DLT and tokenisation: Emerging themes and CBI priorities

On 2 November 2026, the Central Bank of Ireland (CBI) issued its feedback statement following the publication of a discussion paper on distributed ledger technology (DLT) and tokenisation within financial services in March this year.

The purpose of the discussion paper was to collect information to inform the CBI’s understanding of the future role of DLT and tokenisation applications within the Irish and EU financial services systems. The Feedback Statement is therefore best read as a policy and engagement roadmap rather than a new rulebook.

The feedback statement reflects comments received from forty-two written responses and the CBI’s wider engagement with market participants and other stakeholders. The following seven interrelated themes emerged from the responses and engagement:

• establishing legal certainty
• adapting regulatory frameworks
• maintaining governance and accountability
• building interoperability and infrastructure
• tokenisation of financial assets
• tokenisation of money and settlement
• managing systemic, sectoral and transitional risks

In general, the responses to the discussion paper identified longstanding inefficiencies that tokenisation may help to address, including fragmented systems, complex intermediation, sequential processing and operational constraints associated with the movement of assets, collateral and money. Respondents also highlighted practical applications across investment funds, securities markets, payments and settlement.

Two areas are likely to be particularly significant for market participants:

• The Feedback Statement says the limited prevalence of regulated, euro-denominated, on-chain settlement assets received the strongest signal across the consultation.  It was acknowledged that the tokenised-deposit discussion is likely to require further EU-level work. Respondents identified unresolved issues including the non-harmonised legal definition of “deposit” across Europe, the absence of explicit supervisory guidance on equivalent deposit guarantee scheme treatment, and the absence of explicit supervisory guidance on CRR/CRD capital and liquidity treatment. Nevertheless, the market opportunity is clear.
• The second significant area is legal certainty. Domestically, the Feedback Statement notes that Irish company law and certain funds legislation were drafted assuming centralised register infrastructure, and points to Ireland for Finance Strategy – Vision 2030 actions to update primary legislation to enable digitally native tokenisation of funds and assets and an authoritative on-chain register. The move from digital twins to digitally native models in funds and other assets therefore appear to be a realistic target for firms.

The CBI’s next steps will be built around five priority areas:

• enabling central bank money settlement of on-chain transactions and evolving the collateral framework to accept tokenised assets
• supporting efforts domestically and in Europe to advance legal and regulatory clarity
• evolving CBI innovation practices in line with the changing landscape
• shaping the development of the tokenised ecosystem to guard against fragmentation
• deepening CBI understanding of the macro-financial implications of tokenised finance

The CBI views its role in this area as helping to create the conditions for innovation to develop responsibly, while preserving trust and confidence in the financial system. As part of this, the CBI will establish a new ‘Tokenisation Access Point’ to provide a clearer route for engaging with it on emerging tokenisation models, practical implementation issues and questions arising from the application of existing rules and frameworks. The CBI also intends to use focused, time-bound Innovation Insights sprints, with initial areas expected to include operational resilience for DLT infrastructure, smart contracts, and governance and accountability in the context of open, permissionless chains.

For firms, the practical takeaway is that tokenisation projects should be assessed end-to-end. Legal characterisation, settlement finality, register architecture, prudential treatment, operational resilience, outsourcing and governance will need to be considered together, particularly where models depend on shared infrastructure, smart contracts, validators, oracles, bridges, wallet providers or custody and key-management arrangements.

For further information on the feedback statement and the CBI’s plans, please contact Chris Bergin, Partner, Louise Hogan, Partner, Eoin O Connor, Partner, Patrick Brandt, Partner, Eimear O’Brien, Partner, or Sarah Lee, Senior Practice Development Lawyer.

Date published: 9 November 2026