Payment Institutions and E-Money in Ireland: Central Bank Authorisation Guide

Payment institutions and e-money institutions are the firms that move and issue money without being banks, and in Ireland the Central Bank is the authority that decides whether they may operate. This guide explains how payment institutions and e-money fit into the Irish framework, how Central Bank authorisation works in outline, and what finance, compliance and operations teams in Dublin and elsewhere should check. Operational resilience is a related topic, covered in our guide to the Digital Operational Resilience Act for finance teams. This is a plain-English overview, not legal advice, and it deliberately leaves out capital amounts and other figures that change.

Who regulates payment institutions and e-money institutions in Ireland

According to the Central Bank of Ireland's payment authorisation page, the Central Bank is the competent authority for authorising both payment institutions (PIs) and electronic money institutions (EMIs). Its Payment Institutions page adds that firms must obtain authorisation before providing payment services, and that the Central Bank also supervises them to ensure and monitor compliance with the payment services rules.

The Central Bank's pages name the following legal building blocks:

• the European Union (Payment Services) Regulations 2018 (S.I. No. 6 of 2018), which transpose the second Payment Services Directive, Directive (EU) 2015/2366 (commonly called PSD2), and took effect on 13 January 2018;
• the European Communities (Electronic Money) Regulations 2011, as amended, which govern e-money institutions and were amended by the 2018 payment services regulations; and
• the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended, under which payment institutions and e-money institutions are designated persons.

What a payment institution is

The Central Bank describes a payment institution as a legal person, meaning it must be incorporated, that has been authorised to provide and execute payment services. The payment services listed in the Irish regulations include cash placement and withdrawal, execution of payment transactions such as direct debits, card payments and credit transfers, execution of payment transactions with a credit line, issuing or acquiring payment instruments, money remittance, payment initiation and account information.

The Central Bank also states that there is no small payment institution regime in Ireland. A firm that wishes to provide payment services must apply for payment institution authorisation.

What e-money is and who issues it

The Central Bank's Electronic Money Institutions page describes e-money as a digital payment instrument, in effect a digital form of cash. Under the definition on that page, e-money is monetary value stored electronically, issued on receipt of funds, and accepted as a means of payment by parties other than the issuer. An e-money institution is an undertaking authorised to issue e-money under the 2011 regulations. The Central Bank's pages also refer to registration as a small e-money institution, and its authorisation page directs applicants to contact the Payments Authorisation Team.

Account information service providers

Some firms only provide account information services. The Central Bank's authorisation page explains that these providers are registered rather than authorised, and the page states that capital and conditions do not apply to them. The Central Bank still assesses the suitability of all qualifying holders. After registration, anti-money laundering obligations apply if the firm is a designated person under the 2010 Act. To check a specific firm, use the Central Bank's registers.

How Central Bank authorisation works

The Central Bank's payment authorisation page sets out three stages. In outline:

• Stage 1, exploratory. A pre-application meeting is required. The applicant submits a Pre-Application Key Facts Document in advance, and the Central Bank then runs a key information check. The outcome is either progression to assessment, with a named case manager, or a note of issues that prevent progression.
• Stage 2, assessment. The Central Bank can ask for more information and hold meetings, and individuals proposed for pre-approval controlled function roles may be interviewed. The outcome is a letter saying the Central Bank is minded to authorise or register, or minded to refuse, in which case the applicant can make written submissions.
• Stage 3, decision. The firm receives either a letter granting authorisation or registration, or a letter of refusal.

The assessment looks at five areas, according to the Payment Institutions and Electronic Money Institutions pages: business model and financial resilience, governance, risk management (including operational resilience and safeguarding), anti-money laundering and counter-terrorist financing, and resolution and wind-up. The Central Bank also states that it expects Board and executive decision-making to take place within the State.

On timing, the page gives a service standard under which 90% of assessment-stage cases are to be completed within 90 business days, with the clock pausing while an information request is outstanding (and, in some cases such as complex or novel business models, it can be switched off). It also notes that the process can take much longer when applicants take time to supply the information required. The page says there is no application fee, although an annual industry funding levy applies after authorisation. Fees, service standards and processes can change, so confirm them on the Central Bank page on the day you plan an application.

What an application has to contain

The Central Bank's May 2025 guidance note on completing an application covers authorisation as a payment institution or e-money institution and registration as an account information service provider or small e-money institution. It says the Central Bank applies the European Banking Authority's guidelines on the information to be provided for authorisation and registration. According to that note, applicants should expect to provide:

• the completed application form and an anti-money laundering and counter-terrorist financing risk evaluation questionnaire (not required for account-information-only applicants);
• qualifying holder forms and fitness and probity questionnaires for people in pre-approval controlled function roles;
• three-year financial projections with explanatory notes; and
• descriptions of governance, risk management, outsourcing, business continuity, security and fraud arrangements.

The note also sets out initial capital requirements by type of firm. This guide does not reproduce those amounts, because capital rules are specific to each service and can change; use the current guidance note. The note adds that providing false or misleading information is an offence.

The April 2024 Pre-Application Key Facts Document shows how the Central Bank frames the first conversation. It asks about the business model, expected volumes, financial viability, regulatory capital, key risks, outsourcing, safeguarding arrangements and banking partners, business continuity and wind-down, governance and staffing, and shareholders.

Safeguarding of customer funds

Safeguarding is the protection of customers' money so that it is kept apart from the firm's own funds. The Central Bank lists it as a key area in authorisation. Its May 2025 guidance note describes expectations that users' funds are safeguarded and not used for the firm's own account, that segregated accounts are clearly designated, and that insurance or a comparable guarantee can be used where the rules allow.

The Central Bank's pages also record a January 2023 Dear CEO letter requiring firms to obtain a specific audit of their safeguarding compliance, with a Board-approved assertion on a description of their arrangements. Its December 2025 Payment and E-Money Newsletter returns to safeguarding after a thematic inspection and states that the Central Bank has no tolerance for weaknesses in safeguarding arrangements. It points to good practice such as daily reconciliation and staff training, and to weaknesses such as unclear reconciliation procedures and weak segregation of duties. The same newsletter says a new Head of Safeguarding role (PCF-56) is being introduced in 2026, that firms will be required to appoint an individual to it, and that further information will follow, so check the Central Bank's current communications.

Connected obligations for authorised firms

Authorisation is the start of the regulatory relationship, not the end. A few areas deserve early attention:

• Operational resilience. Digital operational resilience rules for financial entities are covered in the DORA guide linked above. The Central Bank's newsletter also lists a DORA Register of Information return in its 2026 returns calendar.
• Anti-money laundering. Because these firms are designated persons, the customer checks described in our guide to customer due diligence under the Criminal Justice Act 2010 are relevant to their onboarding processes.
• Sanctions. Payment flows raise sanctions exposure, which is the subject of our guide to financial sanctions and EU restrictive measures in Ireland.
• Qualifying holdings. The December 2025 newsletter explains that acquiring or increasing a qualifying holding must be notified to the Central Bank in advance, and that non-compliant acquisitions are void.

A changing EU framework

The Central Bank's pages describe the framework by reference to PSD2 and the 2011 e-money regulations. The European Commission has published a proposal for a directive on payment services and electronic money services, which, according to the EUR-Lex record, would repeal Directive (EU) 2015/2366 and the e-money directive. This guide does not cover that proposal's status or content. Before relying on any rule described here, check the Central Bank's current pages and the Official Journal for the legal position on the day.

Practical checks for finance and compliance teams

Our suggestion, if your organisation is considering a payments or e-money model, or relies on one:

• Work out which services you actually provide, and ask for legal advice on whether authorisation, registration or an exclusion applies before you build anything.
• Check the Central Bank's registers before you contract with a provider, and confirm the services it is permitted to offer.
• Ask providers how they safeguard customer money and how they would wind down.
• Keep records of your own due diligence, so you can show how you chose and monitor a provider.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Does Ireland have a small payment institution regime?

No. The Central Bank's authorisation page states that there is no small payment institution regime in Ireland, so a firm that wishes to provide payment services must apply for payment institution authorisation. The page does refer to registration as a small e-money institution and to registration of account information service providers.

Is there an application fee?

The Central Bank's page says there is no application fee, but that an annual industry funding levy applies after authorisation. Check the page on the day, as fees and levies can change.

How long does authorisation take?

The Central Bank gives a service standard under which 90% of assessment-stage cases are to be completed within 90 business days, but states that the clock pauses while information requests are outstanding and that the overall timeline depends heavily on how quickly the applicant supplies the information needed.

Are payment institutions subject to anti-money laundering law?

Yes. The Central Bank's pages state that payment institutions and e-money institutions are designated persons under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended.

Where do I find the capital requirements?

They are in the Central Bank's guidance note on completing an application, which sets initial capital by type of firm. This guide does not repeat them because they can change.

In short, treat authorisation as an evidence-led process: know your services, document your safeguarding and governance, and confirm every figure on the Central Bank's own pages before acting.