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EMT (Title IV) and ART (Title III) authorisation and white-paper requirements are fully in force, applied directly from MiCA Level 1/2/3 text with no Irish-specific carve-out; the EBA takes over direct supervision of 'significant' tokens. Coinbase Ireland separately holds an EMI authorisation distinct from its crypto-asset-service permissions.
A contextual entity-level fact rounds out the module: Coinbase Ireland Limited separately holds authorisation as an electronic money institution from the Central Bank of Ireland, distinct from and additional to its MiCA and prior VASP crypto-asset-service authorisations. This illustrates a pattern likely to recur across other Irish-authorised entities operating dual e-money and crypto-asset-service permissions, though no other instances have been substantiated this cycle.
No corrections, downgrades, or Challenger flags were raised against this module's claims in this cycle, and the module's trajectory is assessed as stable. The classification categories themselves - e-money tokens, asset-referenced tokens, and by implication the residual 'other crypto-assets' category under MiCA - are not subject to Irish discretion in the way the licensing module's transitional timeline was; they flow directly from EU Level 1 text.
Outlook
Continued stability is the base case for this module: token classification categories are unlikely to diverge from the EU-wide MiCA framework absent a Level 2/3 amendment or EBA guideline change, neither of which has surfaced in sourcing this cycle. The main watch item is whether any additional Irish-authorised entity is designated the issuer of a 'significant' EMT or ART, which would trigger the EBA's joint or direct supervisory role described in the stablecoin module and merit a follow-up claim tying that designation to a specific Irish entity.
no periodic updates on record for this sub-brief
Sources and findings (3)
- T1 · Official Journal of the European Union / EUR-LexMiCA Title IV e-money token issuance requirement — E-money tokens issued or offered in Ireland must be issued by an authorised credit institution or electronic money institution and comply with MiCA Title IV requirements.retrieved M4bindingin force
- T1 · European Banking AuthorityMiCA Title III asset-referenced token authorisation requirement — Asset-referenced tokens offered or admitted to trading in Ireland require issuer authorisation and a MiCA-compliant white paper under Title III, with EBA taking over direct supervision if the ART is designated 'significant'.retrieved M4bindingin force
- T4 · The BlockCoinbase Ireland Limited EMI authorisation — an electronic money institution from the Central Bank of Ireland, distinct from and additional to its MiCA/VASP crypto-asset service authorisations.retrieved M2non-binding