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:

  1. Application Form for Authorisation as an Electronic Money Institution (including the specific information and documentation requested therein);
  2. Anti-Money Laundering, Counter-Terrorist Financing and Financial Sanctions Pre-Authorisation Risk Evaluation: Questionnaire for Payment Institution and Electronic Money Institution Applicants;
  3. 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;
  4. 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:

  1. Application Form for Registration as Small Electronic Money Institution (including the specific information and documentation requested therein)
  2. Anti-Money Laundering, Counter-Terrorist Financing and Financial Sanctions Pre-Authorisation Risk Evaluation: Questionnaire for Payment Institution and Electronic Money Institution Applicants;
  3. 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;
  4. 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

Pre-application meetings are scheduled with all potential applicants. The purpose of these pre-application meetings is for the Payments Authorisation Team to provide direction on application requirements before a potential applicant submits an application.   While the Central Bank is not able to provide legal advice to applicant firms, it will provide clarity on its general expectations for application quality and format; operational and business plans; and staffing, governance, and internal controls. Potential applicants are also welcome to use this meeting as an opportunity to seek clarity on any aspect of the application form or the application process.

All firms will be required to return a ‘Key Facts Document' at least 5 working days prior to the pre-application meeting. This document is intended to be a summary overview of the firm’s proposed arrangements, and should not exceed more than 5 pages in length, including organisational and shareholder charts. Payments Authorisation’s review of this document does not constitute an assessment, and will not prevent the firm from formally submitting an application for Key Information Check. However, we would strongly recommend that the firm takes under consideration all items discussed during the pre-application meeting, making whatever changes necessary to meet the Central Bank’s expectations prior to submitting an application for authorisation or registration. The duration of these meetings is 45 minutes. Please email to applications@centralbank.ie in order to arrange a pre-application meeting.

Key Stages in 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.