Ireland / European Union

Ireland Payment Institution Licence: Central Bank of Ireland Authorisation, Capital, Own Funds, Timeline and Passporting

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Ireland payment institution authorisation: €20,000 to €125,000 capital, Methods A to C, no Central Bank fee, levy from €6,625, PCF-56 and real 2025 timelines.

€20,000 to €125,000 capitalNo Central Bank application feeLevy from €6,625 a year
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Key dates for 2026 and 2027

10 February 2026PassedPCF-56 Head of Safeguarding takes effect for Irish payment and e-money institutions.
1 March 2026PassedDeadline for CASPs handling e-money tokens to hold PI authorisation or partner with a payment service provider, under the EBA no action letter.
24 March 2026PassedThe revised Consumer Protection Code takes effect for regulated firms, including payment institutions.
25 September 2026PassedThe Central Bank publishes CP172 on industry funding levy proposals.
9 April 2027UpcomingPayment institutions in euro area states must be able to send and receive instant euro credit transfers.
10 July 2027UpcomingThe EU Anti-Money Laundering Regulation (EU) 2024/1624 applies to payment institutions and other obliged entities.

The short answer

An Irish payment institution (PI) is a company authorised by the Central Bank of Ireland under Regulation 18 of the European Union (Payment Services) Regulations 2018 to provide payment services such as payment accounts, money transfers, card issuing and acquiring, money remittance and payment initiation. Initial capital is €20,000 for money remittance only, €50,000 for payment initiation and €125,000 for the account and transaction services. Ireland has no small payment institution regime, so every PI needs full authorisation. The Central Bank charges no application fee; authorised firms pay an annual industry funding levy with a minimum of €6,625. The law sets a 3-month decision period for a complete application, but the Central Bank's published average for payment and e-money firms was 763 days from application to authorisation in 2025. Every PI that holds customer funds must safeguard them, and since 10 February 2026 must have an approved Head of Safeguarding (PCF-56). An Irish PI can passport its services across the EEA.

Key facts at a glance

RegulatorCentral Bank of Ireland, Payments Authorisation Team
Legal basisEuropean Union (Payment Services) Regulations 2018 (S.I. No. 6 of 2018), Regulation 18
Initial capital€20,000 money remittance only; €50,000 payment initiation; €125,000 for any of the services in paragraphs 1 to 5 of the Schedule (Regulation 8)
Ongoing own fundsHigher of initial capital and Method A, B or C as the Central Bank directs (Regulations 9 and 11), adjustable by 20% either way
Application feeNone. Annual industry funding levy after authorisation, minimum €6,625
Small PI regimeNone in Ireland. Every firm providing payment services needs full PI authorisation
Account information onlyRegistration as an Account Information Service Provider (AISP): no initial capital, professional indemnity insurance required
Statutory decision period3 months from a complete application (Regulation 23)
Real-world timingAverage 763 calendar days from application to authorisation for payment and e-money firms in 2025; shortest 497 days
Head officeA PI with its registered office in Ireland must have its head office in Ireland and carry out part of its payment business there (Regulation 21)
PassportYes, across the EEA by services, branch or agents

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What is the Ireland Payment Institution Licence?

An Irish payment institution licence is the Central Bank of Ireland's authorisation for a non-bank company to provide payment services as a business. The services are listed in the Schedule to the Payment Services Regulations 2018: (1) placing cash on a payment account, (2) cash withdrawals, (3) executing payment transactions such as direct debits, card payments and credit transfers, (4) the same when covered by a credit line, (5) issuing payment instruments or acquiring card payments, (6) money remittance, (7) payment initiation services and (8) account information services.

A PI moves money for customers but does not hold stored value for them to spend later. If customers keep a balance that they can use with other businesses, the firm is usually issuing e-money and needs EMI authorisation instead.

The licence comes with an EEA passport, so a PI authorised in Ireland can serve customers in other EEA states through cross-border services, branches or agents. The Central Bank expects the same local substance from a PI as from an EMI: a real Irish board, approved senior managers and local control of risk, compliance and safeguarding.

Who needs an Ireland Payment Institution Licence?

Any company that provides payment services in or from Ireland as a regular business needs PI authorisation, unless it is a bank, an EMI, a registered AISP or covered by a specific exclusion.

  • - Card acquirers and payment facilitators that collect card payments for merchants
  • - Money remittance and cross-border transfer firms
  • - Payment account providers that do not hold stored e-money balances
  • - Payment initiation service providers (open banking payments)
  • - UK payment institutions that need an EU entity after losing the passport on 1 January 2021
  • - Crypto-asset service providers handling e-money tokens, which the Central Bank says must either be authorised as a PI or partner with a payment service provider

The first misconception is that a small firm can register instead of applying. Ireland has no small payment institution regime: the Central Bank states that every firm wishing to provide payment services must apply for authorisation as a payment institution. The second is that a lower capital tier means a lighter process. Initial capital starts at €20,000 for money remittance, but the Central Bank applies the same expectations on governance, PCF roles, safeguarding and wind-down planning to PIs and EMIs. The third is that exclusions are self-certifying. Firms relying on the limited network or electronic communications exclusions must notify the Central Bank under Regulations 45 and 46, and the Central Bank does not advise whether a service qualifies.

Payment services, capital tiers and AISP registration

Capital follows the highest-tier service applied for. A firm combining money remittance with card acquiring needs €125,000.

Schedule paragraphServiceInitial capital
1 and 2Cash placed on or withdrawn from a payment account, and operating that account€125,000
3Executing payment transactions: direct debits, card payments, credit transfers€125,000
4Executing payment transactions covered by a credit line€125,000
5Issuing payment instruments or acquiring payment transactions€125,000
6Money remittance€20,000 if this is the only service
7Payment initiation services€50,000
8Account information servicesNo capital; AISP registration with professional indemnity insurance

Source: Payment Services Regulations 2018, Regulation 8 and the Schedule.

Own funds: Methods A, B and C

After authorisation a PI's own funds must not fall below the higher of its initial capital and the requirement under the method the Central Bank directs. The Central Bank names the method in the authorisation and may require up to 20% more or allow up to 20% less after reviewing the firm's risk management. A PI offering only payment initiation, or payment initiation with account information, holds own funds equal to its initial capital, and an AISP has no own funds requirement.

Method A is 10% of the previous year's fixed overheads (or projected overheads in year one). Method B applies a sliding scale to payment volume, defined as one twelfth of the previous year's total payment transactions. Method C applies a sliding scale to an income indicator made up of interest income and expense, commissions and fees and other operating income. Methods B and C are multiplied by a scaling factor of 0.5 for money remittance only and 1 for services in paragraphs 1 to 5.

Monthly payment volumeRequirement
Up to €5 million4% of payment volume
€5 million to €10 million€200,000 plus 2.5% of the amount above €5 million
€10 million to €100 million€325,000 plus 1% of the amount above €10 million
€100 million to €250 million€1,225,000 plus 0.5% of the amount above €100 million
Above €250 million€1,975,000 plus 0.25% of the amount above €250 million

Source: Payment Services Regulations 2018, Regulations 9 to 16.

Substance: PCF roles, board and local functions

Every PCF holder needs Central Bank approval before taking up the role. For a PI this normally covers 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 the Head of Safeguarding (PCF-56). Candidates should expect an interview, and the Central Bank expects the firm to have done its own due diligence first.

The board needs a balance of executive, non-executive and independent non-executive directors. Key role holders must have sufficient proximity to oversee operations. Proposals for one person to hold three PCF roles have not been approved to date, and interim appointees are allowed only in exceptional cases. Risk management and compliance must be based in the firm, and second line functions cannot be outsourced.

Safeguarding and the Head of Safeguarding

Regulation 17 applies to PIs providing the services in paragraphs 1 to 6. Users' funds must never be mixed with other money. If not paid out by the end of the business day after receipt, they must sit in a separate credit institution account or in secure, liquid, low-risk assets approved by the Central Bank. The alternative is an insurance policy or comparable guarantee from an insurer or credit institution outside the group.

The Central Bank's January 2023 Dear CEO letter required every safeguarding firm to obtain a specific safeguarding audit from an audit firm, and its December 2025 thematic inspection found missing reconciliation procedures, blurred lines of defence, weak incident escalation and concentration at single banks. Applicants are now expected to show daily reconciliation with separate preparer and reviewer, an internal audit of safeguarding at least yearly and a PCF-56 Head of Safeguarding.

The BlueSnap case shows the cost of getting it wrong. On 21 November 2024 the Central Bank fined BlueSnap Payment Services Ireland Limited, a card acquirer authorised as a PI in December 2020, €324,240 and reprimanded it for not placing customer funds in its safeguarding account, mixing them with other funds and delaying telling the Central Bank. The High Court confirmed the sanction on 2 April 2025.

Crypto firms, e-money tokens and the PI route

The Central Bank's 2025 gatekeeping report records a rise in PI applications from crypto-asset service providers. Following an EBA no action letter on how PSD2 and MiCA interact, CASPs carrying out activity with e-money tokens had to either seek PI authorisation or partner with a payment service provider, with a deadline of 1 March 2026. Five CASPs applied in the fourth quarter of 2025, and the Central Bank used a streamlined process that drew on information already gathered for their CASP applications.

Passporting and ongoing obligations

An Irish PI can provide its authorised services in other EEA states through cross-border services, a branch or agents, using the EBA forms in Commission Delegated Regulation (EU) 2017/2055. Under Regulation 37, the Central Bank sends complete notifications to the host regulator within one month, and decides on agent and branch registration within 3 months. Agents and branches start only once entered in the register.

Ongoing, PIs file the Payment Institution Accounts (PIA) and Payment Institution Supplementary (PIS) XBRL returns every quarter, audited accounts within 6 months of year end, and operational and security risk, fraud and incident reports. The auditor sends its management letter and Statutory Duty Confirmation to the Central Bank within one month of the audit report. Anyone acquiring a holding of 10%, 20%, 30% or 50% must notify the Central Bank first; the Central Bank has 60 working days to assess a complete notification, and an acquisition made without notice is null and void.

Rule changes to plan for in 2026 and 2027

  • - Head of Safeguarding PCF-56 in force from 10 February 2026
  • - Revised Consumer Protection Code in effect from 24 March 2026
  • - CP172 levy consultation published 25 September 2026
  • - Instant euro credit transfers: PIs in euro area states must send and receive them by 9 April 2027
  • - EU AML Regulation (EU) 2024/1624 applies from 10 July 2027
  • - PSD3 and the Payment Services Regulation: provisionally agreed on 27 November 2025, approved by ECON on 5 May 2026, awaiting formal adoption

Payment institution licence: Ireland vs Malta vs Lithuania vs Netherlands vs UK

Initial capital tiers are set by PSD2 and are the same in each EU state. Fees, published timing, substance and language differ.

PointIrelandMaltaLithuaniaNetherlandsUK
RegulatorCentral Bank of IrelandMFSABank of LithuaniaDe Nederlandsche Bank (DNB)FCA
Initial capital€20,000, €50,000 or €125,000€20,000, €50,000 or €125,000€20,000, €50,000 or €125,000€20,000, €50,000 or €125,000€20,000, €50,000 or €125,000
Application feeNone€10,000€898 state fee€10,400 (DNB fee from 22 September 2026), payable even if refused£2,820 or £5,640
Annual regulator chargeLevy: minimum €6,625 plus variable share€25,000 plus a variable element capped at €250,000VariesAnnual supervision charge set by DNBAnnual periodic fees, varies
Statutory decision period3 months from complete application3 months from complete application3 months from complete documents3 months from complete application3 months complete, 12 months incomplete
Published real-world timingAverage 763 days in 2025 for PIs and EMIsService charter: first feedback within 6 weeks of submission reviewCompleteness check within 5 business days; no average publishedDNB says the process usually takes longer than 3 monthsNo average published by the FCA on its fees page
Substance signalsPCF approvals including Head of SafeguardingAt least 2 people directing the business in Malta; board of 3 with one Malta residentHeads of good repute; clear organisational structureAssessed by DNB case by caseHead office in the UK
Language of filingEnglishEnglishLithuanian or EnglishApplication form in DutchEnglish
EEA passportYesYesYesYesNo, since 1 January 2021

Sources: Central Bank of Ireland, S.L. 376.03 and MFSA, Bank of Lithuania, DNB and FCA pages listed below, as at 29 October 2026. Lithuania also offers a restricted-activities licence for smaller firms; Ireland has no equivalent.

Key requirements

Services mapped to the Schedule

Each payment service sought is named against paragraphs 1 to 8 of the Schedule, because capital, own funds, safeguarding and insurance all follow from that list.

Initial capital by service

€20,000 for money remittance only, €50,000 for payment initiation, €125,000 for any of paragraphs 1 to 5. Only the core capital items in Article 26(1)(a) to (e) of the Capital Requirements Regulation count.

Own funds method

The Central Bank directs Method A, B or C and states it in the authorisation. A firm providing only payment initiation (with or without account information) holds own funds equal to its initial capital.

Professional indemnity insurance

Payment initiation and account information providers need professional indemnity insurance or a comparable guarantee. The Central Bank asks for the EBA calculator, completed with the firm's figures, with the application.

Safeguarding

PIs providing services in paragraphs 1 to 6 must safeguard users' funds under Regulation 17, with the same Central Bank expectations on reconciliation, EEA banks and local control as for EMIs.

Board and PCF holders

Approved holders of each PCF role, including Head of AML (PCF-52) and Head of Safeguarding (PCF-56) since 10 February 2026, on a board with independent non-executive directors.

Local functions

Risk management and compliance based in the firm, with the Chief Risk Officer and Head of Compliance having access to the board. Second line functions cannot be outsourced.

Business plan and wind-down plan

The Central Bank's business model template, three-year projections with base, downside and upside cases, and a wind-down plan covering the return of users' funds.

What does an Irish payment institution licence cost in year one?

The Central Bank charges no application fee. The annual industry funding levy for payment and e-money institutions combines a minimum of €6,625 with a variable share based on the value of transactions the firm processes. A firm authorised during the year pays a pro rata levy for the months authorised, invoiced in the following levy cycle. Third-party costs depend on the services and model, so they are listed without invented figures.

ItemAmountSource or note
Central Bank application fee€0Central Bank FAQ: no fee for submitting an application
Initial capital€20,000, €50,000 or €125,000Own funds held by the firm, not a fee
Industry funding levy, minimum€6,625 a year, pro rata in the first year2026 Industry Funding Regulations, Category N
Industry funding levy, variableShare based on the firm's transaction valueCategory N formula
AML flat fee for Ultra High risk rating€496,875Applies only to firms rated Ultra High for AML risk
Professional indemnity insurance (PIS and AIS)VariesMinimum amount set using the EBA calculator
External audit and Statutory Duty ConfirmationVariesAudited accounts within 6 months of year end
Safeguarding assurance and internal auditVariesInternal audit of safeguarding at least yearly
Irish PCF salaries and board feesVariesDepends on the model and services
Regulatory Counsel professional feeA fixed fee set out in a written proposal

The application process

1

Map each service and the flow of funds

We match the product to the Schedule, test the exclusions, confirm that no customer balances turn it into e-money, and fix the capital tier and own funds method to model.

2

Prepare the Key Facts Document and initial meeting

We draft the 15 to 20 page Key Facts Document, file it at least 5 working days before the initial meeting, and prepare the leadership for the Central Bank's questions.

3

Appoint the PCF team

We help identify and vet the Chair, CEO, CRO, Head of Compliance, Head of AML, Head of Internal Audit and Head of Safeguarding before they are proposed.

4

Build and submit the application

We prepare the programme of operations, projections, safeguarding framework, AML risk assessment and questionnaire, outsourcing gap analysis, PII calculation and wind-down plan, and submit through Kiteworks.

5

Manage the assessment

We coordinate responses to each information request and assessment meeting so the service standard clock restarts quickly and the file never approaches the 60 working day dormancy limit.

6

Authorisation and passport

We close the Minded to Authorise conditions and capital injection, then file EEA passport notifications for services, branches or agents.

The Payment Services Regulations require the Central Bank to decide within 3 months of a complete application. Its service standard is that 90% of assessments finish within 90 business days of the assessment stage starting, with the clock paused for every information request. The Central Bank states that it can take over 12 months for firms to provide all the information needed. Its published average for payment and e-money institutions was 763 calendar days from application to authorisation in 2025, with the shortest at 497 days.

How long does Irish PI authorisation take?

The legal deadline is 3 months from a complete application, and the service standard targets 90 business days for the assessment stage. Both pause whenever the Central Bank asks for more information. The Central Bank's average for payment and e-money firms from application to authorisation was 614 days in 2023, 688 days in 2024 and 763 days in 2025, and the fastest 2025 authorisation took 497 days.

StageWhat happensPublished standard
Initial meetingKey Facts Document of about 15 to 20 pages filed 5 working days before95% of contacts acknowledged within 3 business days
Key Information CheckCompleteness and initial assessment; case manager assigned95% within 10 business days
AssessmentInformation requests, assessment meetings, PCF interviews90% within 90 business days, paused for each request
Minded to AuthoriseConditions, capital and final letter90% within 10 business days of a satisfactory response
DormancyNo adequate response to commentsWithdrawn after 60 working days, warning at 50

Why applications fail, and how we prevent it

Wrong licence for the product

A product that lets customers hold and spend balances is likely e-money, not a payment service. We settle the classification before the Key Facts Document is filed.

Own funds planned only at the initial capital floor

Method B rises with payment volume and Method C with income, so a growing PI can need far more than €125,000. We model the directed method across all three projection cases.

Exclusions assumed, not notified

Firms relying on the limited network or electronic communications exclusions must notify the Central Bank. We test the exclusion and file the notification where it applies.

Group-run safeguarding

The BlueSnap case arose from safeguarding run by the group without adequate local monitoring. We put reconciliation sign-off and escalation inside the Irish firm.

Weak PCF candidates

Late or under-qualified PCF candidates are a named top five cause of delay. We help the board complete due diligence before proposing anyone.

Slow or inconsistent responses

Delays in answering queries extend assessments and can lead to dormancy. We run a tracked response plan with one owner per query.

Practitioner notes: pre-application checklist

  • - Service-by-service map to the Schedule, with a written view on any exclusion and on the e-money boundary
  • - Flow of funds diagram showing where users' funds sit at every step
  • - Rationale for choosing Ireland where passporting or outsourcing is significant
  • - Key Facts Document ready 5 working days before the initial meeting
  • - Chair and CEO appointed, other PCF candidates identified and vetted, no triple hatting
  • - Own funds model under the likely method across base, severe downside and upside cases
  • - Safeguarding framework with EEA banks, daily reconciliation and local sign-off
  • - Professional indemnity insurance calculation on the EBA tool for PIS or AIS
  • - AML risk assessment and the Central Bank's pre-authorisation questionnaire
  • - Outsourcing gap analysis against EBA Guidelines EBA/GL/2019/02
  • - Risk appetite statement, risk register and compliance monitoring plan approved by the Irish board
  • - Wind-down plan covering the return of users' funds

How we help

Licence scoping

We map each service to the Schedule, test exclusions and the e-money boundary, and set the capital tier and own funds method.

Central Bank application

We prepare the Key Facts Document, application pack, PCF submissions, PII calculation and wind-down plan, and manage the assessment.

Ongoing compliance

We run quarterly PIA and PIS returns, safeguarding assurance, passport notifications and qualifying holding filings after authorisation.

Regulatory Counsel is a licensing and compliance practice for regulated finance in 65+ jurisdictions, with more than 200 licence and registration engagements. We prepare Irish PI applications alongside UK, Maltese and MiCA filings, so groups can choose the right EU base on one plan. Professional fees are a fixed fee set out in a written proposal, and every enquiry is answered the same business day.

Frequently asked questions

€20,000 if money remittance is the only service, €50,000 for payment initiation, and €125,000 for any of the account, transaction, credit line, issuing or acquiring services in paragraphs 1 to 5 of the Schedule. Account information services alone need registration, not capital.

No. The Central Bank states there is no small payment institution regime in Ireland, so every firm that wants to provide payment services must apply for full authorisation.

There is currently no application fee. Once authorised, the firm pays the annual industry funding levy: a minimum of €6,625 plus a variable share based on its transaction value, pro rata in the first year.

The legal deadline is 3 months from a complete application, but the Central Bank's published average for payment and e-money firms was 763 calendar days from application to authorisation in 2025. The quickest took 497 days.

The Central Bank directs Method A (10% of fixed overheads), Method B (a sliding scale on payment volume) or Method C (a sliding scale on income) and states it in the authorisation. It may adjust the result by 20% either way.

Yes. Since 10 February 2026 the Head of Safeguarding is a Pre-Approval Controlled Function (PCF-56) for payment institutions, e-money institutions and small e-money institutions, so the holder needs Central Bank approval.

Yes. It notifies the Central Bank, which sends complete notifications to the host regulator within one month. Agents and branches can start once the Central Bank has registered them, and it decides within 3 months.

If customers hold a balance with you that they can spend later with third parties, you are likely issuing e-money. That needs EMI authorisation with €350,000 initial capital rather than PI authorisation.

Regulatory Counsel charges a fixed fee set out in a written proposal, separate from the Central Bank levy and third-party costs. Every enquiry is answered the same business day.

Primary sources

The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.

By · Updated

Harry Khan advises payment, e-money and money transmission firms on licensing and compliance.