Regulatory overview
- Scope
- Iceland, European Economic Area
- Authorities
- Regulatory index
- Latest regulatory change
Iceland, European Economic AreaIceland applies MiCA through Act 101/2025 from 1 January 2026, with the Central Bank as competent authority. Former registration ceased to permit ordinary continuity in July. Tokenized securities also have the DLT infrastructure framework under Act 56/2024. Both require distinctions between assets, services and holders’ rights; a CASP licence does not cover every issuance.
In Iceland, digital asset projects need to check how European rules enter the European Economic Area and Icelandic law. Domestic MiCA and digital resilience dates should not be inferred automatically from the European Union timetable.
The Central Bank of Iceland combines financial supervision and fintech guidance. This guide distinguishes authorisations from preliminary assistance and connects crypto-asset services, tokenized securities and winding-down procedures to client rights.
How MiCA and EEA rules are implemented
Act 101/2025 implements MiCA in Iceland from 1 January 2026, with European Economic Area, EEA, adaptations. Domestic application differs from the EU timetable. Financial instruments and deposits remain outside MiCA and must be assessed under the regimes applicable to their legal nature.
Former anti-money laundering registration no longer permits ordinary operations. The Central Bank's clarification of 10 July 2026 requires unauthorised providers to stop new onboarding and marketing. It also explains that orderly closure did not require all asset deliveries before 1 July or prescribe a particular sale or conversion method.
What the Central Bank of Iceland supervises
Article 3 designates the Central Bank of Iceland as competent authority, with responsibilities for its financial supervisory function and the EFTA Surveillance Authority within the EEA framework. The bank's MiCA guidance distinguishes issuers and providers. CASP permissions do not replace requirements for asset-referenced tokens, ARTs, or e-money tokens, EMTs.
The bank operates a fintech helpdesk where firms can describe activities through a checklist and obtain guidance on potential supervision. This helps define an application. An indicative response or meeting does not constitute temporary licensing or remove the conditions applicable to the proposed product.
Which permission each service needs
A CASP application must reflect actual services and include MiCA's required information on organisation, controls and safeguarding. Certain financial entities may use Article 60 notification for activities allowed by their status. These routes should not be equated, nor should notification be extended to services outside its scope.
Cross-border EEA services require verification of home-state entitlement and completion of the applicable procedure. Assessment must identify the entity contracting with clients, its establishment and functions. Another group company's authorisation or a marketing statement referring to MiCA does not itself establish the specific provider's status.
What Iceland’s DLT infrastructure framework allows
Iceland implemented the European DLT infrastructure pilot through Act 56/2024, effective from 5 July 2024. Article 5 assigns the grant and withdrawal of specific permissions and exemptions to financial supervision. The regime concerns eligible financial instrument infrastructures rather than every business using tokens.
The Financial Instruments Markets Act 115/2021 expressly refers to the DLT framework for instruments issued, recorded, transferred and stored using that technology. Projects need documented holder rights, entitlement, transfer formalities and connections to applicable registers. Infrastructure permission does not itself establish ownership of real estate or another referenced asset.
Which duties custody and transfers involve
DORA was implemented through Act 78/2025 from 1 January 2026. It covers authorised CASPs and ART issuers, among other entities, with obligations reflecting scope and proportionality. Incident management, testing and ICT provider oversight must be integrated into operations, including service recovery and outsourcing agreements.
The Central Bank also publishes guidance on TFR II and transfer information. Systems must address originator, beneficiary, data verification and missing information. This does not impose identical procedures on every movement between individuals: scope depends on provider involvement and the implemented regulation's conditions.
How to prepare the project’s domestic assessment
Prepare a description of the asset, services and participating entities and compare it with Icelandic MiCA and financial instrument legislation. The fintech checklist can organise perimeter questions, but the formal application must establish the requested permission and requirements.
For DLT infrastructure, identify the system type, eligible instruments and necessary exemptions. Custody also requires continuity and asset return arrangements. Winding down should follow Central Bank clarifications without inferring a sale or conversion requirement absent from the communication.
To understand how this framework applies to your project, discuss your case with our team.
Key takeaways
- Iceland is in the EEA; domestic MiCA application began in January 2026.
- Wind-down of unauthorised providers does not impose a general forced asset sale.
- Act 56/2024 implements the DLT Pilot Regime for eligible infrastructures.
- DORA applies domestically from January 2026 within its own perimeter.
Regulatory milestones
National DLT infrastructure framework
Act 56/2024 takes effect with specific permissions for eligible infrastructures.
Domestic MiCA and DORA application
Acts 101/2025 and 78/2025 begin applying within their respective scopes.
Orderly wind-down clarification
The Central Bank clarifies its instructions after transition ends.
Frequently asked questions
Yes. Act 56/2024 implements the DLT Pilot Regime with specific permissions and exemptions for eligible infrastructures. It does not replace analysis of the represented right or authorise every issuance or platform.
On 10 July 2026 the Central Bank clarified that wind-down instructions did not prescribe a particular delivery, conversion or disposal method. Return of assets must respect client rights and applicable law.
Act 101/2025 establishes domestic application from 1 January 2026 with EEA adaptations. The relevant Icelandic timetable must be used. Althingi · Act 101/2025.
It describes the activity and supports supervisory perimeter guidance. The enquiry replaces neither financial authorisation nor service conditions. Central Bank · Fintech enquiries.
Act 56/2024 implements the pilot for eligible financial instruments and infrastructure, with specific permissions and exemptions. It is not general digital asset entitlement. Althingi · Act 56/2024 DLT.
