Schedule 2 Firms

Registration for Anti-Money Laundering/Countering the Financing of Terrorism Purposes

On 26 November 2018, Section 108A of the Criminal Justice (Money Laundering and Terrorist Financing), Act 2010 (as amended), introduced for the first time a statutory requirement for certain firms to register for Anti-Money Laundering/Countering the Financing of Terrorism purposes with the Central Bank of Ireland ('Central Bank').

When Does the Obligation to Register Arise

If your firm offers any of the following services and it is not otherwise authorised or licenced to carry on business by the Central Bank, then it will need to register with the Central Bank as a 'Schedule 2 firm'.

Schedule 2 Activities

  1. Lending including inter alia: consumer credit, credit agreements relating to immovable property, factoring, with or without recourse, financing of commercial transactions (including forfeiting).
  2. Financial leasing.
  3. Payment services as defined in Article 4(3) of Directive 2007/64/EC of the European Parliament and of the Council of 13 November 200714 on payment services in the internal market amending Directives 97/7/EC, 2002/65/EC, 2005/60/EC and 2006/48/EC and repealing Directive 97/5/EC.
  4. Issuing and administering other means of payment (e.g. travellers' cheques and bank drafts) insofar as such activity is not covered by point 3.
  5. Guarantees and commitments.
  6. Trading for own account or for account of customers in any of the following:
    1. Money market instruments (cheques, bills, certificates of deposit, etc.);
    2. Foreign exchange;
    3. Financial futures and options;
    4. Exchange and interest-rate instruments; or
    5. Transferable securities.
  7. Participation in securities issues and the provision of services relating to such issues.
  8. Advice to undertakings on capital structure, industrial strategy and related questions, as well as services relating to mergers and the purchase of undertakings.
  9. Money broking.
  10. Portfolio management and advice.
  11. Safekeeping and administration of securities.
  12. Safe custody services.
  13. Issuing electronic money.

Exemptions from the Obligation to Register

If your firm is carrying out Schedule 2 activities, the obligation to register does not occur if your firm falls into any of the following two exemptions:

1. If cumulatively:

  1. Your firm only carries out Schedule 2 Activity 6 above; and
  2. Your firm's customers (if any) are members of the same group as your firm.

or

2. If cumulatively:

  1. Your firm's annual turnover is less than €70,000; and
  2. The total of any single transaction, or a series of linked transactions in relation to your firm's Schedule 2 activities does not exceed €1,000; and
  3. Your firm's Schedule 2 activities do not exceed 5% of your firm's total turnover; and
  4. Your firm's Schedule 2 activities are directly related to and ancillary to your firm's main business activities; and
  5. Your firm only provides Schedule 2 activities to customers of your main business activities rather than the public in general.

Central Bank Portal

From the 6 July 2026, Schedule 2 applicant firms seeking registration for Anti-Money Laundering/Countering the Financing of Terrorism purposes are required to submit the registration, and all related post-registration submissions, via the Central Bank Portal and not by email.

The Central Bank Portal offers several benefits to applicant firms including:

  • Streamlined submission process: A single secure platform for processing all related registration submissions;
  • Improved transparency: Clear visibility of the status of a registration and any follow-up requests;
  • Secure messaging: A dedicated and secure communications channel to exchange messages and process queries;
  • Registration & document retrieval: The ability to securely access and retrieve previously submitted documentation. 

All applicant firms are required to be set up on the Central Bank Portal in order to submit registrations, and all related post-registration submissions. We wish to draw your attention to a detailed Systems Submission Guide (PDF 1.97MB) which has been developed to assist applicant firms in submitting their applications via the Central Bank Portal.

Applicant firms are strongly encouraged to familiarise themselves with the content of this System Submission Guide, to support the provision of a complete and accurate submission and to minimise potential delays in the assessment process.

The System Submission Guide covers the following activity types:

  1. Registration
    • Applicant firms registering as a Schedule 2 firm for Anti-Money Laundering/Countering the Financing of Terrorism purposes, complete and submit an online form via the Central Bank Portal.
  2. Post Registration Changes
  • De-Registration

    • Applicant firms are required to submit a De-Registration form if they are discontinuing all Schedule 2 activities.

    • Complete the below Schedule 2 De-Registration form for Anti-Money Laundering/Countering the Financing of Terrorism purposes and submit via the Central Bank Portal.

              De-Registration form (XLSX 182.45KB)

    • Add or Remove Activities
      • Applicant firms adding or discontinuing certain Schedule 2 activities, must complete the below Schedule 2 Add/Remove Activity form for Anti-Money Laundering/Countering the Financing of Terrorism purposes, and submit via the Central Bank Portal.

      Add/Remove Activity form (XLSX 235.92KB)

    • Request Changes
      • The Central Bank has introduced a post registration Request Change self - service functionality which allows firms to update key information directly via the Central Bank Portal. The key information is shown below:
      • Change to Contact (principal contact details);
      • Change of Address;
      • Change of Legal Name;
      • Change of Trading Name; and
      • Other Material Changes (including change in ownership structure).

    See link to guidance on Request Changes.

    Contact the Central Bank

    For registration and post registration queries, please contact the Central Bank by secure messaging via the Central Bank Portal.

    For general queries, please e-mail the Schedule 2 Registration team at Schedule2@centralbank.ie.

    For Central Bank Portal queries, please e-mail the online returns team at onlinereturns@centralbank.ie.

    Register of Schedule 2 firms

    The register of Schedule 2 firms is published on the Central Bank website, under the heading “Register of Financial Institutions registered under Section 108A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021 (Schedule 2 Firm)”.