Nicola Sheridan
Director

Nicola is the Fintech & Payments Leader for PwC Ireland and leads tokenisation initiatives for the firm. Nicola is currently actively engaged with many asset managers and asset servicers on fund tokenisation initiatives, considering legal, regulatory and tax implications as well as operating model impact.

Nicola is closely engaged with Irish Funds, the leading funds industry association in Ireland, on working groups focused on Exchange Traded Funds and Digital Assets, collaborating with the asset management and digital assets ecosystem on fund tokenisation and other digital asset initiatives.

Nicola is Co-Head of the Irish Chapter of Women in ETFs and a member of the Association of Women in Crypto.

Julia Shanahan
Director

Julia is a tax director in PwC Ireland’s tax practice with over 10 years experience in Financial Services.

Julia advises clients on fulfilling their tax compliance obligations across Corporate Taxation and Automatic Exchange of Information, including the Crypto-Asset Reporting Framework (CARF). Julia is also a member of the Business at OECD (BIAC) group for Working Party 10 on Exchange of Information and Tax Compliance.

Julia is a qualified Chartered Accountant with the Institute of Chartered Accountants in Ireland, Julia is also a member of the Irish Taxation Institute.

Key Developments & the Latest Trends in Ireland

1. Introduction – Ireland’s Unique Position at the Intersection of Finance and Technology

As one of the world’s largest fund domiciles, Ireland accounts for 6.8% of global fund assets, with total assets reaching €5.5 trillion.¹https://www.irishfunds.ie/facts-figures/industry-statistics/total-irish-domiciled-funds/ This, coupled with its role as the European hub for major global technology firms, gives Ireland a unique standing in the international fintech landscape. Ireland’s blend of financial services and technology strengths makes it particularly well placed to benefit as blockchain and digital assets migrate from the margins to the mainstream of global finance. Particularly as this shift accelerates, Ireland stands to benefit from an established talent pool that brings together experience in working in regulated businesses with a depth of knowledge in navigating key regulatory considerations, providing a solid foundation to deliver the skills and expertise needed to develop new products and capabilities.

In June 2025, the “Update to Ireland for Finance” action plan released by the Government of Ireland set out five key themes for the 2026 strategy. Among these, fintech and digital finance features prominently, with collaboration to explore the opportunities presented by tokenisation and digital assets identified as one of 15 specific action measures demonstrating that Ireland’s ambition in digital finance is matched by a clear and deliberate policy framework.

2. The Irish Regulatory and Policy Landscape

The Central Bank of Ireland (“CBI”) has adopted a proactive and forward-looking approach to digital assets and blockchain innovation, while remaining attentive to the risks and challenges these developments present. This builds on the broader regulatory direction set by the Irish Government, through the Department of Finance (“DoF”), which, in its Funds Review 2030 published in 2024, outlined a clear pathway towards the adoption of tokenisation through structured industry engagement.

The CBI has been a prominent contributor at European level to the development and implementation of the Markets in Crypto-Assets Regulation (MiCAR) and serves as the competent authority for Ireland’s MiCAR authorisations.

Senior members of the CBI’s policy, supervisory and authorisations teams have consistently articulated a unified regulatory stance. The CBI views its role as implementing MiCAR in a manner that supports the successful delivery of its core regulatory objectives: a well-functioning financial system that serves consumers, users, and the wider economy. Central to this vision is a financial system that is trusted to operate in customers’ interests, that demonstrates resilience, and that is safeguarded against financial crime and money laundering. To that end, the CBI’s authorisation process is underpinned by principles of clarity, transparency, flexibility, and predictability for firms seeking authorisation.

The CBI has also launched an Innovation Sandbox Programme centred on the theme of “innovation in payments”. The programme is designed to provide participating firms with regulatory guidance and support as they develop and refine their projects. The selected participants are working on solutions spanning tokenised digital assets and AI-powered payment services.

3. Ireland as a MiCA-Authorised Hub – Building the Next Wave

As of early 2026, the CBI has granted 12 MiCA licences, establishing Ireland as one of the top 5 EU jurisdictions for crypto-asset service provision. The licensee base represents a mix of global platforms and specialised providers, signalling that Ireland is attracting both scale and technical depth. This pattern mirrors what Ireland has already achieved in payments and e-money: providing a credible, well-regulated EU gateway for non-EU firms (particularly US-based) seeking regulatory authorisation with passporting rights across all EU Member States.

The CBI carries out thorough reviews prior to granting MiCA licenses. Firms must demonstrate genuine substance and governance, not merely compliance on paper. This approach strengthens Ireland’s position as a credible, trusted, and investor-focused jurisdiction. For market participants, this creates a clear value proposition: authorisation in Ireland signals to investors that a firm meets high standards of integrity and resilience. In a sector where credibility is critical, the CBI’s rigorous approach becomes a strategic asset for the firms that choose to obtain their licence in Ireland.

As the industry moves towards tokenisation as a future proofing strategy, Ireland has the potential to foster a hub of digital asset capability by combining a growing base of authorised CASPs with its established €5.5 trillion funds ecosystem and robust technology infrastructure.

4. The Central Bank’s Discussion Paper 12 – Ireland’s Blueprint for Tokenisation

In March 2026, the CBI published Discussion Paper 12 (“DP12”), titled “Distributed Ledger Technology (“DLT”) and Tokenisation in Financial Services” designed to stimulate dialogue within the Irish and European financial ecosystem. This is consistent with a consultative approach taken by the CBI for other sectors (e.g. ETFs), engaging with the industry on the key opportunities and the primary risks.

In this publication, the CBI has conveyed its commitment to the development of tokenisation while seeking input from the industry. DP12 examines how tokenisation could deliver significant benefits, including near-instant settlement, reduced operational costs, fractional ownership of assets and greater transparency.

5. Tokenisation and the Irish Funds Ecosystem

The global growth trajectory of tokenisation is striking. According to PwC’s “Asset and wealth management revolution 2025” report tokenised fund assets under management are projected to grow to $715 billion by 2030 from about $90 billion in 2024. Per the report more than 40% of managers view tokenisation as their most important product innovation.

DP12 indicates that, over the preceding 18 months, Irish authorised funds and their managers have actively engaged with the CBI to explore how tokenisation could be incorporated into both existing and newly designed fund offerings. This engagement has focused not only on digital-twin representations of fund units, but also on digitally native structures, with asset managers approaching the CBI to understand how fully on-chain issuance models might operate within the Irish regulatory framework. This momentum is particularly significant given Ireland’s dominant position in the global money market fund (“MMF”) and Exchange Traded Fund (“ETF”) markets, where operational efficiency, liquidity management, and distribution scalability are critical competitive factors.

The DoF is also actively engaged in assessing the need for legislative change to provide the necessary legal certainty to key aspects of tokenised fund structures, such as the unilateral authority of a DLT based share register. This will provide welcome clarity for asset managers considering tokenisation of their Irish fund structures.

Industry engagement is fundamental as Ireland embarks on its tokenisation journey. Various industry bodies across the ecosystem are collaborating to ensure that Ireland is well positioned to capitalise on its unique position at the intersection of the finance and technology spheres.

6. Payments, Settlement and Money – What It Means for Ireland

To realise the full benefits of tokenisation and blockchain technology, alternative payment methods that allow for instant settlement must be considered. Stablecoins represent perhaps the most developed of these alternatives. Unlike crypto-assets, which fluctuate in value, stablecoins are typically pegged to a fiat currency or commodity to maintain price stability. In Ireland, several MiCAR-authorised firms are actively engaged in stablecoin-related activity, positioning these instruments within the institutional settlement landscape rather than as merely speculative tools.

The CBI acknowledges in DP12 the potential for operational efficiencies whilst also recognising the disruptive capacity of such instruments. The CBI is also actively participating in the European Central Bank’s exploration of a digital euro.

Ireland’s National Payments Strategy, published in October 2024, sets out a vision for a resilient payments ecosystem by 2030 and explicitly considers the costs and benefits of future alternative payment forms for Irish consumers and businesses.

7. Key regulatory considerations

DORA, Cybersecurity and Operational Resilience — The Irish Technology Sector Dimension

DORA became applicable in January 2025 with its five pillars of ICT risk management, ICT-related incident management, classification and reporting, Digital operational resilience testing, ICT third-party risk management and information-sharing arrangements. DORA is particularly significant for Ireland & the EU more broadly, given the concentration of global financial entities and global technology firms. The CBI has been clear that operational resilience is a critical precondition for scalable tokenisation.

DORA is designed around an entity-centric model, under which regulated financial firms retain clear ownership, accountability, and oversight of their ICT environment and third-party dependencies. This is part of their operational resilience framework. DORA will apply to CASPs authorised under MiCAR and will govern their ICT risk management and operational resilience. However, DORA does not regulate the resilience of underlying public blockchain infrastructure itself, such as decentralised protocols, validators, or node networks, except where those elements form part of a regulated entity’s ICT environment or third-party dependency arrangements. MiCAR complements DORA by creating a harmonised EU framework for crypto-assets and crypto-asset service providers, but it does not by itself bring all underlying DLT infrastructure directly within scope.

Anti-Money Laundering (“AML”) considerations

AML and financial crime controls represent an equally critical dimension of Ireland’s digital asset landscape and remain one of the biggest challenges in the space. The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended, implements EU AML/CFT rules into Irish law and was amended in 2021 to include a registration requirement for Virtual Asset Service Providers (“VASPs”). As MiCAR replaces the VASP regime, firms must navigate the transition from a registration-based AML framework to the full CASP authorisation regime, with the CBI expecting robust KYC processes, transaction monitoring and suspicious activity reporting across all crypto-asset activities. AML considerations will remain high on the agenda for tokenisation of fund structures and “white listing” of wallets will become a critical part of customer onboarding.

8. AI and Ireland – Where Digital Assets Meets Artifi­cial Intelligence

Generative AI redefined how digital assets are created, managed, and traded across global financial markets. Generative models are now capable of synthesising vast quantities of market data, identifying complex patterns, and producing novel trading strategies with minimal human intervention. This shift carries profound implications not only for market participants but also for the regulatory and tax frameworks that govern digital asset transactions. The future sees a move to Agentic AI with capabilities to execute transactions and interact with other digital entities with limited to no human intervention. In this model, Agentic AI provides the decision-making intelligence, whilst blockchain serves as the secure layer for execution, record-keeping, and transaction settlement.

Ireland has recognised the unprecedented pace and scale of these technological developments, acknowledging both the significant opportunities and the challenges they present across the economy and society. Ireland’s National Digital & AI Strategy 2030 positions the country as a global hub for applied AI innovation, with fintech, including regtech, insurtech, and payments, identified as a high-growth area for applied AI. The Strategy also highlights the establishment of the AI Office of Ireland as a central coordinating authority for the EU AI Act, providing clarity and regulatory certainty for enterprise. The AI Office will host an AI Regulatory Sandbox, offering a safe, supervised environment for innovators to test new digital and AI solutions in partnership with compliance experts, thereby accelerating responsible development while identifying regulatory gaps at an early stage.

The CBI’s DP 12 also considers how advances in agentic AI could enable autonomous agents to initiate, authorise, and complete financial transactions on behalf of users, with the potential to transform aspects of commerce from Irish-domiciled platforms. This reflects a broader recognition by the CBI that programmable smart contracts, combined with AI-driven decision-making, could give rise to entirely new categories of financial services.

9. Conclusion – Ireland’s Moment

Ireland stands at a pivotal moment in the evolution of digital finance. The convergence of its deep-rooted funds ecosystem, its established position as a European base for global technology firms, and a regulatory environment that is both rigorous and forward-looking places the country in an exceptionally strong position to lead the next chapter of blockchain and digital asset adoption in the European Union.

Ireland has demonstrated that it can attract a diverse cohort of crypto-asset service providers, from large-scale global platforms to specialist operators. The CBI’s publication of DP12 signals a genuine willingness to engage with the transformative potential of tokenisation whilst maintaining the supervisory standards that have earned Ireland the trust of international market participants. The regulatory stance taken by the CBI instills trust in investors which is critical for the long-term success of a digital assets business.

The broader policy environment further reinforces this momentum. The “Update to Ireland for Finance” action plan, the National Payments Strategy and Ireland’s National Digital & AI Strategy 2030 collectively articulate a coherent vision in which fintech and digital finance are not peripheral ambitions but central pillars of Ireland’s economic strategy. The establishment of the CBI’s Innovation Sandbox Programme and the AI Regulatory Sandbox reflects a practical commitment to fostering innovation in a supervised and responsible manner, ensuring that new technologies can be tested, refined and brought to market with appropriate safeguards in place.

Ireland’s funds industry provides a powerful foundation upon which tokenisation can develop at scale. The exploration of tokenised funds as outlined in DP12, offers a tangible pathway for Ireland to extend its global leadership in fund domiciliation into the digital era.