Ireland electronic money institution licence.

What you get

How the firm obtains the licence

1. Scoping and proposal. The permissions, the own funds method and the levy category are confirmed in a written proposal the same day, and the pre-application key facts document is prepared for submission five working days before the Central Bank’s initial meeting.
2. Application pack. The business plan, programme of operations, projections, outsourcing, IT and security, the AML risk evaluation questionnaire and the fitness and probity questionnaire for each controlled function, submitted by secure file transfer.
3. Banking. The segregated safeguarding account with an EEA-authorised credit institution and the operating accounts are arranged through the firm’s relationships before the decision, so the banking evidence the Central Bank expects sits in the file.
4. Regulator engagement. The key information check, the assessment questions and the controlled function interviews run through one process, with candidates appointed early and every request answered promptly, until the minded-to-authorise letter and the decision; the service standard is 90% of assessments within 90 business days.

Key people, banking and technology

You will need senior managers approved by the Central Bank, at least one independent non-executive director, and compliance and risk heads working in Ireland.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

Who needs the licence

A business that issues stored value to customers in Ireland or, through passporting, anywhere in the EU and EEA, needs authorisation under the Irish electronic money regulations. Ireland is the EU licence most often paired with a UK FCA authorisation by groups serving both markets: English-speaking, common-law, with a regulator that publishes its expectations in detail. An EMI may provide every payment service under the same authorisation.

What the Central Bank requires

• Legal form and location. A company established in Ireland with its head office and registered office in the State; the Central Bank expects board decision-making, financial control, legal, compliance and risk to be located in Ireland, with a significant senior management presence.
• Governance. At least one independent non-executive director, more as the firm grows; pre-approval controlled function holders assessed under the fitness and probity regime; compliance and risk management performed in-house, not outsourced; no triple-hatting of control roles.
• Safeguarding. Segregation in a separate account with a credit institution, or secure low-risk assets, or an insurance policy or guarantee from outside the group; the Central Bank states it has no tolerance for weaknesses and expects EEA-authorised banking partners.
• Application pack. A pre-application key facts document, then the full application: business plan, programme of operations, financial projections, policies, governance, outsourcing, IT and security, AML and the fitness and probity questionnaires for each controlled function.
• Anti-money laundering. An AML and counter-terrorist financing risk evaluation questionnaire and a framework built for the firm’s own customers and products.
• Capital. Initial capital of €350,000 and own funds thereafter of at least 2% of average outstanding e-money, plus capital for any unrelated payment services; the final figure is set in the minded-to-authorise letter.

Capital

The Central Bank may require up to 20% more, or permit 20% less, than the method produces.

Timing

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

Small EMI registration

A firm whose average outstanding e-money stays below €1 million and whose monthly payment transactions stay below €3 million may register as a small EMI. The registration is valid in Ireland only: no issuance in other Member States and no payment initiation or account information services. Capital under the Central Bank’s guidance is €125,000.

Passporting and scope

An Irish EMI passports throughout the EU and EEA by branch, agent or distributor, or on a cross-border services basis. Notifications are submitted after authorisation and forwarded by the Central Bank within one month. The authorisation covers e-money issuance and every payment service.

Why applications are delayed

The Central Bank publishes the reasons applications take longer than they should.

1. Inadequate preparation and incomplete submissions.
2. Unclear or changing business models and assumptions that are not supported.
3. Slow responses to requests, group-only risk frameworks, and late or unsuitable appointments to pre-approval controlled functions. An application dormant for 60 business days is treated as withdrawn.

Banking

An EMI needs a safeguarding account that satisfies the regulator’s requirements, an operating account and settlement accounts in the currencies it serves. The firm arranges each through institutions that serve regulated firms in Ireland and across the EU, during the application, so the firm trades on authorisation. See banking and payment processing.

Questions firms ask

References

1. Central Bank of Ireland: payment and e-money authorisation
2. Central Bank of Ireland: expectations for PI and EMI authorisation
3. Central Bank of Ireland: PSD2 guidance note
4. Central Bank of Ireland: industry funding levy
5. European Communities (Electronic Money) Regulations 2011
6. Central Bank of Ireland: EMI passporting

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.