Electronic money institution authorisation in Ireland
The Central Bank of Ireland authorises electronic money institutions under the European Communities (Electronic Money) Regulations 2011. The process has three stages and starts with a mandatory pre-application meeting backed by a key facts document. Ireland suits firms that can put real senior management in Dublin and want a demanding but predictable regulator.
Facts under review · last checked 2026-10-08 · confirm figures with the regulator before relying on them
Regulator · Central Bank of Ireland (CBI) ↗
Key facts
- Minimum initial capital
- €350,000EMD-Art-4as of 2026-10-08Source ↗
- Process
- Three stages: exploratory (initial meeting and key information check), assessment, and authorisation decision. A Pre-Application Key Facts Document must be sent at least 5 working days before the initial meetingas of 2026-10-08Source ↗
- CBI service standards
- Assessment: 90% within 90 business days of the start of the assessment phase. Decision: 90% within 10 business days of a satisfactory response to the 'minded to authorise' letteras of 2026-10-08Source ↗
- Passporting
- Authorisation allows e-money and payment services across the EU/EEA after notificationas of 2026-10-08Source ↗
- EU reform status (PSD3/PSR)
- Negotiated text approved by the European Parliament ECON committee on 5 May 2026; plenary indicatively scheduled for 14 December 2026as of 2026-10-08Source ↗
Realistic timeline
Who does what, and how long each phase usually takes once work starts. The regulator’s share is outside anyone’s control.
- HartsizScoping and key facts document3–6 weeks
- YouHires, capital and full application pack8–16 weeksHartsiz drafts the pack; the client supplies people, capital and decisions
- RegulatorCBI exploratory stage, assessment and decision26–60 weeksOutside our control; the 90-business-day standard runs only once assessment formally starts
Estimated end to end: 9–19 months. Not a guarantee.
What the regulator expects to see
- Irish company with head office in Ireland and part of the business carried on there
- Board and pre-approval controlled function (PCF) holders who pass the CBI fitness and probity assessment
- MLRO and AML/CFT framework under the Irish Criminal Justice (Money Laundering and Terrorist Financing) Acts
- Safeguarding arrangements for e-money holders' funds
- ICT risk-management framework under DORA
Questions we get
Does the 90-business-day service standard mean we are authorised in about four months?
No. The standard covers the assessment phase only and applies to 90% of cases. The exploratory stage comes first, and question rounds can pause progress.
Do we need people in Ireland?
Yes. The head office must be in Ireland and the CBI assesses the fitness, probity and time commitment of directors and PCF holders. Plan for senior people working in Ireland.