Ireland EMI License: Gateway to European Electronic Money Services

The Central Bank of Ireland

The Central Bank serves as Ireland's integrated financial regulator, responsible for authorization, supervision, and enforcement across all financial services sectors, including electronic money institutions.

Legislative Foundation

Irish EMI regulation derives from European harmonization:

EU Directive 2009/110/EC: The Electronic Money Directive, transposed into Irish law, establishes core requirements for EMI authorization and operation.

Payment Services Directive 2 (PSD2): Directive 2015/2366, enacted in Ireland in January 2018, governs payment services and introduces requirements for payment initiation and account information services.

European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations: Implements EU AML requirements in Irish law.

PSD2 Regulatory Objectives

The revised Payment Services Directive aims to:

• •Enhance integration of European payments markets
• •Create competitive balance among payment service providers
• •Strengthen transaction security through strong customer authentication
• •Improve consumer protection through clear rights and obligations

Electronic Money Services

• •E-Money Issuance: Creating electronic money against receipt of funds, including prepaid cards, digital wallets, and stored value instruments
• •Cash Services: Facilitating deposits to and withdrawals from e-money accounts
• •Redemption: Converting electronic money back to traditional currency at par value

Payment Services

• •Credit Transfers: Processing standing orders and one-off transfers
• •Direct Debits: Collecting payments from customer accounts
• •Card Operations: Issuing and processing card-based payment transactions
• •Money Remittance: Transferring funds domestically and internationally
• •Payment Initiation Services: Initiating payments from accounts held at other institutions
• •Account Information Services: Aggregating account data from multiple providers

European Market Access

Irish EMI licenses enable passporting throughout the European Economic Area, providing access to over 450 million consumers across 30 countries from a single authorization.

Payment Infrastructure

• •SEPA Membership: Full participation in the Single Euro Payments Area
• •IBAN Accounts: Ability to offer IBAN-denominated accounts to customers
• •Card Scheme Access: Authorization to issue Visa and Mastercard branded instruments

Business Environment

Ireland offers several commercial advantages:

• •Corporate Tax Rate: 12.5% on trading income—among the lowest in the EU
• •English Language: Native English-speaking jurisdiction simplifies operations for international companies
• •Skilled Workforce: Strong talent pool in financial services and technology
• •Established Ecosystem: Presence of major technology and financial services companies creates partnership opportunities

Authorized Electronic Money Institution (AEMI)

Full EMI authorization for unrestricted operations:

• •Minimum Capital: €350,000
• •Application Fee: No application or registration fees charged by the Central Bank
• •Scope: No limitations on transaction volumes or e-money outstanding

Authorized Payment Institution (API)

For payment services without e-money issuance:

• •Minimum Capital: €125,000 (varies by service type)
• •Application Fee: None
• •Scope: Payment services as authorized

Small Electronic Money Institution

For smaller-scale operations:

• •Capital Requirements: No minimum initial capital
• •Turnover Limits: Average outstanding e-money not exceeding €5 million
• •Geographic Scope: Ireland only (no passporting)

Stage 1: Pre-Application Engagement

Prospective applicants may request informal meetings with the Central Bank to discuss their business model and authorization requirements before formal application.

Stage 2: Application Submission and Acknowledgment

• •Submit complete application through the Central Bank's online portal
• •Central Bank acknowledges receipt within 3 working days
• •Application assigned to assessment team

Stage 3: Completeness Review

• •Assessment within 10 working days of acknowledgment
• •Incomplete applications returned with specific deficiency notices
• •Complete applications proceed to detailed assessment

Stage 4: Detailed Assessment

• •Comprehensive 90 working-day review period (clock stops for information requests)
• •Evaluation against all authorization criteria
• •Applicants must respond to information requests within 60 days

Stage 5: Outcome Communication

• •Authorization proposal letter (for successful applications)
• •Assessment notification letter (identifying remaining concerns)
• •Opportunity to address any outstanding matters

Stage 6: Final Decision

• •Written authorization granted (with or without conditions)
• •Or formal refusal with stated reasons
• •Decision communicated within 10 working days of Stage 5 completion

Total Timeline: Approximately 103+ working days for straightforward applications, though complex cases may require longer.

Corporate and Legal Documentation

• •Completed application form with entity identification
• •Articles of Association and company constitution
• •Certificate of incorporation and registration proof
• •Details of any prior regulatory interactions or applications

Business Planning

• •Comprehensive three-year business plan
• •Marketing strategy and customer acquisition approach
• •Financial projections including revenue, costs, and capital adequacy
• •Description of proposed services and target markets

Governance and Management

• •Organizational structure diagram
• •Job descriptions for key positions
• •CVs and fit and proper documentation for directors and senior managers
• •Staffing plan (minimum 8-9 local personnel typically required)

Compliance Framework

• •AML/CFT policies and procedures
• •Customer due diligence protocols
• •Transaction monitoring and suspicious activity reporting procedures
• •Risk management framework
• •Internal audit arrangements
• •Data protection policies and GDPR compliance
• •Business continuity and disaster recovery plans

Operational Documentation

• •Client fund safeguarding arrangements
• •IT systems architecture and security measures
• •Outsourcing arrangements and due diligence on service providers
• •Complaint handling procedures
• •Professional indemnity insurance documentation

Financial Documentation

• •Proof of initial capital
• •Auditor appointment confirmation
• •Banking arrangements for safeguarding

Local Personnel

Minimum 8-9 employees based in Ireland, typically including:

• •Chief Executive Officer / Managing Director
• •Chief Financial Officer
• •Head of Compliance / MLRO
• •Head of Operations
• •Risk management personnel
• •Customer service staff
• •Technical / IT personnel

Physical Presence

• •Registered office in Ireland
• •Operational premises suitable for proposed activities
• •Key management functions performed locally

Prudential Requirements

• •Capital adequacy at or above prescribed minimums
• •Safeguarding of customer funds through segregation or insurance
• •Liquidity appropriate for operational needs

Regulatory Reporting

• •Regular submission of financial and operational returns
• •Annual audited financial statements
• •Notification of material changes to business or ownership

Conduct Requirements

• •Fair treatment of customers
• •Transparent pricing and clear terms
• •Effective complaint handling
• •Data protection compliance

AML/CFT Compliance

• •Ongoing customer due diligence
• •Transaction monitoring
• •Suspicious activity reporting to Irish Financial Intelligence Unit