Application Process for Electronic Money Institutions
This section provides information to firms considering applying for authorisation as an electronic money institution or registration as a small electronic money institution. The Central Bank of Ireland (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 (as amended) (EMR).
Each applicant seeking authorisation/registration must satisfy the Central Bank that it can meet the authorisation/registration standards set out in the EMR. Accordingly, 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. This process aligns with guidance issued by the European Banking Authority (EBA).
The Central Bank seeks to process each application as expeditiously as possible while meeting its obligation to operate a rigorous and effective gatekeeper function.
1. Guidance and Resources
The Payments Authorisation Team is the point of contact for applicant firms. The teams which assist the Payments Authorisation Team with an EMI application include the Fitness and Probity, Technology Risk and Anti-Money Laundering teams. For queries on EMI applications, please contact applications@centralbank.ie.
The Innovation Hub is a facility available to firms to engage with the Central Bank outside of existing formal regulator/firm engagement processes. Applicant firms are advised to use the following documents as guidance:
• EBA Guidelines on the Information to be Provided for Authorisation and Registration under PSD2 (EBA Guidelines);
• Central Bank Guidance Note on Completing an Application for Authorisation under PSD2
• Central Bank Fitness and Probity Standards (F&P Standards);
• Central Bank Guidance on Fitness and Probity Standards (F&P Guidance)
• Central Bank Fitness and Probity Frequently Asked Questions (F&P FAQ); and,
• Central Bank Guidance on Fitness and Probity for Firms Authorised Under PSD2 (PSD2 F&P Guidance)
2. Application Forms and Individual Questionnaires
Applicant firms should submit the following documentation for authorisation as an Electronic Money Institution:
- Application Form for Authorisation as an Electronic Money Institution (including the specific information and documentation requested therein);
- Anti-Money Laundering, Counter-Terrorist Financing and Financial Sanctions Pre-Authorisation Risk Evaluation: Questionnaire for Payment Institution and Electronic Money Institution Applicants;
- Qualifying Holder Application Forms, as appropriate:
a) Application for a Legal Person or other entity type with Qualifying Holdings in an Applicant Payment Institution or Electronic Money Institution
b) Application for a Natural Person with Qualifying Holding in an Applicant Payment Institution or Electronic Money Institution
c) Application for a Director with Qualifying Holdings in an Applicant Payment Institution or Electronic Money Institution;
- Fitness and Probity Individual Questionnaires for all Pre-Approval Controlled Function (PCF) roles (typically board members, senior management, key function holders) submitted electronically via the Central Bank’s Online Reporting System (ONR). Please note access to the ONR is only provided once an application has progressed to Stage 3 - Assessment Phase (detailed below).
Applicant firms should submit the following documentation for registration as a Small Electronic Money Institution:
- Application Form for Registration as Small Electronic Money Institution (including the specific information and documentation requested therein)
- Anti-Money Laundering, Counter-Terrorist Financing and Financial Sanctions Pre-Authorisation Risk Evaluation: Questionnaire for Payment Institution and Electronic Money Institution Applicants;
- Qualifying Holder Application Forms, as appropriate:
a) Application for a Legal Person or other entity type with Qualifying Holdings in an Applicant Payment Institution or Electronic Money Institution
b) Application for a Natural Person with Qualifying Holding in an Applicant Payment Institution or Electronic Money Institution
c) Application for a Director with Qualifying Holdings in an Applicant Payment Institution or Electronic Money Institution;
- Fitness and Probity Individual Questionnaires for all Pre-Approval Controlled Function (PCF) roles (typically board members, senior management, key function holders) submitted electronically via the Central Bank’s Online Reporting System (ONR). Please note access to the ONR is only provided once an application has progressed to Stage 3 - Assessment Phase (detailed below).
Pre-Application
Applicant firms may request a pre-application meeting with Payments Authorisations to ask specific queries about the authorisation process. However, it is not within the remit of the Central Bank to provide advice at these meetings. Applicant firms must seek their own legal advice prior to submitting an application for authorisation or registration. The Central Bank recommends that applicant firms who wish to avail of this facility progress their application to an advanced stage before requesting such a meeting. Specific questions should be prepared in advance in order to make the meeting as productive as possible. Meetings are limited to no more than forty five minutes.
The completed application form, along with all relevant accompanying material, must be submitted in electronic format to the Central Bank via our secure file transfer system. Please request access via email to applications@centralbank.ie.
Key Stages in the Application Process
The Central Bank will acknowledge receipt of an application for authorisation/registration submitted by the applicant within 3 working days of receipt.
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/registration requirements to determine whether sufficient information has been provided to enable the Central Bank to issue a 'Notification of Assessment' letter as referred to in Stage 4 below. The Central Bank will issue initial and subsequent comments to the applicant firm based on this review.
The Central Bank has published service standards in respect of the processing of applications for authorisation/registration 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 firm.
Please note, The Central Bank can in its authority disband its 90 working day service standard where it considers any or all of the following have arisen in an application:
a) where another regulatory authority has to be contacted,
b) which are subject to interview,
c) where significant legal issues arise,
d) where significant fitness and probity issues arise,
e) where the business model of an applicant is complex or novel in nature,
f) where significant changes to the business model, the applicant’s shareholder structure or other key aspects of an application arise during the review process, or where the application becomes dormant, and
g) where the Central Bank is minded to refuse an application.
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.
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/register the applicant on the basis of the information provided in its application submission, provided any specific 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/registration itself once granted. The 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 has not been 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.
The Central Bank will assess any further information/evidence/representations submitted by the application following on from Stage 4 above.
Within 10 working days of receipt of a satisfactory response to issues set out following the outcome of Stage 4 above, the Central Bank will notify the applicant, via letter, of its decision on the application as follows:
a) Authorisation/Registration
The Central Bank has decided to grant an authorisation/registration.
b) Authorisation/Registration with Specific Conditions
The Central Bank has decided to grant an authorisation/registration with specific conditions attached to the authorisation/registration. The specific conditions will be outlined in the letter.
c) Proposed Refusal of Authorisation/Registration
The Central Bank is minded to refuse the application for authorisation/registration. In accordance with the applicable legislation, the Central Bank will notify the applicant of the grounds for the proposed refusal of the authorisation/registration. The applicant will then have the 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/registration applied for, as appropriate. Read more about the Central Bank's process for refusal of an application for authorisation/registration.
The legislation provides that the Central Bank must inform firms whether their application for authorisation/registration 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.
Service Standards Performance Reports
Read about our Service Standards Performance Reports.
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.