Reporting Requirements for Electronic Money Institutions

Regular Reporting

An authorised E-Money Institution is required to submit to the Central Bank of Ireland ("Central Bank") at the frequency specified to the E-Money institution and within 20 business days of the end of the relevant reporting period reports setting out financial information and information in relation to the services provided including the safeguarding of users' funds and the appointment of distributors.  The details to be included in the reports are set out in the Guidance Note for the Supplementary Return and the Guidance Note for the Accounts Return.

Non-submission or late submission of returns is a key indicator in the assessment of the risk profile of authorised E-Money Institutions and in deciding which E-Money Institutions need to be inspected.

Additional guidance regarding reporting of Major Incidents; Operational and Security Risks; Payment Fraud Statistics; and Denial of Service can be found in the PSD2 - FAQ or PSD2 - Reporting Requirements pages.

Annual Accounts 

The annual audited accounts of an E-Money Institution authorised in Ireland under the provisions of the E-Money Regulations must be submitted to the Central Bank within six months of the relevant financial year end.

Reporting of Breaches or Errors

E-Money Institutions, for example, are required to report to the Central Bank:

  • any material breaches of legislative or supervisory requirements, and
  • any errors as defined in the Consumer Protection Code requiring an Error Notification Template

the E-Money Institution should contact paymentservicessupervision@centralbank.ie directly.  Please also see additional contact points in the Contact Us section.

Duties of External Auditors

Statutory Duty Confirmations and/or Auditors Management Letters 

Following the audit of an E-Money Institution’s financial statements, the auditor must supply the Central Bank with a copy of the 'Management letter' issued to the E-Money Institution’s Board of Directors or subcommittee of the Board.

In addition, auditors of E-Money Institution’s must make an annual 'Statutory Duty Confirmation' to the Central Bank stating whether any circumstances came to their attention during their annual audit that gave rise to a duty to report the matter(s).

Both the 'Management Letter' and 'Statutory Duty Confirmation' should be submitted to the Central Bank to the following address:

Statutory Duty Confirmations and/or Auditors Management Letter
EMI / PI Supervision
Central Bank of Ireland
New Wapping Street
North Wall Quay
Dublin 1
D01 F7X3

Statutory Duty Confirmations

Section 27B of the Central Bank Act 1997 (as inserted by the CBFSAI Act 2004) places a duty on auditors to make a written report to the Central Bank, within one month of the date of the auditor’s report on the financial service provider’s financial statements. The Statutory Duty Confirmation is sent directly to the Central Bank and is a statement to the Central Bank that there is no matter, not already reported in writing to the Central Bank by the auditor, that has come to the attention of the auditor during the ordinary course of the audit that gives rise to a duty to report to the Central Bank. Where matters have already been reported to the Central Bank, such matters should be referred to in the Statutory Duty Confirmation. The Statutory Duty Confirmation does not replace the auditor’s obligation to report under other relevant legislation.

Auditors must make a written report to the Central Bank stating whether or not circumstances have arisen that require the auditor to report a matter to the Central Bank under a prescribed enactment and if such circumstances have arisen, specify those circumstances.

This is an annual requirement and the Central Bank should receive such reports every year from the external auditor.

The report should be submitted to the Central Bank within one month of the date of the auditor’s report on the financial statements, or such extended period as the Central Bank allows.

The period covered by the Statutory Duty Confirmation commences from the date of issue of the previous declaration. It covers all matters that require the auditor to report to the Central Bank in respect of the specified period.

The Institute of Chartered Accountants in Ireland (“ICAI”), in consultation with the Central Bank, prepared Guidance on Reporting to the Central Bank under the CBFSAI Act, 2004.

A pro-forma report to be used by auditors is set out in Miscellaneous Technical Statement M46 issued by the ICAI, in September 2006.

Auditors Management Letters

Section 27C of the Central Bank Act 1997 (as amended by the CBFSAI Act 2004) requires that if the auditor of an entity regulated by the Central Bank makes a report to the entity, or those concerned with its management, on any matter that has come to the auditor’s notice during the course of the financial statement audit (or while carrying out any work for the entity of a kind specified by the Central Bank) the auditor must provide the Central Bank with a copy of that report.

The Central Bank Act, 1997 (as amended) requires auditors of financial services providers to provide the Central Bank with a copy of any report made on an entity (including payment institutions) or those concerned with its management during the course of a financial statement audit or while carrying out any work for the entity of a kind specified by the Central Bank.

The copy of the report must be provided at the same time as, or as soon as practicable after, the original is provided to the payment institution. If the auditor does not provide a report to the payment institution, the auditor must notify the Central Bank in writing that this is the case (a “nil return”).

If the auditor invites the payment institution to comment on a draft of a report and the payment institution comments, the auditor is obliged to send the final version of the report to the Central Bank. The Central Bank should, on an annual basis, receive from the payment institution auditors either a copy of the auditor’s report or a “nil return”.

An auditor of a payment institution who, without reasonable excuse, fails to comply with the provisions above, commits an offence.

Links to Guidance Notes

Guidance Note EMI Accounts Return (FINREP) | pdf 992 KB Guidance Note for the E-Money Institution Supplementary Return | pdf 1226 KB EMI FINREP Appendix 1 | xls 172 KB Additional Transactional data for EMIs - Valid for reporting dates up to and including 31/12/2019 | xls 30 KB Additional Transactional data for EMIs v2 - Valid for all reporting dates from 31/03/2020 onward | xls 28 KB