5 reasons why Ireland is the top ICO country in the ESMA register (MiCA)

The implementation of the Markets in Crypto-Assets Regulation (MiCA) has created a seismic shift in the European digital asset landscape. For the first time, crypto-assets are governed by a unified rulebook across 27 member states, replacing a patchwork of national laws with a single, harmonious framework. Central to this new regime is the concept of the “Home Member State”, the jurisdiction where a project chooses to submit its White Paper and anchor its compliance.

As the dust settles and the Interim MiCA Register begins to populate, one trend has become undeniably clear: Ireland has emerged as a dominant force. A review of the current filings (visible in the OTHER.csv dataset) reveals a disproportionately high volume of white paper notifications submitted to the Central Bank of Ireland (CBI) compared to other National Competent Authorities.

From global giants like Kraken (operating as Payward Global Solutions) to innovative foundations like VeChain and Moonwell, the industry is voting with its feet. But why Ireland? Why are so many projects choosing Dublin over Paris, Frankfurt, or Vilnius?

1. The “CASP Gravity Well”: Home to the World’s Biggest Exchanges

The most immediate reason for Ireland’s prominence in the ESMA Register is the presence of major Crypto-Asset Service Providers (CASPs). Under MiCA, the obligation to publish a white paper typically falls on the issuer. However, if the issuer is not established in the EU, or has not published a white paper for an older asset, the responsibility shifts to the trading platform (the CASP) that wishes to list the token.

The register reveals that Payward Global Solutions LTD (trading as Kraken) has submitted a massive volume of white papers to the Central Bank of Ireland for assets ranging from Solana (SOL) and Cardano (ADA) to Dogecoin and Optimism.

This phenomenon creates a “gravity well.” Because major exchanges like Kraken and Coinbase have chosen Ireland as their European regulatory hub, they have established deep lines of communication with the Central Bank of Ireland. For a new crypto entrepreneur, this is a crucial commercial signal. If the entities responsible for the liquidity of the entire market feel comfortable navigating Irish regulations for hundreds of assets, it validates the jurisdiction’s operational efficiency.

Launching your token in the same jurisdiction where major CASPs are domiciled can streamline the listing process. The regulatory expectations are aligned, and the legal language used in your white paper will be familiar to the compliance teams of these top-tier exchanges.

For more on how exchanges and issuers interact under this framework, visit our guide on MiCA Token Issuance.

2. The Strategic Gateway for Non-EU Issuers

MiCA mandates that to offer a crypto-asset to the public in the EU, the offeror must be a legal person. However, the crypto industry is global. Many of the most prominent projects are established in offshore jurisdictions like the British Virgin Islands (BVI), the Cayman Islands, or Singapore.

The ESMA register shows that Ireland is the preferred “bridge” for these non-EU entities. For example:

• VeChain Foundation chose Ireland for its notification;
• Hedera Hashgraph (US-based) was notified via Ireland;
• Zora Labs (US-based) chose the Irish jurisdiction.

Why is this happening? Under MiCA Article 8, an offeror established in a third country must notify their white paper to the competent authority of the Member State where they intend to offer the crypto-assets for the first time.

Ireland is the only native English-speaking country in the Eurozone (post-Brexit). For US, UK, and Asian projects, this removes a massive barrier to entry. There is no need to translate complex technical white papers into French, German, or Spanish to satisfy the local regulator (though summaries may still need translation for host member states). The ability to conduct all regulatory business in English makes Ireland the most logical, cost-effective, and low-friction entry point for international projects seeking access to the European Single Market.

3. A Common Law System in a Civil Law Union

Legal certainty is the bedrock of investment. Ireland’s legal system is based on Common Law, similar to the systems in the United States, the United Kingdom, Australia, Singapore, and Hong Kong. In contrast, the vast majority of EU member states operate under Civil Law systems.

For crypto entrepreneurs and their investors, the distinction is vital. Common Law is widely regarded as being more commercially focused, flexible, and predictable regarding business contracts and financial instruments.

• Predictability: Concepts such as “trusts,” fiduciary duties, and beneficial ownership are clearly defined in Irish law, which is essential for the complex structures often used in Web3 (e.g., Foundations, DAOs, and SPVs);
• Compatibility: Most international crypto projects are structured using legal templates derived from Anglo-American law. Adapting these structures to an Irish vehicle is significantly easier than adapting them to a German GmbH or a French SAS.

By choosing Ireland, issuers can leverage a legal environment that aligns with the global standard for finance, while gaining the full benefits of EU compliance. This unique dual advantage, Common Law flexibility plus EU regulatory passporting, is a primary driver of the volume seen in the OTHER.csv register.

To understand how to structure your Irish entity effectively, review our specific page on MiCA Token Issuance in Ireland.

4. The “Premium” Badge: Regulatory Credibility

Not all jurisdictions are created equal in the eyes of investors. While MiCA harmonises the rules, the perception of supervision varies. The Central Bank of Ireland (CBI) has a reputation for being rigorous, detailed, and conservative.

This might sound like a hurdle, but for serious projects, it is a commercial asset.

• Anti-Scam Signal: The CBI’s scrutiny on “Fit and Proper” assessments for directors and its refusal to entertain “brass-plate” (shell) companies acts as a filter;
• Banking Access: Ireland is home to a sophisticated banking sector. Banks are generally more willing to provide accounts to crypto projects that have engaged with a tier-one regulator like the CBI, compared to jurisdictions with lighter supervision.

The register listing for projects like Moonwell Foundation or MANTRA Chain Association signals to the market that these projects have substance. They are not merely paper companies; they have navigated a serious compliance process. In a market recovering from high-profile collapses, this regulatory “stamp of approval” (even if technically a notification) serves as a powerful marketing tool for institutional investors who require assurance of governance and compliance standards.

5. Efficient Classification of “Other Crypto-Assets”

The vast majority of entries in the Irish section of the register fall under Title II: Other Crypto-Assets. These are utility tokens or assets that are not Asset-Referenced Tokens (stablecoins backed by a basket of assets) or E-Money Tokens (fiat-pegged stablecoins).

Ireland has streamlined the notification process for this category. While ARTs and EMTs require a heavy authorisation process involving capital requirements and direct supervision, “Other Crypto-Assets” require a notification procedure.

• Speed: The CBI reviews the notification to ensure the White Paper contains all mandatory disclosures (rights, risks, technology, issuer identity). If compliant, the project can typically launch after the mandatory 20-working-day notification period;
• Clarity: The Irish framework clearly delineates what falls into this “lighter” category versus the heavy-duty stablecoin categories.

This efficiency allows projects to launch quickly while remaining fully compliant. The register shows that many DeFi protocols and infrastructure projects (e.g., Sui, Sei, Worldcoin via Kraken notifications) are categorized this way. By offering a clear path for utility tokens that avoids the heavy capital requirements of banking-style regulation, Ireland facilitates innovation without sacrificing oversight.

For assistance in determining if your token qualifies as an “Other Crypto-Asset” or requires full authorisation, visit our MiCA Regulation page.

How to Leverage the Irish Advantage for Your ICO

The data is clear: Ireland is the current leader for white paper submissions in the EU. For an entrepreneur, following this path involves a structured approach to compliance that turns regulatory necessity into a competitive advantage.

Step 1: Accurate Classification

Before approaching the CBI, you must be certain of your asset class.

• Utility/Other Crypto-Assets: Most projects fall here. You need a white paper notification;
• Asset-Referenced Tokens (ARTs): If your token references a basket of currencies or assets to maintain value, you face a rigorous authorization process;
• E-Money Tokens (EMTs): If you are pegging to a single fiat currency, you likely need to be a licensed Electronic Money Institution.

Misclassification is a critical risk. The CBI will reject a notification if a token masquerading as a utility token actually functions as a stablecoin or financial instrument.

Step 2: Establish Irish Substance

You cannot simply mail a white paper to Dublin. You need a legal person established in the Union. In Ireland, this means incorporating a company (LTD or DAC) and ensuring it has real “mind and management” within the country. This includes having local directors and a physical presence.

Step 3: The White Paper Drafting

Your white paper is no longer just a marketing deck; it is a liability document. Under MiCA Article 6, it must contain specific, standardized information regarding the offeror, the project, the rights attached to the token, the underlying technology, and the environmental impact. It must also include a prominent disclaimer that the paper has not been approved by the authority (for Title II tokens).

Step 4: Notification and Passporting

Once drafted, the white paper is notified to the CBI. After the required period (usually 20 working days), you may publish the white paper and commence the offer. Crucially, you must simultaneously provide a list of other host Member States where you intend to market the token. The CBI then communicates this to the other regulators, activating your EU Passport. This allows you to market your token across the entire EEA without further local filings.

For ongoing management of this process, including post-issuance reporting, refer to our MiCA Compliance services.

Willing to Join the Party?

The sheer volume of activity in the Irish section of the Interim MiCA Register is not a coincidence. It is the result of a strategic convergence: the presence of global CASPs, a business-friendly Common Law system, the English language advantage, and a regulator that offers hard-won credibility.

For crypto entrepreneurs, Ireland offers the optimal balance between the ease of doing business and the regulatory rigour required to attract institutional capital. It is the gateway to Europe for the world’s most ambitious Web3 projects.

However, navigating the Central Bank of Ireland’s expectations and drafting a MiCA-compliant white paper requires specialized expertise. A misstep in classification or a failure in “substance” can lead to delays or rejection.

LegalBison is here to ensure your launch is successful. As legal experts specialized in the FinTech industry, we can assist entrepreneurs and companies with the whole process of registration, token issuance, and compliance. From incorporating your Irish entity to drafting the white paper and managing the notification with the Central Bank, our team provides the turnkey support you need to join the leaders on the European stage.