering. These are all things which the public expects of financial sector. And it is not only in their interests but in the interest of the sector itself that they are achieved.Guided by these outcomes, amongst the things that we are focusing on in implementing MiCAR are:Governance and culture: In 2022, we saw the “Crypto Winter” where investors and consumers experienced the negative impacts arising from a lack of good governance and poor culture in certain parts of the sector.Consumer interests. Our revised Consumer Protection Code was launched this week. At its heart is the obligation for regulated financial firms to secure their customer’ interests. This means that at all stages, from the development of a business model and strategy, through product design and marketing, and after sales, firms must ensure that what they are offering and doing is well aligned with their customers’ reasonable expectations and with their interests.Risks to consumers and investors are inherently high in some crypto and related services and crypto markets have been noteworthy for their significant volatility. While representing important progress, MiCAR will not provide the same levels of protection as exists for traditional financial investment products, nor will it enable mitigation of all the risks linked to crypto-assets.Regulators, including ESMA and ourselves, have issued a set of warnings to consumers concerning crypto markets. We have expressed scepticism about business models where profitability is driven from the heavy marketing, offering and distributing of unbacked crypto to retail customers for speculative purposes. Where we see higher inherent conduct and investor protection risks in the products offered to customers and investors, we will have higher expectations of firm’s ability to manage these risks.Crime and fraud. 2025 has already seen an enormous theft event of crypto assets in another part of the world. This underscores the importance of high levels of security, without which the sector will not flourish. More broadly it is essential that there is effective control of the risk of money laundering and other criminal activity.As a regulator, these are the factors influencing our thinking and our approach to regulating this sector. It is our objective to ensure the regulatory environment enables the potential benefits of innovation for consumers, businesses and society to be realised, while ensuring that the risks are effectively managed and mitigated. Consumer and investor protection begins with firms themselves. For the crypto sector to succeed, compliance and a customer centric approach should not be seen as a cost of doing business, but rather, they have the potential to be a competitive advantage. The provision of financial services is about helping others make financial decisions; it is also about the provision of choice for consumers and importantly, the provision of products that are appropriate and suitable for consumers. And the better firms’ own risk management, the better position they are in to understand, calculate and mitigate their risks, therefore strengthening their business model, and their relationship with their customers.MiCAR ReadinessAs the National Competent Authority for MiCAR in Ireland, we are well advanced in our authorisations pathway having regard to the twelve-month transitional period for VASPs to be authorised as CASPs under MiCAR. The Central Bank’s authorisation process is based on clarity, transparency, flexibility and predictability for firms seeking authorisation.  We are committed to delivering the benefits of the new EU regulatory framework for crypto assets. And we have been in continuous engagement with different players in the ecosystem, including of course, with many of you in the room today.To achieve this, we have a well-resourced and expert team handling the CASP authorisation process in a high quality and timely way. This is designed to ensure a good implementation of the new MiCAR regime in Ireland cognisant of business demands and the 12-month transition period. Key to our approach is the idea of a path to success - for firms engaging with the Central Bank on MiCAR Authorisation, and for the regulatory system as we move to the implementation of this new framework.Let me say a little about this. Sonia Weafer, who heads up the CASP Authorisation and Supervision teams, will delve into some of the aspects I mention in more detail in a few minutes.Firstly, our authorisation approach. This is two-phased, with phase 1 comprising of preliminary engagement and a Key Facts Document (KFD) stage and phase 2 comprising of formal authorisation. In order to move as quickly as possible, with maximum flexibility and adaptive engagement for firms, we are heavily frontloading work into phase 1. This will set firms up well for an efficient phase 2 process.We have designed this purposefully as we are extremely cognizant of the tight timelines of MiCAR and the 12 months transitional arrangements. By front-loading into the preliminary engagement and KFD, we are hopeful that we will unpack and resolve any issues, thus making the formal authorisation process smoother and more expeditious. We believe this approach will benefit firms as they engage with us during the authorisation process.I have mentioned the path to success for firms and there are a few considerations that can ensure this.We are dealing with a pipeline of diverse firms. Some are large global firms that have significant resources to hand, including the ability to leverage intra-group structures and entities. Others are smaller firms, perhaps indigenous, perhaps at an earlier stage in their business life cycle. Some are seeking authorisation for the full suite of activities under MiCAR, while some are seeking authorisation for a select few activities. It is a diverse context, and the issues we all are experiencing are diverse as we navigate this new regulation together.In the context of this diversity, I would like to highlight that we recognise the challenges you will be facing. And we want you to succeed, so that we have well-prepared and well-run firms on the other side of the gate. For those of you in the earlier stages of the business life cycle, we recognise that resourcing the lift on MiCAR is significant. Regulation should not be a barrier to innovation and we fully appreciate the need for proportionality in our approach. In this context, what we have found helpful is detailed engagement with you, and signposting from our side, partnered with your own reflections. MICAR is about enabling safe innovation, and I say to small firms here today, we will work with you to meet challenges in a constructive way.If I were to call out specific issues I would like to focus on:Substantive presence: We believe that MiCAR provides a constructive way forward to give legal clarity within a harmonised manner across the EU. We believe that building an EU crypto ecosystem demands commitment. As such, substance is of critical importance. I won’t focus on our lack of appetite for firms that seek to operate on a “brass plate” basis, rather I want to encourage firms to recognise the opportunity of investing appropriately in their EU entity seeking CASP Authorisation and the long term benefits to them of contributing to the development of the EU crypto ecosystem. Outsourcing: Outsourcing is part of every modern business and we recognise its benefits. Leveraging intra-group entities and functions can bring additional strength as well as efficiencies. There are, of course, limits to the level of outsourcing that works. A firm cannot outsource to the extent that it becomes an empty shell or in a manner that means a core activity and the effective accountability for it are moved outside the firm.Alignment with MiCAR and the ESMA Broker Model: A critical point of concern for us is that business models should align with MiCAR, including the ESMA Broker Model Opinion. We have and will continue to push strongly against business models that do not adhere to this, in line with our European counterparts. Clarity on the activities for which you need authorisation: An issue we are finding commonplace is that firms are not clear on their full business model and the activities they need authorisation for. Here we have worked with firms to unpack elements of their proposals, bringing questions to the table to help drive clarity.Governance and Safeguarding: Regardless of the services, the target customer base, or whether the business is retail focused or aimed at institutional clients, governance and safeguarding of client assets are critical considerations for the Central Bank.Finally, we appreciate that MiCAR is new, and that we are all navigating new scenarios. In this regard, we recognise that we have a role in facilitating greater clarity, and I reiterate that we are fully open to constructive discussion with firms to work through challenges. For any firm considering seeking authorisation as a CASP, our website has information on our authorisation process, including the CASP application form and information on our expectations on authorisation.Our Work in EuropeNow I want to mention an aspect that has been fundamental to our approach to MiCAR and its implementation. That is that it is a European framework designed to operate consistently across Europe. Fundamentally, many of its benefits derive from the fact that it is a regulatory framework designed for the large European market.As I have said, at the Central Bank we have played a very active role at European level in the development and implementation of the new framework. We continue to focus a significant part of our effort to work at an EU level. It is of critical importance that together we achieve a harmonised and convergent approach to implementing MiCAR across the EU. Avoidance of divergent approaches or the potential for regulatory arbitrage is a key goal for us, the European Supervisory Authorities (ESAs), and other National Competent Authorities (NCAs). Without this, the MiCAR framework will be undermined and its benefits significantly reduced.We are working as part of both the EBA and ESMA supervisory communities in this regard. ESMA is charged with driving a convergent approach to MiCAR implementation for CASPs and through its Digital Finance Standing Committee (DFSC) is facilitating an impactful and real-time sharing of authorisation experiences and approaches among NCAs. This includes building convergence on whether firm proposals, business models, and their component parts are fully compliant with MiCAR and any ESMA opinions. We are finding this to be a very useful and valuable process. It draws on, and builds on, a similar approach that was adopted during the Brexit-related relocation process. It is delivering real results.Furthermore, we are engaging with other NCA’s on a bilateral basis to unpack specific issues and challenges. This engagement not only allows us to engage with other experts across the EU but also help to drive a convergent approach to applying MiCAR. We want to build a path for success so that we can help deliver positive outcomes for the ecosystem, and our EU engagement is critical for this. The result is that we do not expect to see divergent approaches across the different EU jurisdictions.ConclusionBefore I hand over to Sonia, I want to reiterate the purpose for today. We hope that today will facilitate a conversation, to help you as industry participants, navigate the next steps to success in your MiCAR journey with us here in the Central Bank. We find such engagement very valuable and hope that you do also. We want to see firms move successfully through the authorisation process. We are committed to achieving the benefits of the new EU regulatory framework for crypto assets while ensuring the risks are well managed. To achieve this, firms should focus on good quality submissions, timely engagement with us, full alignment with MiCAR and ESMA Broker Model Opinion, an openness to reflect on feedback, and a clear commitment to their European and Irish presence.Thank you for your attention and I shall now handover to Sonia Weafer.

Good morning everyone, I would like to welcome you all to the Central Bank today.Welcome in particular to Robert Troy TD, Minister of State, as well as Brian McHugh, Chair of the Competition and Consumer Protection Commission (CCPC), and Liam Sloyan the Financial Services and Pensions Ombudsman (FSPO).We are also joined by stakeholders from across the financial system who, over the last three years, have supported and informed the development of the revised Consumer Protection Code which we are publishing today. Thank you all for coming and thank you for your commitment to dialogue and engagement to inform the new Code. You have made an important contribution to the new Code.Before turning to the Code itself, let me say a few words about consumer protection more generally and our approach here in the Central Bank of Ireland.Our mission is to serve the public interest by maintaining monetary and financial stability while ensuring that the financial system operates in the best interests of consumers and the wider economy.  We are guided by the objective set out in our founding legislation which stated that the Central Bank’s “constant and predominant aim shall be the welfare of the people as a whole”.  Everything that we do is aimed at serving the public interest and protecting consumers of financial services, whether it is through the consumer protection code, the mortgage measures, our monetary policy actions, our oversight of the payments system, or our supervision of individual firms. Over the last decade, we have, along with the CCPC and FSPO in particular, played a significant role in strengthening the consumer protection framework in Ireland, to ensure that the system and protections are in line with global standards.  I was pleased with the endorsement we received from the OECD just before Christmas.  But while this strengthening of the framework has improved supports and outcomes for consumers, we also recognise the importance of ensuring that the framework – like all frameworks – continues to adapt and evolve so that it remains fit for purpose and future-ready.   The challenges and risks facing us are clear. The global economy is fragmenting and countries across the globe are undergoing significant economic transitions – in demography, in technology, in climate – while also experiencing a period of unprecedented innovation.  The ways in which we as consumers buy, use and engage with financial services are changing significantly.  These changes reflect new preferences, provide new opportunities and meet different needs on the part of individuals, households and businesses.  But they also create new challenges and new risks in the financial sector that we supervise and for the consumers we protect. In the face of this changing ecosystem, we need to adapt, evolve and transform.  In fact all of us – firms, regulators, advocates, media – need to work together to secure customers’ interests as they seek to navigate their financial affairs and to plan for their financial futures.As set out in our Strategy, the Central Bank recognises that we must keep up with the changing world if we are to continue to deliver on our mandate.  As both a regulator and supervisor we are working to ensure that our frameworks are ready to respond to the changes that people are experiencing in their daily lives, and that we are connected to – and understand – the needs of the individuals, households and businesses that make up the real economy which ultimately supports the welfare of the people as a whole.  For us it means being focused on innovation, building our data capability, modernising our regulations, evolving to adopt new mandates and transforming our supervisory framework. Our new supervisory approach came into effect in January this year. It remains outcomes-focused and risk-based, building on our existing principles and practices.  The changes enable a more integrated approach to the different aspects of our mandate but remain focused on achieving four safeguarding outcomes: the protection of consumer and investor interests, the integrity of the financial system, the safety and soundness of firms, and the stability of the financial system.  Importantly, our new approach places consumer protection at the heart of day-to-day supervision. It positions us better as an organisation to meet our objectives to ensure consumers of financial services are protected in a changing financial landscape. Consumer Protection Code Let me turn to the revised Consumer Protection Code itself.  It is built on the strong foundations of its predecessor which is the cornerstone of our – and the wider national – consumer protection framework for financial services. Throughout the course of the morning, you will hear further detail on the measures and protections that the updated Code will introduce. And you will also be able to read about them in the suite of materials that we are publishing today. At its core, financial regulation is about supporting positive outcomes, protecting consumers and investors, and, ultimately, contributing to the economic well-being of the community as a whole. In reviewing the Code we have focused on modernising the regulatory framework to reflect the provision of financial services in a digital world. Consumers will benefit from a package of protections that better reflect how they are accessing financial services in the modern world.  Regulated firms will benefit from an integrated regulatory format, and a clearer articulation of their Code obligations, complementing the work they are already doing.One of our key objectives in revising the Code has been to put customers at the heart of the culture, strategy and business models of financial services firms. This is addressed through a new Securing Customers’ Interests Standard, supported by detailed guidance which describes what firms need to consider, the actions they need to take, and the mind-set they should have towards their customers.  We want to see a maturing of firms’ understanding and engagement with their consumer protection obligations where they take ownership for meeting these obligations, deliver positive outcomes and are proactive in addressing any issues that arise.Another important aspect of our review has been on protecting consumers in vulnerable circumstances, as they are more likely to suffer detriment or harm.  The new Code sets out an updated definition of vulnerability along with enhanced requirements which reflect an improved understanding of its dynamic nature, recognising that people can move in and out of circumstances that make them vulnerable.  We want firms need to understand the broad nature of vulnerability, and ensure that their culture, policies and processes take account of the needs of consumers in vulnerable circumstances. The revised Consumer Protection Code comes into effect 12 months from today.  We will continue to engage with industry and consumer representatives in relation to its implementation over the next year.  We want to see the new Code contributing to building trust in the financial system and for consumers to have the confidence that it will work to deliver positive outcomes for them.In my view implementing the revised Code successfully will be more likely if it is seen as a collective effort on the part of all participants in the financial system:firms must continue to put the customer at the heart of their culture, strategy, business model and decision-making.  Customer interests should not be the afterthought to finalising a strategy. Consideration of the impacts on customers and customer outcomes needs to be a key aspect of the strategy development and decision-making process itself;consumer representative organisations play an important role in supporting and advising consumers in their interactions with financial services and I’m sure they will continue to do this as we work through implementation of the revised Code;media organisations of course play an important role in informing all the participants in the system;agencies such as the CCPC, FSPO and others will continue to play their important roles as key players in the national consumer protection framework; andthe Central Bank we will remain focused on ensuring that the financial system operates in the best interests of consumers and the wider economy, as well as playing our part in communicating with consumers to raise their awareness of the revised Code. Adopting a whole-of-system approach will support effective implementation of the revised Code and ensure the protection of consumer and investor interests in their interactions with a rapidly-changing financial system.Thank you once again for joining us today. 

Good morning everyone, I would like to welcome you all to the Central Bank today.Welcome in particular to Robert Troy TD, Minister of State, as well as Brian McHugh, Chair of the Competition and Consumer Protection Commission (CCPC), and Liam Sloyan the Financial Services and Pensions Ombudsman (FSPO).We are also joined by stakeholders from across the financial system who, over the last three years, have supported and informed the development of the revised Consumer Protection Code which we are publishing today. Thank you all for coming and thank you for your commitment to dialogue and engagement to inform the new Code. You have made an important contribution to the new Code.Before turning to the Code itself, let me say a few words about consumer protection more generally and our approach here in the Central Bank of Ireland.Our mission is to serve the public interest by maintaining monetary and financial stability while ensuring that the financial system operates in the best interests of consumers and the wider economy.  We are guided by the objective set out in our founding legislation which stated that the Central Bank’s “constant and predominant aim shall be the welfare of the people as a whole”.  Everything that we do is aimed at serving the public interest and protecting consumers of financial services, whether it is through the consumer protection code, the mortgage measures, our monetary policy actions, our oversight of the payments system, or our supervision of individual firms. Over the last decade, we have, along with the CCPC and FSPO in particular, played a significant role in strengthening the consumer protection framework in Ireland, to ensure that the system and protections are in line with global standards.  I was pleased with the endorsement we received from the OECD just before Christmas.  But while this strengthening of the framework has improved supports and outcomes for consumers, we also recognise the importance of ensuring that the framework – like all frameworks – continues to adapt and evolve so that it remains fit for purpose and future-ready.   The challenges and risks facing us are clear. The global economy is fragmenting and countries across the globe are undergoing significant economic transitions – in demography, in technology, in climate – while also experiencing a period of unprecedented innovation.  The ways in which we as consumers buy, use and engage with financial services are changing significantly.  These changes reflect new preferences, provide new opportunities and meet different needs on the part of individuals, households and businesses.  But they also create new challenges and new risks in the financial sector that we supervise and for the consumers we protect. In the face of this changing ecosystem, we need to adapt, evolve and transform.  In fact all of us – firms, regulators, advocates, media – need to work together to secure customers’ interests as they seek to navigate their financial affairs and to plan for their financial futures.As set out in our Strategy, the Central Bank recognises that we must keep up with the changing world if we are to continue to deliver on our mandate.  As both a regulator and supervisor we are working to ensure that our frameworks are ready to respond to the changes that people are experiencing in their daily lives, and that we are connected to – and understand – the needs of the individuals, households and businesses that make up the real economy which ultimately supports the welfare of the people as a whole.  For us it means being focused on innovation, building our data capability, modernising our regulations, evolving to adopt new mandates and transforming our supervisory framework. Our new supervisory approach came into effect in January this year. It remains outcomes-focused and risk-based, building on our existing principles and practices.  The changes enable a more integrated approach to the different aspects of our mandate but remain focused on achieving four safeguarding outcomes: the protection of consumer and investor interests, the integrity of the financial system, the safety and soundness of firms, and the stability of the financial system.  Importantly, our new approach places consumer protection at the heart of day-to-day supervision. It positions us better as an organisation to meet our objectives to ensure consumers of financial services are protected in a changing financial landscape. Consumer Protection Code Let me turn to the revised Consumer Protection Code itself.  It is built on the strong foundations of its predecessor which is the cornerstone of our – and the wider national – consumer protection framework for financial services. Throughout the course of the morning, you will hear further detail on the measures and protections that the updated Code will introduce. And you will also be able to read about them in the suite of materials that we are publishing today. At its core, financial regulation is about supporting positive outcomes, protecting consumers and investors, and, ultimately, contributing to the economic well-being of the community as a whole. In reviewing the Code we have focused on modernising the regulatory framework to reflect the provision of financial services in a digital world. Consumers will benefit from a package of protections that better reflect how they are accessing financial services in the modern world.  Regulated firms will benefit from an integrated regulatory format, and a clearer articulation of their Code obligations, complementing the work they are already doing.One of our key objectives in revising the Code has been to put customers at the heart of the culture, strategy and business models of financial services firms. This is addressed through a new Securing Customers’ Interests Standard, supported by detailed guidance which describes what firms need to consider, the actions they need to take, and the mind-set they should have towards their customers.  We want to see a maturing of firms’ understanding and engagement with their consumer protection obligations where they take ownership for meeting these obligations, deliver positive outcomes and are proactive in addressing any issues that arise.Another important aspect of our review has been on protecting consumers in vulnerable circumstances, as they are more likely to suffer detriment or harm.  The new Code sets out an updated definition of vulnerability along with enhanced requirements which reflect an improved understanding of its dynamic nature, recognising that people can move in and out of circumstances that make them vulnerable.  We want firms need to understand the broad nature of vulnerability, and ensure that their culture, policies and processes take account of the needs of consumers in vulnerable circumstances. The revised Consumer Protection Code comes into effect 12 months from today.  We will continue to engage with industry and consumer representatives in relation to its implementation over the next year.  We want to see the new Code contributing to building trust in the financial system and for consumers to have the confidence that it will work to deliver positive outcomes for them.In my view implementing the revised Code successfully will be more likely if it is seen as a collective effort on the part of all participants in the financial system:firms must continue to put the customer at the heart of their culture, strategy, business model and decision-making.  Customer interests should not be the afterthought to finalising a strategy. Consideration of the impacts on customers and customer outcomes needs to be a key aspect of the strategy development and decision-making process itself;consumer representative organisations play an important role in supporting and advising consumers in their interactions with financial services and I’m sure they will continue to do this as we work through implementation of the revised Code;media organisations of course play an important role in informing all the participants in the system;agencies such as the CCPC, FSPO and others will continue to play their important roles as key players in the national consumer protection framework; andthe Central Bank we will remain focused on ensuring that the financial system operates in the best interests of consumers and the wider economy, as well as playing our part in communicating with consumers to raise their awareness of the revised Code. Adopting a whole-of-system approach will support effective implementation of the revised Code and ensure the protection of consumer and investor interests in their interactions with a rapidly-changing financial system.Thank you once again for joining us today. 

Good morning everyone, I would like to welcome you all to the Central Bank today.Welcome in particular to Robert Troy TD, Minister of State, as well as Brian McHugh, Chair of the Competition and Consumer Protection Commission (CCPC), and Liam Sloyan the Financial Services and Pensions Ombudsman (FSPO).We are also joined by stakeholders from across the financial system who, over the last three years, have supported and informed the development of the revised Consumer Protection Code which we are publishing today. Thank you all for coming and thank you for your commitment to dialogue and engagement to inform the new Code. You have made an important contribution to the new Code.Before turning to the Code itself, let me say a few words about consumer protection more generally and our approach here in the Central Bank of Ireland.Our mission is to serve the public interest by maintaining monetary and financial stability while ensuring that the financial system operates in the best interests of consumers and the wider economy.  We are guided by the objective set out in our founding legislation which stated that the Central Bank’s “constant and predominant aim shall be the welfare of the people as a whole”.  Everything that we do is aimed at serving the public interest and protecting consumers of financial services, whether it is through the consumer protection code, the mortgage measures, our monetary policy actions, our oversight of the payments system, or our supervision of individual firms. Over the last decade, we have, along with the CCPC and FSPO in particular, played a significant role in strengthening the consumer protection framework in Ireland, to ensure that the system and protections are in line with global standards.  I was pleased with the endorsement we received from the OECD just before Christmas.  But while this strengthening of the framework has improved supports and outcomes for consumers, we also recognise the importance of ensuring that the framework – like all frameworks – continues to adapt and evolve so that it remains fit for purpose and future-ready.   The challenges and risks facing us are clear. The global economy is fragmenting and countries across the globe are undergoing significant economic transitions – in demography, in technology, in climate – while also experiencing a period of unprecedented innovation.  The ways in which we as consumers buy, use and engage with financial services are changing significantly.  These changes reflect new preferences, provide new opportunities and meet different needs on the part of individuals, households and businesses.  But they also create new challenges and new risks in the financial sector that we supervise and for the consumers we protect. In the face of this changing ecosystem, we need to adapt, evolve and transform.  In fact all of us – firms, regulators, advocates, media – need to work together to secure customers’ interests as they seek to navigate their financial affairs and to plan for their financial futures.As set out in our Strategy, the Central Bank recognises that we must keep up with the changing world if we are to continue to deliver on our mandate.  As both a regulator and supervisor we are working to ensure that our frameworks are ready to respond to the changes that people are experiencing in their daily lives, and that we are connected to – and understand – the needs of the individuals, households and businesses that make up the real economy which ultimately supports the welfare of the people as a whole.  For us it means being focused on innovation, building our data capability, modernising our regulations, evolving to adopt new mandates and transforming our supervisory framework. Our new supervisory approach came into effect in January this year. It remains outcomes-focused and risk-based, building on our existing principles and practices.  The changes enable a more integrated approach to the different aspects of our mandate but remain focused on achieving four safeguarding outcomes: the protection of consumer and investor interests, the integrity of the financial system, the safety and soundness of firms, and the stability of the financial system.  Importantly, our new approach places consumer protection at the heart of day-to-day supervision. It positions us better as an organisation to meet our objectives to ensure consumers of financial services are protected in a changing financial landscape. Consumer Protection Code Let me turn to the revised Consumer Protection Code itself.  It is built on the strong foundations of its predecessor which is the cornerstone of our – and the wider national – consumer protection framework for financial services. Throughout the course of the morning, you will hear further detail on the measures and protections that the updated Code will introduce. And you will also be able to read about them in the suite of materials that we are publishing today. At its core, financial regulation is about supporting positive outcomes, protecting consumers and investors, and, ultimately, contributing to the economic well-being of the community as a whole. In reviewing the Code we have focused on modernising the regulatory framework to reflect the provision of financial services in a digital world. Consumers will benefit from a package of protections that better reflect how they are accessing financial services in the modern world.  Regulated firms will benefit from an integrated regulatory format, and a clearer articulation of their Code obligations, complementing the work they are already doing.One of our key objectives in revising the Code has been to put customers at the heart of the culture, strategy and business models of financial services firms. This is addressed through a new Securing Customers’ Interests Standard, supported by detailed guidance which describes what firms need to consider, the actions they need to take, and the mind-set they should have towards their customers.  We want to see a maturing of firms’ understanding and engagement with their consumer protection obligations where they take ownership for meeting these obligations, deliver positive outcomes and are proactive in addressing any issues that arise.Another important aspect of our review has been on protecting consumers in vulnerable circumstances, as they are more likely to suffer detriment or harm.  The new Code sets out an updated definition of vulnerability along with enhanced requirements which reflect an improved understanding of its dynamic nature, recognising that people can move in and out of circumstances that make them vulnerable.  We want firms need to understand the broad nature of vulnerability, and ensure that their culture, policies and processes take account of the needs of consumers in vulnerable circumstances. The revised Consumer Protection Code comes into effect 12 months from today.  We will continue to engage with industry and consumer representatives in relation to its implementation over the next year.  We want to see the new Code contributing to building trust in the financial system and for consumers to have the confidence that it will work to deliver positive outcomes for them.In my view implementing the revised Code successfully will be more likely if it is seen as a collective effort on the part of all participants in the financial system:firms must continue to put the customer at the heart of their culture, strategy, business model and decision-making.  Customer interests should not be the afterthought to finalising a strategy. Consideration of the impacts on customers and customer outcomes needs to be a key aspect of the strategy development and decision-making process itself;consumer representative organisations play an important role in supporting and advising consumers in their interactions with financial services and I’m sure they will continue to do this as we work through implementation of the revised Code;media organisations of course play an important role in informing all the participants in the system;agencies such as the CCPC, FSPO and others will continue to play their important roles as key players in the national consumer protection framework; andthe Central Bank we will remain focused on ensuring that the financial system operates in the best interests of consumers and the wider economy, as well as playing our part in communicating with consumers to raise their awareness of the revised Code. Adopting a whole-of-system approach will support effective implementation of the revised Code and ensure the protection of consumer and investor interests in their interactions with a rapidly-changing financial system.Thank you once again for joining us today. 

Good morning everyone, I would like to welcome you all to the Central Bank today.Welcome in particular to Robert Troy TD, Minister of State, as well as Brian McHugh, Chair of the Competition and Consumer Protection Commission (CCPC), and Liam Sloyan the Financial Services and Pensions Ombudsman (FSPO).We are also joined by stakeholders from across the financial system who, over the last three years, have supported and informed the development of the revised Consumer Protection Code which we are publishing today. Thank you all for coming and thank you for your commitment to dialogue and engagement to inform the new Code. You have made an important contribution to the new Code.Before turning to the Code itself, let me say a few words about consumer protection more generally and our approach here in the Central Bank of Ireland.Our mission is to serve the public interest by maintaining monetary and financial stability while ensuring that the financial system operates in the best interests of consumers and the wider economy.  We are guided by the objective set out in our founding legislation which stated that the Central Bank’s “constant and predominant aim shall be the welfare of the people as a whole”.  Everything that we do is aimed at serving the public interest and protecting consumers of financial services, whether it is through the consumer protection code, the mortgage measures, our monetary policy actions, our oversight of the payments system, or our supervision of individual firms. Over the last decade, we have, along with the CCPC and FSPO in particular, played a significant role in strengthening the consumer protection framework in Ireland, to ensure that the system and protections are in line with global standards.  I was pleased with the endorsement we received from the OECD just before Christmas.  But while this strengthening of the framework has improved supports and outcomes for consumers, we also recognise the importance of ensuring that the framework – like all frameworks – continues to adapt and evolve so that it remains fit for purpose and future-ready.   The challenges and risks facing us are clear. The global economy is fragmenting and countries across the globe are undergoing significant economic transitions – in demography, in technology, in climate – while also experiencing a period of unprecedented innovation.  The ways in which we as consumers buy, use and engage with financial services are changing significantly.  These changes reflect new preferences, provide new opportunities and meet different needs on the part of individuals, households and businesses.  But they also create new challenges and new risks in the financial sector that we supervise and for the consumers we protect. In the face of this changing ecosystem, we need to adapt, evolve and transform.  In fact all of us – firms, regulators, advocates, media – need to work together to secure customers’ interests as they seek to navigate their financial affairs and to plan for their financial futures.As set out in our Strategy, the Central Bank recognises that we must keep up with the changing world if we are to continue to deliver on our mandate.  As both a regulator and supervisor we are working to ensure that our frameworks are ready to respond to the changes that people are experiencing in their daily lives, and that we are connected to – and understand – the needs of the individuals, households and businesses that make up the real economy which ultimately supports the welfare of the people as a whole.  For us it means being focused on innovation, building our data capability, modernising our regulations, evolving to adopt new mandates and transforming our supervisory framework. Our new supervisory approach came into effect in January this year. It remains outcomes-focused and risk-based, building on our existing principles and practices.  The changes enable a more integrated approach to the different aspects of our mandate but remain focused on achieving four safeguarding outcomes: the protection of consumer and investor interests, the integrity of the financial system, the safety and soundness of firms, and the stability of the financial system.  Importantly, our new approach places consumer protection at the heart of day-to-day supervision. It positions us better as an organisation to meet our objectives to ensure consumers of financial services are protected in a changing financial landscape. Consumer Protection Code Let me turn to the revised Consumer Protection Code itself.  It is built on the strong foundations of its predecessor which is the cornerstone of our – and the wider national – consumer protection framework for financial services. Throughout the course of the morning, you will hear further detail on the measures and protections that the updated Code will introduce. And you will also be able to read about them in the suite of materials that we are publishing today. At its core, financial regulation is about supporting positive outcomes, protecting consumers and investors, and, ultimately, contributing to the economic well-being of the community as a whole. In reviewing the Code we have focused on modernising the regulatory framework to reflect the provision of financial services in a digital world. Consumers will benefit from a package of protections that better reflect how they are accessing financial services in the modern world.  Regulated firms will benefit from an integrated regulatory format, and a clearer articulation of their Code obligations, complementing the work they are already doing.One of our key objectives in revising the Code has been to put customers at the heart of the culture, strategy and business models of financial services firms. This is addressed through a new Securing Customers’ Interests Standard, supported by detailed guidance which describes what firms need to consider, the actions they need to take, and the mind-set they should have towards their customers.  We want to see a maturing of firms’ understanding and engagement with their consumer protection obligations where they take ownership for meeting these obligations, deliver positive outcomes and are proactive in addressing any issues that arise.Another important aspect of our review has been on protecting consumers in vulnerable circumstances, as they are more likely to suffer detriment or harm.  The new Code sets out an updated definition of vulnerability along with enhanced requirements which reflect an improved understanding of its dynamic nature, recognising that people can move in and out of circumstances that make them vulnerable.  We want firms need to understand the broad nature of vulnerability, and ensure that their culture, policies and processes take account of the needs of consumers in vulnerable circumstances. The revised Consumer Protection Code comes into effect 12 months from today.  We will continue to engage with industry and consumer representatives in relation to its implementation over the next year.  We want to see the new Code contributing to building trust in the financial system and for consumers to have the confidence that it will work to deliver positive outcomes for them.In my view implementing the revised Code successfully will be more likely if it is seen as a collective effort on the part of all participants in the financial system:firms must continue to put the customer at the heart of their culture, strategy, business model and decision-making.  Customer interests should not be the afterthought to finalising a strategy. Consideration of the impacts on customers and customer outcomes needs to be a key aspect of the strategy development and decision-making process itself;consumer representative organisations play an important role in supporting and advising consumers in their interactions with financial services and I’m sure they will continue to do this as we work through implementation of the revised Code;media organisations of course play an important role in informing all the participants in the system;agencies such as the CCPC, FSPO and others will continue to play their important roles as key players in the national consumer protection framework; andthe Central Bank we will remain focused on ensuring that the financial system operates in the best interests of consumers and the wider economy, as well as playing our part in communicating with consumers to raise their awareness of the revised Code. Adopting a whole-of-system approach will support effective implementation of the revised Code and ensure the protection of consumer and investor interests in their interactions with a rapidly-changing financial system.Thank you once again for joining us today. 

Good morning everyone, I would like to welcome you all to the Central Bank today.Welcome in particular to Robert Troy TD, Minister of State, as well as Brian McHugh, Chair of the Competition and Consumer Protection Commission (CCPC), and Liam Sloyan the Financial Services and Pensions Ombudsman (FSPO).We are also joined by stakeholders from across the financial system who, over the last three years, have supported and informed the development of the revised Consumer Protection Code which we are publishing today. Thank you all for coming and thank you for your commitment to dialogue and engagement to inform the new Code. You have made an important contribution to the new Code.Before turning to the Code itself, let me say a few words about consumer protection more generally and our approach here in the Central Bank of Ireland.Our mission is to serve the public interest by maintaining monetary and financial stability while ensuring that the financial system operates in the best interests of consumers and the wider economy.  We are guided by the objective set out in our founding legislation which stated that the Central Bank’s “constant and predominant aim shall be the welfare of the people as a whole”.  Everything that we do is aimed at serving the public interest and protecting consumers of financial services, whether it is through the consumer protection code, the mortgage measures, our monetary policy actions, our oversight of the payments system, or our supervision of individual firms. Over the last decade, we have, along with the CCPC and FSPO in particular, played a significant role in strengthening the consumer protection framework in Ireland, to ensure that the system and protections are in line with global standards.  I was pleased with the endorsement we received from the OECD just before Christmas.  But while this strengthening of the framework has improved supports and outcomes for consumers, we also recognise the importance of ensuring that the framework – like all frameworks – continues to adapt and evolve so that it remains fit for purpose and future-ready.   The challenges and risks facing us are clear. The global economy is fragmenting and countries across the globe are undergoing significant economic transitions – in demography, in technology, in climate – while also experiencing a period of unprecedented innovation.  The ways in which we as consumers buy, use and engage with financial services are changing significantly.  These changes reflect new preferences, provide new opportunities and meet different needs on the part of individuals, households and businesses.  But they also create new challenges and new risks in the financial sector that we supervise and for the consumers we protect. In the face of this changing ecosystem, we need to adapt, evolve and transform.  In fact all of us – firms, regulators, advocates, media – need to work together to secure customers’ interests as they seek to navigate their financial affairs and to plan for their financial futures.As set out in our Strategy, the Central Bank recognises that we must keep up with the changing world if we are to continue to deliver on our mandate.  As both a regulator and supervisor we are working to ensure that our frameworks are ready to respond to the changes that people are experiencing in their daily lives, and that we are connected to – and understand – the needs of the individuals, households and businesses that make up the real economy which ultimately supports the welfare of the people as a whole.  For us it means being focused on innovation, building our data capability, modernising our regulations, evolving to adopt new mandates and transforming our supervisory framework. Our new supervisory approach came into effect in January this year. It remains outcomes-focused and risk-based, building on our existing principles and practices.  The changes enable a more integrated approach to the different aspects of our mandate but remain focused on achieving four safeguarding outcomes: the protection of consumer and investor interests, the integrity of the financial system, the safety and soundness of firms, and the stability of the financial system.  Importantly, our new approach places consumer protection at the heart of day-to-day supervision. It positions us better as an organisation to meet our objectives to ensure consumers of financial services are protected in a changing financial landscape. Consumer Protection Code Let me turn to the revised Consumer Protection Code itself.  It is built on the strong foundations of its predecessor which is the cornerstone of our – and the wider national – consumer protection framework for financial services. Throughout the course of the morning, you will hear further detail on the measures and protections that the updated Code will introduce. And you will also be able to read about them in the suite of materials that we are publishing today. At its core, financial regulation is about supporting positive outcomes, protecting consumers and investors, and, ultimately, contributing to the economic well-being of the community as a whole. In reviewing the Code we have focused on modernising the regulatory framework to reflect the provision of financial services in a digital world. Consumers will benefit from a package of protections that better reflect how they are accessing financial services in the modern world.  Regulated firms will benefit from an integrated regulatory format, and a clearer articulation of their Code obligations, complementing the work they are already doing.One of our key objectives in revising the Code has been to put customers at the heart of the culture, strategy and business models of financial services firms. This is addressed through a new Securing Customers’ Interests Standard, supported by detailed guidance which describes what firms need to consider, the actions they need to take, and the mind-set they should have towards their customers.  We want to see a maturing of firms’ understanding and engagement with their consumer protection obligations where they take ownership for meeting these obligations, deliver positive outcomes and are proactive in addressing any issues that arise.Another important aspect of our review has been on protecting consumers in vulnerable circumstances, as they are more likely to suffer detriment or harm.  The new Code sets out an updated definition of vulnerability along with enhanced requirements which reflect an improved understanding of its dynamic nature, recognising that people can move in and out of circumstances that make them vulnerable.  We want firms need to understand the broad nature of vulnerability, and ensure that their culture, policies and processes take account of the needs of consumers in vulnerable circumstances. The revised Consumer Protection Code comes into effect 12 months from today.  We will continue to engage with industry and consumer representatives in relation to its implementation over the next year.  We want to see the new Code contributing to building trust in the financial system and for consumers to have the confidence that it will work to deliver positive outcomes for them.In my view implementing the revised Code successfully will be more likely if it is seen as a collective effort on the part of all participants in the financial system:firms must continue to put the customer at the heart of their culture, strategy, business model and decision-making.  Customer interests should not be the afterthought to finalising a strategy. Consideration of the impacts on customers and customer outcomes needs to be a key aspect of the strategy development and decision-making process itself;consumer representative organisations play an important role in supporting and advising consumers in their interactions with financial services and I’m sure they will continue to do this as we work through implementation of the revised Code;media organisations of course play an important role in informing all the participants in the system;agencies such as the CCPC, FSPO and others will continue to play their important roles as key players in the national consumer protection framework; andthe Central Bank we will remain focused on ensuring that the financial system operates in the best interests of consumers and the wider economy, as well as playing our part in communicating with consumers to raise their awareness of the revised Code. Adopting a whole-of-system approach will support effective implementation of the revised Code and ensure the protection of consumer and investor interests in their interactions with a rapidly-changing financial system.Thank you once again for joining us today. 

Good morning everyone, I would like to welcome you all to the Central Bank today.Welcome in particular to Robert Troy TD, Minister of State, as well as Brian McHugh, Chair of the Competition and Consumer Protection Commission (CCPC), and Liam Sloyan the Financial Services and Pensions Ombudsman (FSPO).We are also joined by stakeholders from across the financial system who, over the last three years, have supported and informed the development of the revised Consumer Protection Code which we are publishing today. Thank you all for coming and thank you for your commitment to dialogue and engagement to inform the new Code. You have made an important contribution to the new Code.Before turning to the Code itself, let me say a few words about consumer protection more generally and our approach here in the Central Bank of Ireland.Our mission is to serve the public interest by maintaining monetary and financial stability while ensuring that the financial system operates in the best interests of consumers and the wider economy.  We are guided by the objective set out in our founding legislation which stated that the Central Bank’s “constant and predominant aim shall be the welfare of the people as a whole”.  Everything that we do is aimed at serving the public interest and protecting consumers of financial services, whether it is through the consumer protection code, the mortgage measures, our monetary policy actions, our oversight of the payments system, or our supervision of individual firms. Over the last decade, we have, along with the CCPC and FSPO in particular, played a significant role in strengthening the consumer protection framework in Ireland, to ensure that the system and protections are in line with global standards.  I was pleased with the endorsement we received from the OECD just before Christmas.  But while this strengthening of the framework has improved supports and outcomes for consumers, we also recognise the importance of ensuring that the framework – like all frameworks – continues to adapt and evolve so that it remains fit for purpose and future-ready.   The challenges and risks facing us are clear. The global economy is fragmenting and countries across the globe are undergoing significant economic transitions – in demography, in technology, in climate – while also experiencing a period of unprecedented innovation.  The ways in which we as consumers buy, use and engage with financial services are changing significantly.  These changes reflect new preferences, provide new opportunities and meet different needs on the part of individuals, households and businesses.  But they also create new challenges and new risks in the financial sector that we supervise and for the consumers we protect. In the face of this changing ecosystem, we need to adapt, evolve and transform.  In fact all of us – firms, regulators, advocates, media – need to work together to secure customers’ interests as they seek to navigate their financial affairs and to plan for their financial futures.As set out in our Strategy, the Central Bank recognises that we must keep up with the changing world if we are to continue to deliver on our mandate.  As both a regulator and supervisor we are working to ensure that our frameworks are ready to respond to the changes that people are experiencing in their daily lives, and that we are connected to – and understand – the needs of the individuals, households and businesses that make up the real economy which ultimately supports the welfare of the people as a whole.  For us it means being focused on innovation, building our data capability, modernising our regulations, evolving to adopt new mandates and transforming our supervisory framework. Our new supervisory approach came into effect in January this year. It remains outcomes-focused and risk-based, building on our existing principles and practices.  The changes enable a more integrated approach to the different aspects of our mandate but remain focused on achieving four safeguarding outcomes: the protection of consumer and investor interests, the integrity of the financial system, the safety and soundness of firms, and the stability of the financial system.  Importantly, our new approach places consumer protection at the heart of day-to-day supervision. It positions us better as an organisation to meet our objectives to ensure consumers of financial services are protected in a changing financial landscape. Consumer Protection Code Let me turn to the revised Consumer Protection Code itself.  It is built on the strong foundations of its predecessor which is the cornerstone of our – and the wider national – consumer protection framework for financial services. Throughout the course of the morning, you will hear further detail on the measures and protections that the updated Code will introduce. And you will also be able to read about them in the suite of materials that we are publishing today. At its core, financial regulation is about supporting positive outcomes, protecting consumers and investors, and, ultimately, contributing to the economic well-being of the community as a whole. In reviewing the Code we have focused on modernising the regulatory framework to reflect the provision of financial services in a digital world. Consumers will benefit from a package of protections that better reflect how they are accessing financial services in the modern world.  Regulated firms will benefit from an integrated regulatory format, and a clearer articulation of their Code obligations, complementing the work they are already doing.One of our key objectives in revising the Code has been to put customers at the heart of the culture, strategy and business models of financial services firms. This is addressed through a new Securing Customers’ Interests Standard, supported by detailed guidance which describes what firms need to consider, the actions they need to take, and the mind-set they should have towards their customers.  We want to see a maturing of firms’ understanding and engagement with their consumer protection obligations where they take ownership for meeting these obligations, deliver positive outcomes and are proactive in addressing any issues that arise.Another important aspect of our review has been on protecting consumers in vulnerable circumstances, as they are more likely to suffer detriment or harm.  The new Code sets out an updated definition of vulnerability along with enhanced requirements which reflect an improved understanding of its dynamic nature, recognising that people can move in and out of circumstances that make them vulnerable.  We want firms need to understand the broad nature of vulnerability, and ensure that their culture, policies and processes take account of the needs of consumers in vulnerable circumstances. The revised Consumer Protection Code comes into effect 12 months from today.  We will continue to engage with industry and consumer representatives in relation to its implementation over the next year.  We want to see the new Code contributing to building trust in the financial system and for consumers to have the confidence that it will work to deliver positive outcomes for them.In my view implementing the revised Code successfully will be more likely if it is seen as a collective effort on the part of all participants in the financial system:firms must continue to put the customer at the heart of their culture, strategy, business model and decision-making.  Customer interests should not be the afterthought to finalising a strategy. Consideration of the impacts on customers and customer outcomes needs to be a key aspect of the strategy development and decision-making process itself;consumer representative organisations play an important role in supporting and advising consumers in their interactions with financial services and I’m sure they will continue to do this as we work through implementation of the revised Code;media organisations of course play an important role in informing all the participants in the system;agencies such as the CCPC, FSPO and others will continue to play their important roles as key players in the national consumer protection framework; andthe Central Bank we will remain focused on ensuring that the financial system operates in the best interests of consumers and the wider economy, as well as playing our part in communicating with consumers to raise their awareness of the revised Code. Adopting a whole-of-system approach will support effective implementation of the revised Code and ensure the protection of consumer and investor interests in their interactions with a rapidly-changing financial system.Thank you once again for joining us today. 

Good morning everyone, I would like to welcome you all to the Central Bank today.Welcome in particular to Robert Troy TD, Minister of State, as well as Brian McHugh, Chair of the Competition and Consumer Protection Commission (CCPC), and Liam Sloyan the Financial Services and Pensions Ombudsman (FSPO).We are also joined by stakeholders from across the financial system who, over the last three years, have supported and informed the development of the revised Consumer Protection Code which we are publishing today. Thank you all for coming and thank you for your commitment to dialogue and engagement to inform the new Code. You have made an important contribution to the new Code.Before turning to the Code itself, let me say a few words about consumer protection more generally and our approach here in the Central Bank of Ireland.Our mission is to serve the public interest by maintaining monetary and financial stability while ensuring that the financial system operates in the best interests of consumers and the wider economy.  We are guided by the objective set out in our founding legislation which stated that the Central Bank’s “constant and predominant aim shall be the welfare of the people as a whole”.  Everything that we do is aimed at serving the public interest and protecting consumers of financial services, whether it is through the consumer protection code, the mortgage measures, our monetary policy actions, our oversight of the payments system, or our supervision of individual firms. Over the last decade, we have, along with the CCPC and FSPO in particular, played a significant role in strengthening the consumer protection framework in Ireland, to ensure that the system and protections are in line with global standards.  I was pleased with the endorsement we received from the OECD just before Christmas.  But while this strengthening of the framework has improved supports and outcomes for consumers, we also recognise the importance of ensuring that the framework – like all frameworks – continues to adapt and evolve so that it remains fit for purpose and future-ready.   The challenges and risks facing us are clear. The global economy is fragmenting and countries across the globe are undergoing significant economic transitions – in demography, in technology, in climate – while also experiencing a period of unprecedented innovation.  The ways in which we as consumers buy, use and engage with financial services are changing significantly.  These changes reflect new preferences, provide new opportunities and meet different needs on the part of individuals, households and businesses.  But they also create new challenges and new risks in the financial sector that we supervise and for the consumers we protect. In the face of this changing ecosystem, we need to adapt, evolve and transform.  In fact all of us – firms, regulators, advocates, media – need to work together to secure customers’ interests as they seek to navigate their financial affairs and to plan for their financial futures.As set out in our Strategy, the Central Bank recognises that we must keep up with the changing world if we are to continue to deliver on our mandate.  As both a regulator and supervisor we are working to ensure that our frameworks are ready to respond to the changes that people are experiencing in their daily lives, and that we are connected to – and understand – the needs of the individuals, households and businesses that make up the real economy which ultimately supports the welfare of the people as a whole.  For us it means being focused on innovation, building our data capability, modernising our regulations, evolving to adopt new mandates and transforming our supervisory framework. Our new supervisory approach came into effect in January this year. It remains outcomes-focused and risk-based, building on our existing principles and practices.  The changes enable a more integrated approach to the different aspects of our mandate but remain focused on achieving four safeguarding outcomes: the protection of consumer and investor interests, the integrity of the financial system, the safety and soundness of firms, and the stability of the financial system.  Importantly, our new approach places consumer protection at the heart of day-to-day supervision. It positions us better as an organisation to meet our objectives to ensure consumers of financial services are protected in a changing financial landscape. Consumer Protection Code Let me turn to the revised Consumer Protection Code itself.  It is built on the strong foundations of its predecessor which is the cornerstone of our – and the wider national – consumer protection framework for financial services. Throughout the course of the morning, you will hear further detail on the measures and protections that the updated Code will introduce. And you will also be able to read about them in the suite of materials that we are publishing today. At its core, financial regulation is about supporting positive outcomes, protecting consumers and investors, and, ultimately, contributing to the economic well-being of the community as a whole. In reviewing the Code we have focused on modernising the regulatory framework to reflect the provision of financial services in a digital world. Consumers will benefit from a package of protections that better reflect how they are accessing financial services in the modern world.  Regulated firms will benefit from an integrated regulatory format, and a clearer articulation of their Code obligations, complementing the work they are already doing.One of our key objectives in revising the Code has been to put customers at the heart of the culture, strategy and business models of financial services firms. This is addressed through a new Securing Customers’ Interests Standard, supported by detailed guidance which describes what firms need to consider, the actions they need to take, and the mind-set they should have towards their customers.  We want to see a maturing of firms’ understanding and engagement with their consumer protection obligations where they take ownership for meeting these obligations, deliver positive outcomes and are proactive in addressing any issues that arise.Another important aspect of our review has been on protecting consumers in vulnerable circumstances, as they are more likely to suffer detriment or harm.  The new Code sets out an updated definition of vulnerability along with enhanced requirements which reflect an improved understanding of its dynamic nature, recognising that people can move in and out of circumstances that make them vulnerable.  We want firms need to understand the broad nature of vulnerability, and ensure that their culture, policies and processes take account of the needs of consumers in vulnerable circumstances. The revised Consumer Protection Code comes into effect 12 months from today.  We will continue to engage with industry and consumer representatives in relation to its implementation over the next year.  We want to see the new Code contributing to building trust in the financial system and for consumers to have the confidence that it will work to deliver positive outcomes for them.In my view implementing the revised Code successfully will be more likely if it is seen as a collective effort on the part of all participants in the financial system:firms must continue to put the customer at the heart of their culture, strategy, business model and decision-making.  Customer interests should not be the afterthought to finalising a strategy. Consideration of the impacts on customers and customer outcomes needs to be a key aspect of the strategy development and decision-making process itself;consumer representative organisations play an important role in supporting and advising consumers in their interactions with financial services and I’m sure they will continue to do this as we work through implementation of the revised Code;media organisations of course play an important role in informing all the participants in the system;agencies such as the CCPC, FSPO and others will continue to play their important roles as key players in the national consumer protection framework; andthe Central Bank we will remain focused on ensuring that the financial system operates in the best interests of consumers and the wider economy, as well as playing our part in communicating with consumers to raise their awareness of the revised Code. Adopting a whole-of-system approach will support effective implementation of the revised Code and ensure the protection of consumer and investor interests in their interactions with a rapidly-changing financial system.Thank you once again for joining us today.