Ireland is home to some of the world’s leading payments companies, attracted in part by Ireland’s thriving financial services and growing FinTech sector.

There are a number of advantages to being authorised in Ireland as an electronic money (“e-money”) or payment institution.

These include:

- The ability to passport to other EEA member states either on a branch or a cross-border services basis; and
- A favourable tax regime, due to a combination of a 12.5% corporate tax rate and an exceptionally extensive and comprehensive set of double tax agreements;

As per Article 2(2) of Directive 2009/110/EC, “electronic money” or e-money means “electronically, including magnetically, stored monetary value as represented by a claim on the issuer which is issued on receipt of funds for the purpose of making payment transaction, and which is accepted by a natural or legal person other than the electronic money issuer”. Prepaid cards and electronic wallets are examples of electronic money.

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. In fulfilling its statutory role in this regard, 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.

The Central Bank seeks to process each application as expeditiously as possible while meeting its obligation to operate a rigorous and effective gatekeeper function. It aims to ensure that the application process is facilitative and accessible from the perspective of applicants and, importantly, that applicants have clarity with regard to the process, its requirements and timelines.

A license for an Ireland Electronic Money Institution is issued by Central Bank of Ireland, the Financial Services Regulator of Ireland under the European Union (Payment Services) Regulations 2018.

As part of your Authorised Electronic Money Institution (e-money) license application, you will be required to provide the following information as part of your application:

Company identification details
Programme of operations
Business plan and financial forecasts
Description of your business’s organisation structure
Evidence of your initial capital
Measures to safeguard funds of your users
Compliance & governance arrangements and internal controls
Procedure for monitoring, handling, and following up on security incidents and security-related customer complaints
Processes for filing, monitoring, tracking and restricting access to sensitive payment data
Business continuity measures
Principles and definitions applicable to the collection of statistical data on performance, transaction and fraud
Security policy
Internal control mechanisms to comply with obligations in relation to money laundering and terrorist financing (AML/CFT obligations)
Details of your qualifying holdings (shareholders)
Details of any outsourcing arrangement

We can help you with Electronic Money License (EMI) licensing and compliance in Ireland.

What we need from you, to take care of the EMI license application, after your local company has been properly incorporated and registered in Ireland:

We will need you to provide us the details of your physical office within the application at the point of submitting the application; but you can provide these details at a later date whilst the application is being assessed.

You should also have the staff in place at the point of submission however, you may choose to finalise the hiring after having submitted the application.

The employees should have suitable and relevant experience, skills and knowledge for the role they intend to carry out. For example, the compliance officer should have ideally worked in a payments/banking firm in a similar compliance role previously. You will be responsible for hiring the staff as we do not get involved with this. However, on some occasions, we can help with hiring senior people for the client.

We prepare all the documents required for the application submission, including the legal/technical documentation. This will include compliance, risk, and security policies and procedures.

We offer an end-to-end service, taking responsibility for the entire project, including project planning and preparing all the required documents, such as the regulatory business plan, compliance procedure, a programme of operations, security policy, AML policy and financial documents.

After we have submitted the application, we will work closely with the client and will prepare any responses and further information to the regulator where they require further information. We offer our service for a fixed cost.

The following will apply with regards to initial capital.

Authorised Electronic Money Institution - €350,000 Authorised Payment institution:

- Payment accounts i.e. debit cards - €125,000
- Merchant acquiring/payment processing - €125,000
- Money remittance - €20,000

E-Money and payment institutions authorised in Ireland can passport to other EEA member states on either a services or cross-border establishment basis, subject to the fulfilment of certain notification requirements. An e-money institution/payment institution authorised in another member state can also passport into Ireland.

An e-money or a payments business established outside the EEA, can obtain passporting rights either by establishing itself or a subsidiary in Ireland (or in another member state) or by acquiring an existing authorised e-money/payment institution

Before Applying for Authorisation

In advance of submitting an application for authorisation/registration, the firm should satisfy itself that:

- its proposed business model requires authorisation/registration;
- it can comply with the authorisation requirements for electronic money institutions or registration requirements for small electronic money institutions;
- it is capable of complying with, and adhering to, the authorisation/registration requirements and on-going supervisory requirements that must be satisfied on an on-going basis;

Firms are advised to seek legal advice if they are unsure as to whether their proposed activities require authorisation/registration or if they are unsure as to how they should comply with the authorisation/registration requirements. If, after having received and considered such advice, firms have any doubt about their status, they are advised to submit an application for authorisation/registration.

The Central Bank offers the facility of an optional pre-application meeting to firms to answer specific questions about any aspect of the application process and completing the application form. Please note that the Central Bank recommends that firms who wish to avail of this facility have completed their application material to an advanced state before requesting such a meeting and have their specific questions prepared in advance in order to make the meeting as productive as possible. Such meetings will typically be no longer than one hour.

The applicant submits a completed Application Form with supporting documentation; The Central Bank acknowledges receipt of the application submission;

The Central Bank assesses whether the application submission contains the key information and documentation required to progress to the assessment phase;

Where all key information and documentation has been provided, the Central Bank completes an assessment of the application submission and may issue detailed comments and/or seek additional information;

The applicant is provided with the opportunity to address the comments and requests issued by the Central Bank in a revised application submission(s);

The Central Bank will assess these subsequent application submission(s) and notify the applicant of its assessment and next steps. The applicant is provided with a further opportunity to address any concerns arising at this stage in the process (if any); and The Central Bank will notify the applicant of its decision in respect of the application submission.

In the sections set out below, the firm will be able to learn about the different stages of the application process in more detail.

Stage 1 - Acknowledgement

The Central Bank will acknowledge receipt of an application for authorisation/registration submitted by the applicant within3 working days of receipt.


Stage 2 - Key Information Check

The Central Bank will then check that the application material submitted contains all the key information and documentation required to proceed to the assessment phase. Within 10 working days of receipt of the application, the Central Bank will either:

1. Advise the applicant that the application contains sufficient material to proceed to the assessment phase (further information is likely to be required as part of the assessment phase and may be required thereafter before a decision will be made in respect of the application); or 2. Advise the applicant that the application does not contain sufficient material to proceed to the assessment phase and so is not being progressed to that phase. A statement of the omitted information is also provided to assist the applicant should it wish to submit another application in the future. Any subsequent application will be considered a new application and the application process commences again.


Stage 3 - Assessment Phase

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 comments to the applicant based on its review of the application material submitted and any subsequent comments based on its review of responses submitted by the applicant. The Central Bank has published service standards (see below) 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.

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.


Stage 4 - Notification of Assessment

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.


Stage 5 - Notification of decision in respect of the Application

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

Our lawyers and financial services specialists at Atrium Legal Lab provide solutions to clients by combining the traditional legal fabric with new technologies.

Ireland is undoubtedly and excellent option in the European Union, offering you extremely low tax advantages.

It provides all the advantages of all traditional financial centres and offers you the passporting rights to carry out all your payment services through whole European Union.


Atrium Legal Lab has a team of trained professionals to advise clients who wish to become a licensed Electronic Money Institution.

In particular, we welcome questions about the EMI Registration in Ireland and are pleased to fully assist you.

One of our Customer Representatives will be most pleased to help and assist you