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Domestic
European
Related areas
Central Bank of Ireland updates the Authorisation process for Retail Intermediaries
On 20 June 2025, the Central Bank of Ireland (CBI) updated the available information on its website concerning the authorisation process for retail intermediaries.
Central Bank of Ireland’s options and national discretions
On 27 June 2025, the CBI updated its options and national discretions under Regulation (EU) No 575/2013 on prudential requirements for credit institutions and investment firms, and under Directive (EU) 2013/36 on access to the activity of credit institutions and the prudential supervision of credit institutions and investment firms.
Commencement order signed on Access to Cash legislation
On 16 June 2025, a commencement order was signed in respect of the Finance (Provision of Access to Cash Infrastructure) Act 2025 (Access to Cash Act).
The Access to Cash Act entered into force on 30 June 2025.
European Commission updates list of high-risk countries to strengthen international fight against financial crime
On 10 June 2025, the European Commission updated the list of high-risk countries which have deficiencies in their national anti-money laundering and countering the financing of terrorism (AML/CFT) regimes.
Those third-country jurisdictions added to the list are: Algeria, Angola, Côte d'Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela. EU entities subject to the AML/CFT regulations are required to apply enhanced measures for transactions involving these third countries.
The European Commission also delisted the following countries: Barbados, Gibraltar, Jamaica, Panama, Philippines, Senegal, Uganda and United Arab Emirates.
The updated list, which will take the form of a delegated regulation, will enter into force after examination and non-objection of the European Parliament and the Council within a period of one month.
ESMA provides advice and recommendations to streamline prospectuses
On 12 June 2025, the European Securities and Markets Authority (ESMA) published its final reports on the Prospectus Regulation and on civil prospectus liability. The reports provide recommendations intended to facilitate capital market activity by reducing the regulatory burden and it also includes the results of ESMA’s recent call for evidence on civil prospectus liability.
AMLA appoints Juan-Manuel Vega Serrano as Vice Chair
On 13 June 2025, the newly established Anti-Money Laundering Authority (AMLA) appointed Juan-Manuel Vega Serrano as the Vice-Chair of the Authority. The Vice Chair previously held several prominent roles in Spain’s higher civil service and helped to shape the anti-money laundering and counter-terrorist financing policies both nationally and internationally.
European Council and European Parliament agree on a shorter settlement cycle
On 18 June 2025, the European Council and the European Parliament reached a provisional agreement on making transactions in transferable securities more efficient. The objective of this agreement is to shorten the settlement cycle for transactions executed on EU trading venues from the current T+2 (two business days) to T+1 (one business day).
These new rules take the form of an amendment to Regulation 909/2014 on improving securities settlement in the European Union. However, the new rules won’t affect certain securities financing transactions (SFTs) where those SFTs are documented as single transactions composed of two linked operations.
Once the new rules are adopted by both institutions, they will apply from 11 October 2027.
Joint EBA and ESMA guidelines on the assessment of the suitability of the members of the management body of issuers of asset-referenced tokens and of crypto-asset service providers
On 18 June 2025, ESMA and the European Banking Authority (EBA) updated the guideline on assessment of the suitability of the members of the management body of issuers of asset-referenced tokens and of crypto-asset service providers with a compliance table highlighting the compliance of national competent authorities with the provisions of the guideline.
ESMA publishes the final report on the active account requirement under EMIR 3
On 19 June 2025, ESMA published its final report concerning the regulatory technical standards (RTS) which specify the conditions to be met under which the active account requirement as specified in Regulation (EU) No 648/2012 on OTC derivatives, central counterparties and trade repositories (EMIR). The final report sets out draft RTS which further specify the requirements related to Article 7a, paragraph 3, points a, b, and c of EMIR, the conditions for stress testing such conditions, the details of the representativeness obligation, and also the details for reporting under Article 7b of EMIR.
The final report and the draft RTS will be submitted to the European Commission who will then have three months to decide whether or not to adopt the RTS in the form of a Commission delegated regulation.
The European Commission adopts Delegated Regulation under MiCAR on liquidity management for ARTs and EMTs
On 27 June 2025, the European Commission adopted a delegated regulation supplementing Regulation (EU) 2023/1114 on markets in crypto-assets (MiCAR), regarding RTS specifying the minimum contents of the liquidity management policy and procedures for issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs).
The RTS aims to ensure that issuers have robust liquidity frameworks which are capable of withstanding both normal and stressed market conditions.
EBA publishes a no action letter on the interplay between the Payment Services Directive and the Markets in Crypto-Assets Regulation
On 10 June 2025, the EBA published a no action letter on the interplay between Directive (EU) 2015/2366 on payment services in the internal market (PSD2), and Regulation (EU) 2013/1114 on MiCAR.
In assessing the relevant provisions under both regimes, the EBA advised national competent authorities (NCAs) to view the transfer of crypto assets as a payment service under PSD2 if they involve EMTs and are also carried out by the entities on their client’s behalf.
The EBA also set out the applicable requirements with regard to the custody and administration of EMTs as a payment service. It noted that custodial wallets should be regarded as a payment account where that wallet is held in the name of one or more clients and also allows the sending and receiving of EMTs to/from third parties.
Based on the above, the EBA noted that these services require a PSD2 authorisation however, the EBA advises NCAs not to require such authorisation until 2 March 2026 and to apply a streamlined procedure making use of information that legal entities provide during their crypto asset service provider authorisation process.
Once an authorisation is granted, NCAs should not prioritise the supervision and enforcement of various PSD2 elements such as safeguarding, and information disclosure to consumers. However, NCA’s are advised to still insist on full compliance in other areas such as strong consumer authentication, reporting payment fraud, and own funds calculation requirements.
The EBA also advised NCAs not to consider the following as payment services: the ‘exchange of crypto-assets for funds’, the ‘exchange of crypto-assets for other crypto-assets’, and cases where crypto-asset service providers intermediate the purchase of crypto-assets with EMTs. These scenarios are therefore excluded from the scope of PSD2.
ESMA consults on margin transparency and cost of clearing
On 24 June 2025, ESMA launched two public consultations following the review of the Regulation (EU) 2024/2987 (EMIR).
The two consultations are seeking stakeholder views in relation to:
Responses to the consultation paper must be submitted by 8 September 2025.
FATF urges stronger global action to address illicit finance risks in virtual assets
On 26 June 2025, the Financial Action Task Force (FATF) published its sixth targeted update on the global implementation of AML/CFT measures to virtual assets and virtual asset service providers (VASPs).
It noted that progress had been made since 2024 by jurisdictions with materially important VASP activity to develop or implement AML/CFT regulation and in respect of taking enforcement and supervisory action.
However, FATF also noted that there is a need for further work on licencing and registration, as jurisdictions face difficulties in identifying the natural or legal persons conducting VASP activities.
Commission delegated regulation with regard to regulatory technical standards specifying the minimum contents of the liquidity management policy and procedures for certain issuers of asset- referenced tokens and e-money tokens
On 27 June 2025, the European Commission published its draft delegated regulation on RTS specifying the minimum contents of the liquidity management policy and procedures for certain issuers of asset- referenced tokens and e-money tokens. The draft RTS establish the minimum amount of deposits in each official currency referenced, and also set out the procedures for identifying, measuring and managing liquidity risk in the context of the applicable liquidity management policy and procedures. The draft RTS also set out requirements pertaining to contingency policies, mitigation tools and minimum aspects of liquidity stress testing.
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.