Central Bank of Ireland publishes Markets Update No 3 of 2026

On 19 March 2026, the Central Bank of Ireland (the Central Bank) published Issue No 3 2026 of its regular Market Update, in which it sets out alerts of interest to Irish regulated firms and other market participants. For our summaries of the previous issues, please see the right-hand column of this page.

The new update contains three items:

EBA decision on arrangements for the ISDA Standard Initial Margin Model validation

On 26 February 2026, EBA published its decision concerning arrangements for the Initial Margin Model Validation of ISDA SIMM. This entered into force on 1 March 2026.

The decision details

• operational arrangements for the validation function, including onboarding and application procedures

• governance and cooperation mechanisms with competent authorities and ISDA and

• the criteria for ongoing monitoring and assessment of SIMM model changes.

The EBA's central ISDA SIMM validation function is operational and applies as of 1 March 2026.

Amended MiFID client asset regulations published

On 5 March 2026, the European Union (Markets in Financial Instruments) (Amendment) (No. 2) Regulations 2026 (S.I. No. 81 of 2026) were published.

These amend client asset provisions in Paragraph 1(3) of Schedule 3 to the European Union (Markets in Financial Instruments) Regulations 2017 (S.I. No. 375 of 2017) and delete Paragraph 1(4).

The amended provisions come into force on 31 August 2026. 

Central Bank Discussion on Distributed Ledger Technology (DLT) & Tokenisation in Financial Services

On 5 March 2026, the Central Bank published DP 12, "DLT & Tokenisation in Financial Services".

In the DP, the Central Bank examines the benefits, the enablers, sectoral considerations and risks associated with DLT and tokenisation in financial services and how regulation and supervision may need to evolve in response.

The consultation period closes on 5 June 2026.

The Central Bank intends to use the DP as a basis for structured engagement with domestic and international stakeholders on the opportunities, challenges, enablers and risks arising from DLT and tokenisation - responses to the DP will inform its thinking on, and approach to these issues.

A feedback statement will be published in due course and this will assess, in light of feedback from the consultation process, whether existing policy and regulatory approaches are adequate to both allow the benefits of integrating DLT into financial services to be achieved and the risks to be managed.

For our summary of the DP, see here.