Ireland EMI Licence: Central Bank of Ireland Authorisation, Capital, Levy, Timeline and EEA Passporting

Who an Irish EMI suits, especially after Brexit

The Central Bank's own data describes the typical applicant: most payment and e-money applicants are groups setting up an Irish subsidiary, and passporting across the EEA is a significant feature of their plans. That fits UK EMIs, which lost their EEA passport on 1 January 2021, and non-EU groups that want an English-speaking, common law regulator in the euro area.

Ireland suits firms that can staff a real Irish company. The Central Bank expects senior appointments such as Chair and CEO to be in place at application, key role holders close enough to oversee operations, and the risk and compliance functions based in the firm. A firm that wants a light local footprint run from a group hub will find the Central Bank's expectations a poor fit.

There is also a lighter route. A small EMI can register under Regulation 33 of the Electronic Money Regulations, but that registration is valid only in Ireland and does not allow e-money to be issued in other Member States, so it does not solve the Brexit passport problem.

Initial capital and own funds

Regulation 13 sets initial capital at a minimum of €350,000, counted only from the core capital items the law allows. The Central Bank's Minded to Authorise letter states the capital it expects, and the applicant must be able to inject it before the final decision and fund its capital needs for the first three years, including under stress.

Once trading, own funds must be at least the higher of €350,000 and Method D, which is 2% of average outstanding e-money. If the EMI also provides payment services that are not linked to e-money, the Central Bank directs it to add an amount under Method A (based on fixed overheads), Method B (based on payment volume) or Method C (based on income). After reviewing the firm's risk management, the Central Bank may require up to 20% more own funds or allow up to 20% less.

Substance: PCF roles, local directors and staff

Ireland approves people, not just firms. Every Pre-Approval Controlled Function (PCF) holder needs Central Bank approval before taking up the role. For an EMI this normally covers the executive and non-executive directors, the Chair, the chair of the audit committee, the CEO, the Head of Finance, the Head of Compliance, the Head of Internal Audit, the Chief Risk Officer, the Head of AML (PCF-52) and, since 10 February 2026, the Head of Safeguarding (PCF-56). Candidates should expect an interview.

The board must have enough members and expertise to oversee the firm, with a balance of executive, non-executive and independent non-executive directors. The Central Bank expects key role holders to have sufficient proximity to oversee operations, and allows interim appointees only in exceptional cases. Applications proposing one person in three PCF roles have not been approved to date.

Staffing is phased. The Central Bank checks resources at four points: the Key Information Check, the Minded to Authorise letter, the authorisation letter and go-live. Firms with a Chair and CEO in place at application tend to move faster. Under the Central Bank's new fitness and probity guidance, separate lawyer or notary attestations are no longer needed in most PI and EMI cases: Irish residents go through Garda vetting and non-Irish residents provide police certificates where available.

Safeguarding, the safeguarding audit and the Head of Safeguarding

Regulation 29 of the Electronic Money Regulations requires an EMI to keep users' funds apart from all other money. Funds not paid out by the end of the business day after receipt must sit in a separate account at a credit institution or in secure, low-risk assets approved by the Central Bank. The alternative is an insurance policy or bank guarantee from outside the group for the same amount. Funds received by card or other payment instrument must be safeguarded no later than 5 business days after the e-money is issued.

The Central Bank says it has no tolerance for weaknesses in safeguarding. In January 2023 it reported that one in every four payment and e-money firms had found weaknesses in their own safeguarding, and it required every firm that safeguards to obtain a specific audit of its safeguarding compliance from an audit firm. Its May 2023 notice set the format: a board-approved description of the safeguarding arrangements, a reasonable assurance report from the auditor and a separate long-form review, due by 31 October 2023.

Applicants now inherit those standards. The Central Bank expects internal audit to review safeguarding at least once a year, annual compliance testing of safeguarding calculations and account letters, daily reconciliation with clear separation between the person who prepares it and the person who checks it, and a named Head of Safeguarding approved as PCF-56.

• - Thematic inspection findings (December 2025): reconciliation steps missing from procedures, second line staff doing first line safeguarding work, no escalation thresholds for incidents, and heavy concentration of funds at single banks
• - Insurance findings: policies held by the group rather than the Irish firm, unclear claim terms, and Irish teams that did not understand their own cover
• - Reconciliation error flagged: including negative customer balances, which understates the money that must be safeguarded
• - Central Bank expectation: insurance written in trust for users, with no condition that delays a payout

What the Central Bank's recent supervision and enforcement say

The Central Bank set out its expectations in Dear CEO letters of 9 December 2021 and 20 January 2023. The 2023 letter described a year of supervision more intense than it would expect for the sector, driven by weak governance, risk management and controls at some firms, and warned that strategic ambition was outpacing frameworks and capacity.

Two enforcement cases show where the line sits. On 21 November 2024 the Central Bank fined BlueSnap Payment Services Ireland Limited, a payment institution, €324,240 and reprimanded it for safeguarding breaches between January 2021 and December 2022, including failing to place customer funds in its safeguarding account and mixing them with other money. The High Court confirmed the sanction on 2 April 2025.

On 21 October 2026 the Central Bank reached a settlement with Coinbase Ireland Limited, an EMI, for breaches of the Electronic Money Regulations between 1 November 2020 and 19 August 2025. The firm had outsourced safeguarding to a US group company for over four years without enough local oversight or expertise. The Central Bank found that its designated safeguarding account showed a daily shortfall for at least 18 months, with a maximum daily shortfall of €3.4 million in 2023 and €5.2 million in 2024. The sanctions are a reprimand and a penalty of €4,646,597, reduced to €3,252,618 after the settlement discount, subject to High Court confirmation.

Passporting from Ireland to the EEA

An Irish EMI can issue, distribute and redeem e-money and provide payment services in other EEA states. It can do this without a local presence (freedom to provide services), through a branch, or through agents and distributors. Each route starts with a notification to the Central Bank on the forms set by the EBA regulatory technical standards (Commission Delegated Regulation (EU) 2017/2055).

Once the information is complete, the Central Bank sends it to the host regulator within one month. For an agent or branch, the host regulator assesses it and the Central Bank must decide within 3 months whether to enter the agent or branch in its register. The agent or branch can start only once it is on the register, and the firm must tell the Central Bank the date it starts.

• - Services without a local presence: one notification per host state
• - Branch: management, organisational structure and AML controls of the branch
• - Agents: identity, management and AML controls of each agent, and a notice when each agent starts
• - Distributors of e-money: notification of each distributor and its host state
• - Changes: notify the Central Bank without delay so it can update host regulators

Ongoing reporting and supervision

Irish EMIs file the E-Money Institution Accounts return (EIA) and the E-Money Supplementary return (EIS) every quarter in XBRL format. Audited annual accounts are due within 6 months of the financial year end, and the external auditor sends the Central Bank its management letter and an annual Statutory Duty Confirmation within one month of the audit report.

Rule changes to plan for in 2026 and 2027

• - Head of Safeguarding: PCF-56 in force since 10 February 2026 under S.I. No. 20 of 2026
• - Revised Consumer Protection Code: in effect from 24 March 2026, with more emphasis on digital services, frauds and scams and customers in vulnerable circumstances
• - Industry funding levy: the Central Bank published CP172 on levy proposals on 25 September 2026
• - Instant payments: EMIs in euro area states must be able to send and receive instant euro credit transfers by 9 April 2027
• - EU AML Regulation (EU) 2024/1624: applies from 10 July 2027. AMLA plans to begin direct supervision of selected firms during 2028
• - PSD3 and the Payment Services Regulation: political agreement reached on 27 November 2025 and approved by the European Parliament's ECON committee on 5 May 2026. The new directive covers payment and e-money services together and still needs formal adoption