On 13 May 2025, the Central Bank of Ireland (Central Bank) published its annual Authorisations and Gatekeeping Report for 2024.

The report summarises the Central Bank’s authorisation and gatekeeping activity across all sectors in 2024 and provides helpful data and insights into common issues experienced with authorisation applications.

Timelines

Again this year, the Central Bank emphasises that the timeline from a firm’s initial application to authorisation is strongly influenced by:

• the nature, scale and complexity of the proposed application/business model;
• the completeness and quality of the application submission; and
• the applicant’s responsiveness in responding to the Central Bank’s queries and the quality of those responses.

The Central Bank reiterates that applicants with a settled and clear business plan, proper governance and organisational arrangements, and firms that are transparent and proactive in their engagement with the Central Bank will receive positive outcomes in a more timely manner.

Metrics

The information below covers the period from the date a complete application is received to the final decision and includes the time taken by applicants to deal with queries raised by the Central Bank during the application. The report states that no applications were refused during the year.

The report states that no applications were received from Credit Unions or High Cost Credit Providers in 2024.

Common challenges in the authorisation process

Business Models

Firms’ inability to describe their proposed business model clearly, including the underlying assumptions made and customer offerings or substantial changes made by firms phase to their proposed business model during the assessment, may prolong the assessment period.

Delays in Responding

Long delays in firms’ responses to queries or clarifications to questions posed during the authorisation process can delay the authorisation process.

Governance

A lack of substantive presence and adequate staffing for both PCF and non-PCF roles in the jurisdiction will likely delay authorisation.

Inadequate Preparation and Application Completeness

Firms that have made key senior appointments at the application point generally submit a more complete application, which has been subject to appropriate review and, therefore, tend to progress through the authorisation process in a more timely manner.

Localised Risk Frameworks

The Central Bank expects firms to have localised risk frameworks tailored to the entity seeking authorisation to ensure all risks are appropriately managed. In many cases, firms over-rely on group risk frameworks, which do not achieve that outcome.

Fitness and Probity Insights

The Central Bank has made inroads in implementing the recommendations from the independent review of the fitness and probity regime, including:

• Establishing a dedicated and centralised Fitness and Probity Unit.
• Creating a Gatekeeping Decisions Committee within the Central Bank to consider cases of potential refusal. For further information, please see our articles here and here.
• Publishing a consultation paper (CP160) regarding consolidated and revised Fitness and Probity Guidance and proposing simplification of the Pre-Approval Controlled Function (PCF) list. For further information, please see our article here.
• Enhancing statistical information for accountability and transparency to develop knowledge of how the process works in practice, including how the Central Bank is tracking against the 90-day timeframe for completion of assessments.

PCF Applications

The Central Bank has observed a continued improvement in the quality of PCF applications submitted since the introduction of its new online portal in April 2023 (e.g. a 17% year-on-year reduction in PCF applications that were returned as incomplete in 2024 as against 2023).

In the context of PCF applications linked to new firm authorisations, the PCF role can only be approved when the firm authorisation is approved, which affects PCF application timelines in this scenario. The Central Bank is continuing to work to achieve greater alignment between these processes.

Common errors include failures to upload necessary supporting documentation, application for an incorrect PCF role, firm updates not reflected in the application, or the initial proposer no longer being a valid proposer.

Fitness & Probity Interviews

In 2024, 47 fitness and probity interviews were conducted versus 126 in 2023. The sectors with the most applicants called for interviews in 2024 were Virtual Asset Service Providers (9), Credit Institutions (8), and Insurance/Reinsurance Undertakings (7). The role most frequently interviewed was PCF-1 (Office of the Executive Director) followed by PCF-12 (Head of Compliance).

DORA

The Digital Operational Resilience Act (DORA) has been in effect since 17 January 2025. When evaluating a financial entity’s DORA maturity, the Central Bank expects applicants to have clearly identified any gaps in compliance with the DORA requirements and to move quickly and strongly to close those gaps via concrete and evidence-based plans.

The Central Bank expects financial entities to demonstrate that they have duly considered and documented their assessment of the proportionality aspects of critical functions, dependence on in-house and contracted ICT services and systems, and the implications a total loss or severe degradation of such systems would have in terms of critical or important functions and market efficiency.

Contact Us

For more information, please contact Shane Kelleher, Louise McNabola, or your usual William Fry contact.

Contributed by Jane Balfe