Domestic

Department of Finance consults on Distance Marketing of Consumer Financial Services

On 11 April 2025, the Department of Finance (DoF) published the Public Consultation on Distance Marketing of Consumer Financial Services Directive ((EU) 2023/2673) in the form of a regulatory impact assessment, with the objective of consulting on the transposition of the Directive. The Directive reflects the impact of digitalisation on the financial services market and addresses sector specific legislation. Chapter 3 outlines the discretions contained in the new Directive and the DoF invites comments on this. The consultation closed on 2 May 2025. Comments will be considered in deciding how best to transpose the Directive.

CBI announces appointment of new Director of Policy and International

On 29 April 2025, the Central Bank of Ireland (CBI) announced the appointment of Micheál O’Keeffe as Director of Policy and International. Micheál is currently a Senior Advisor to Minister Pascal Donohoe in his role as President of the Eurogroup and will now sit as a member on the CBI’s senior leadership team where he will lead on the international and domestic development of financial regulation, from 23 June 2025.

European

ECB publishes progress report on digital euro rulebook

On 9 April 2025, the European Central Bank (ECB) published the fourth progress report on the digital euro scheme rulebook. The Rulebook Development Group (RDG) is seeking to harmonise digital euro payments through a single set of rules, standards and procedures, being set out in the draft digital euro scheme rulebook. The report highlights the progress made in three key areas:

• Existing rulebook sections have been updated to reflect 2,000 comments received.
• Collaborations with market participants through dedicated workstreams has assisted in progress in additional areas.
• Expert sessions have led to developments in key subject areas.

The draft digital euro rulebook will consider any future adjustments arising from the outcome of the digital euro legislative process. The next step will be the sharing of the next draft of the digital euro scheme rulebook with the RDG and its constituents for comment. This version will further elaborate on areas such as dispute management, minimum UX standards and non-functional requirements, stakeholder management, risk management and implementation specifics. Further improvements and versions are expected beyond this. The next progress report should be shared in the third quarter of 2025.

Update on MiCAR guidelines

On 23 April 2025, the final report on guidelines on templates to assist competent authorities in performing their supervisory duties regarding issuers’ compliance under Titles III and IV of Markets in Crypto Assets Regulation ((EU) 2023/1114) (MiCAR) was updated with a compliance table. The guidelines are applicable to competent authorities, issuers of asset-referenced tokens and issuers of e-money tokens, providing instructions and common templates to be used for providing the EBA and competent authorities with the necessary information for the collection of data from the relevant CASPs.

The guidelines will apply from 26 May 2025. In the interim, competent authorities must notify the EBA on their intentions for compliance with these guidelines.

Speech by Sharon Donnery at the Institute of International Finance

On 24 April 2025, Sharon Donnery, Member of the Supervisory Board at ECB, delivered introductory remarks at the Institute of International Finance, Washington DC. Ms. Donnery’s speech was focussed on the theme of ‘Agile supervision amid uncertainty’, where she presented the ECB 2025-2027 supervisory priorities, noting that these provide a clear framework with flexibility to respond to the evolving circumstances. Donnery also noted the resilience of the European banking sector despite the high rate of global trade policy uncertainty. Ms. Donnery outlined three key areas of supervisory priority for the ECB:

• enhancing resilience to macro-financial and geopolitical risks
• remediating persistent material shortcomings
• managing risks from digital transformation and emerging technologies

The key takeaway was that these priorities will assist in providing a clear and predictable framework for navigation through the current global uncertainty.

EBA publishes draft RTS on central contact points for CASPs

On 25 April 2025, the European Banking Authority (EBA) published draft regulatory technical standards (RTSs) with criteria which help determine when crypto asset service providers (CASPs) must appoint a central contact point to help fight financial crime. The draft RTS amend existing RTS as set out in Commission Delegated Regulation ((EU) 2018/1108) to specify when a CASP must appoint a central contact point in accordance with the Fourth Anti-Money Laundering Directive (EU) 2015/849 (AMLD4).

It also sets out the roles and responsibilities of the central contact point. Where a CASP is required to comply with local anti-money laundering and countering the financing of terrorism (AML/CFT) rules, the central contact point will act on its behalf to ensure its compliance with those rules. The central contact point can help mitigate the money laundering and terrorist financing risks associated with the cross-border provision of crypto asset services and facilitate adequate AML/CFT supervision and oversight. The existing RTS apply to payment service providers and e-money issuers. The amendments under the draft RTS extend the existing provisions to CASPs, while also introducing new provisions for CASPs. The draft RTS will be submitted to the Commission for endorsement.

ECB Annual Report 2024

On 28 April 2025, the ECB published the Annual Report 2024. Some key takeaways from the report:

• At the start of 2024, the ECB was in its ‘holding phase’, the second of three distinct phases in the ECB monetary policy cycle. The restrictive policy ensured decreasing inflation and indicated by June 2024 that inflation would reach 2% in 2025.
• The ‘dialling-back’ phase took effect from June 2024 with monetary policy becoming less restrictive, which led to the cutting of rates by 25 basis points from June.
• From September to December 2024, the ECB reduced policy rates by a further 75 basis points, allowing for the normalisation of balance sheets, leading to gradually declining liquidity.
• The ECB introduced changes to the operational framework for the implementation of monetary policy; adjusting the deposit facility rate and narrowing the differential between this and the main refinancing operations rate.
• The daily average number of instant payments in euro increased by 72% over the course of the year.
• The ECB took steps to integrate AI technologies, with staff now utilising four large language models to support their work.
• The ECB launched its climate and nature plan 2024-2025 in a bid to expand its work on climate change.
• The House of the Euro celebrated its first year.
• Citizens’ support for the euro achieved a record high, underscoring the appreciation for the single currency.

ESMA issues supervisory guidelines to prevent market abuse under MiCA Regulation

On 29 April 2025, the European Securities and Markets Authority (ESMA) published the final report on guidelines on supervisory practices for competent authorities to prevent and detect market abuse under MiCA.

The guidelines will assist National Competent Authorities (NCAs) with effective and specific practices for combatting market abuse in crypto assets and set objectives for the NCA common supervisory culture. The guidelines will apply three months after being translated into all EU languages and published on ESMA’s website. ESMA recommend that NCAs commence with the implementation of the principles whilst awaiting the publication.

For more information on these topics please contact any member of A&L Goodbody's Financial Regulation Advisory team.

This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.