Application Process for Electronic Money Institutions 

The purpose of this section is to provide information to firms considering applying for authorisation as an electronic money institution.  The Central Bank of Ireland (the Central Bank) is the competent authority in Ireland for the authorisation and supervision of electronic money institutions under the European Communities (Electronic Money) Regulations 2011 (the Regulations).

Each applicant seeking authorisation must satisfy the Central Bank that it can meet the authorisation standards set out in the Regulations.  In fulfilling its statutory role in this regard, the Central Bank adopts a robust, structured and risk-based process that seeks to ensure that only those applicants that demonstrate compliance with these authorisation requirements are authorised. 

The Central Bank seeks to process each application as expeditiously as possible while meeting its obligation to operate a rigorous and effective gatekeeper function.  It aims to ensure that the application process is facilitative and accessible from the perspective of applicants and, importantly, that applicants have clarity with regard to the process, its requirements and timelines.

Before Applying for Authorisation

In advance of submitting an application for authorisation, the firm should satisfy itself that

  • its proposed business model requires authorisation pursuant to the Regulations
  • it can comply with the authorisation requirements for electronic money institutions;

Firms are advised to seek legal advice if they are unsure as to whether their proposed activities require authorisation pursuant to the Regulations or if they are unsure as to how they should comply with the authorisation requirements set out in the Regulations.  If, after having received and considered such advice, firms have any doubt about their status, they are advised to submit an application for authorisation.

Summary of the Key Stages in the Application Process

  • The applicant submits a completed Application Form with supporting  documentation;
  • The Central Bank acknowledges receipt of the application submission;
  • The Central Bank assesses whether the application submission contains the key information and documentation required to progress to the assessment phase;
  • Where all key information and documentation has been provided, the Central Bank completes an  assessment of the application submission and may issue detailed comments and/or seek additional information;
  • The applicant is provided with the opportunity to address the comments and requests issued by the Central Bank in a revised application submission(s);
  • The Central Bank will assess these subsequent application submission(s) and notify the applicant of its overall assessment and next steps. The applicant is provided with a further opportunity to address any concerns arising at this stage in the process (if any);  and
  • The Central Bank will notify the applicant of its decision in respect of the application submission.

In the sections set out below, the firm will be able to learn about the different stages of the application process in more detail. 

The Documentation Required to Make an Application for Authorisation

Applicants should submit the following documentation which should be fully completed:

  1. An Application for Authorisation as an Electronic Money Institution Form (including the specific information/documentation requirements set out therein);
  2. A Business Plan; and
  3. A Programme of Operations.

Where the firm proposes to appoint distributors or agents or establish a branch as at the date of authorisation, it should also submit the following documentation, as appropriate, which should be fully completed:  

Once an application is submitted the applicant will also need to ensure that all relevant individuals proposed to hold a Pre-Approval Controlled Function (“PCF”) role (typically board members, senior management, key function holders) and any qualifying shareholders complete Fitness and Probity Individual Questionnaires – more information here.  Individual Questionnaires must be submitted electronically via the Central Bank’s Online Reporting System by all relevant individuals, but qualifying shareholders (that are not proposed PCF role holders) are required to submit a paper version.  Please note that access to the online Individual Questionnaire only becomes available after an application has been deemed to contain all the key information needed to progress to the assessment phase of the application process.

The completed Application Form, along with all relevant accompanying material, should be submitted in both paper and electronic format to the Central Bank.  The paper copy should be sent to EMI Authorisations Team, Consumer Protection: Policy & Authorisations, Central Bank of Ireland, PO Box 559, Dame Street, Dublin 2. and the electronic version can be included with the paper copy or sent by email to emiauthorisations@centralbank.ie.

The Key Stages in the Application Process

The various stages of the application process are as follows:

Stage 1 - Acknowledgement

The Central Bank will acknowledge receipt of an Application for Authorisation submitted by the applicant within 3 working days of receipt.

Stage 2 - Key Information Check

The Central Bank will then check that the application material submitted contains all the key information and documentation required to proceed to the assessment phase. Within 10 working days of receipt of the application, the Central Bank will either:

  1. Advise the applicant that the application contains sufficient material to proceed to the assessment phase (further information is likely to be required as part of the assessment phase and may be required thereafter before a decision will be made in respect of the application); or
  2. Advise the applicant that the application does not contain sufficient material to proceed to the assessment phase and so is not being progressed to that phase. A statement of the omitted information is also provided to assist the applicant should it wish to submit another application in the future.  Any subsequent application will be considered a new application and the application process commences again at Stage 1.

Stage 3 - Assessment Phase

Where sufficient information has been received, as outlined in 2 (1) above, the Central Bank will then proceed to the assessment phase of the application process. The application material submitted will be reviewed against the relevant authorisation requirements to determine whether sufficient information has been provided to enable the Central Bank to issue a 'Notification of Assessment' letter referred to in Stage 4 below. The Central Bank will issue initial comments to the applicant based on its review of the application material submitted and any subsequent comments based on its review of responses submitted by the applicant. The Central Bank has published service standards (see below) in respect of the processing of applications for authorisation and in the context of meeting those standards the service standard timeframe to which the Central Bank has committed for the assessment phase of the application process is 90 working days.  However, it should be noted that in the event of further and/or subsequent information being sought, this 90 day ‘clock’ is paused until such information is received by the Central Bank from the applicant.

In the event of the applicant failing to respond to a request from the Central Bank for further and/or subsequent information, after 60 working days the application may not be considered further by the Central Bank (see Guidance Note). 

Stage 4 – Notification of Assessment

The Central Bank will notify the applicant of the outcome of the Assessment Phase of the application process as follows:

a)      Where the assessment is favourable, the Central Bank will notify the applicant by letter that it proposes to authorise the applicant on the basis of the information provided in its application submission, provided any specified final steps are taken and/or any specified final items of information and evidence are received. This letter will also specify any specific conditions the Central Bank proposes to impose on the authorisation itself once granted.  This letter will explain the reasons for these proposed conditions and the applicant will be afforded the opportunity to make representations in respect of the proposed conditions before the Central Bank makes any decision on the application.

b)      In the event that the Central Bank is not satisfied on foot of the Assessment Phase such that it can issue a Notification of Assessment letter under (a) above,  the Central Bank will advise the applicant of this by letter. The letter will set out the areas to be addressed and afford the applicant the opportunity to do so and to make any submissions it wishes to the Central Bank in respect of these matters.

Stage 5 - Notification of Decision in Respect of Application

Once the Central Bank has assessed any further information/evidence/representations submitted by the applicant following on from Stage 4 above, the Central Bank will notify the applicant, via letter, of its decision on the application as follows:

a) Authorisation – The Central Bank has decided to grant an authorisation.

b) Authorisation with Specific Conditions – The Central Bank has decided to grant an authorisation with specific conditions attached to the authorisation. The specific conditions to be attached to the authorisation will be outlined in the letter.

c) Proposed Refusal of Authorisation – The Central Bank is minded to refuse the application for authorisation. In accordance with the applicable legislation, the Central Bank will notify the applicant of the grounds for the proposed refusal of the authorisation. The applicant will then have an opportunity to make submissions in response to the proposed refusal.  These submissions will then be considered by the Central Bank following which a decision will be taken by the Central Bank to grant or refuse the authorisation applied for, as appropriate. Details of the Central Bank’s process for the refusal of an application for authorisation are available here.

The Regulations provide that the Central Bank must inform firms whether their application for authorisation has been granted or refused within three months of receiving all the information required to make a decision. For the purposes of this statutory timeframe, the Central Bank does not consider this three month period to have commenced until the receipt of any outstanding information or any representations arising from the assessment phase, or thereafter, of the application process.

If the applicant has any queries in respect of the application process it can contact the Central Bank at emiauthorisations@centralbank.ie or use the contact form available here.

The Central Bank offers the facility of a single optional pre-application meeting to firms to answer specific questions about any aspect of the application process and completing the application form. Please note that the Central Bank recommends that firms who wish to avail of this facility have completed their application material to an advanced state before requesting such a meeting and have their specific questions prepared in advance in order to make the meeting as productive as possible.  Such meetings will typically be no longer than one hour.

Applying for Registration as a Small Electronic Money Institution

Chapter 7 of the Regulations provides that the Central Bank may waive all or part of the procedure and conditions set out in Chapters 2, 3, 4 and 6 of the Regulations and register a firm as a “small electronic money institution” as defined therein.  A small electronic money institution’s registration is only valid in the State and does not entitle the small electronic money institution to issue electronic money in any other Member State.   

The process for applying for registration as a small electronic money institution is the same as the process for applying for authorisation as an electronic money institution (as set out above) in all other respects.

In advance of submitting an application for registration as a small electronic money institution, the firm should ensure that it has read the Guidance Note for the Completion of an Application for Registration as a Small Electronic Money Institution and has taken the information provided therein into consideration when completing the Application for Registration as a Small Electronic Money Institution Form.

The Documentation Required to Make an Application for Registration as a Small Electronic Money Institution

Applicants should submit the following documentation which should be fully completed:

  1. An Application for Registration as a Small Electronic Money Institution Form (including the specific information/documentation requirements set out therein);
  2. A Business Plan; and
  3. A Programme of Operations.

Where the applicant proposes to appoint distributors or agents or establish a branch in the State as at the date of authorisation, it should also submit the following documentation, as appropriate, which should be fully completed:  

Once an application is submitted the applicant will also need to ensure that all relevant individuals proposed to hold a Pre-Approval Controlled Function (“PCF”) role (typically board members, senior management, key function holders) and any qualifying shareholders complete Fitness and Probity Individual Questionnaires – more information here.  Individual Questionnaires must be submitted electronically via the Central Bank’s Online Reporting System by all relevant individuals, but qualifying shareholders (that are not proposed PCF role holders) are required to submit a paper version.  Please note that access to the online Individual Questionnaire only becomes available after an application has been deemed to contain all the key information needed to progress to the assessment phase of the application process.

The completed Application Form, along with all relevant accompanying material, should be submitted in both paper and electronic format to the Central Bank.  The paper copy should be sent to EMI Authorisations Team, Consumer Protection: Policy & Authorisations, Central Bank of Ireland, PO Box 559, Dame Street, Dublin 2. and the electronic version can be included with the paper copy or sent by email to emiauthorisations@centralbank.ie.

Service Standards Performance Reports

Please find a link to the Service Standards Performance Reports page here. The reports set out the Central Bank's performance against Service Standards that it has committed to in respect of (i) Authorisation of Funds, (ii) Authorisation of Financial Service Providers and (iii) Processing of Fitness and Probity applications, on a half-yearly basis.

The Central Bank will notify the applicant of the outcome of the Assessment Phase of the application process as follows: