The Central Bank of Ireland (Central Bank) has recently published the second edition of its Payments and E-Money Newsletter (Newsletter).

The Newsletter’s purpose is to keep payment institutions (PIs) and electronic money institutions (EMIs) firms informed of key regulatory changes and share relevant insights in the Payments and E-Money sector.

The Central Bank has flagged two priorities for firms in this edition.

• First, it is urging firms as a matter of priority, to complete their assessment of the impact of the narrower interpretation of ‘electronic money‘ in EBA Q&A 6336 on their business models – having found that many have not yet done so or not in sufficient detail – and it notifies firms that it will step up its engagement with industry over the coming months.
• Second, it will host a Payments and E-Money industry seminar on 21 October 2026 at its North Wall Quay, Dublin office, with agenda and invitations to follow.

The second edition of the Newsletter covers the following topics:

1. Material Changes of Business Model

The maintenance of authorisation and licensing conditions under Regulation 18 of the European Communities (Electronic Money) Regulations 2011 (EMRs) and Regulation 27 of the European Union (Payment Services) Regulations 2018 (PSRs) require an EMI or PI to notify the Central Bank in advance of any proposed material change to its business model, and it may not proceed with that change unless and until it receives approval. While the Central Bank has acknowledged early engagement by several firms, it has also observed significant inconsistencies in engagement by firms.

The Central Bank has noted situations where firms’ growth ambitions have outpaced their control frameworks and local operational capacity. In addition, the Central Bank has noted certain firms’ tendency to treat regulatory requirements in a ‘tick box manner’ rather than adopting a strategic plan for supporting sustainable growth and delivering positive consumer outcomes.

The Central Bank has highlighted that it is the responsibility of the board of each firm to define what constitutes a material change to its business model and to document that within a board-approved policy.

Consistent with its December 2021 Dear CEO letter, the Central Bank also expects firms to notify it at the earliest possible opportunity once a material change is anticipated.

Non-exhaustive examples of a material change highlighted by the Central Bank include:

• significant changes to service or product offering;
• growth materially exceeding authorisation projections;
• changes that alter a firm’s risk profile;
• material changes to how services or products are delivered, such as the introduction of agent, distributor or branch networks; or
• changes to the firm’s target market or customer profile.

Any notification of material change should be accompanied by a board-approved risk assessment covering areas such as safeguarding, AML/CFT, operational and IT risks, and consumer risks, together with evidence that the firm’s governance, financial resources and operational capacity can support the proposed material change. The board-approved submission should also set out proposed timelines for executing the change, and firms should document the basis for treating any change as non-material because the Central Bank may periodically test a sample of changes that firms have treated as non-material.

2. Consumer Protection Code Update

In its Regulatory and Supervisory Outlook Report 2026, the Central Bank identified that securing consumer and investor interests in a rapidly changing world is a key supervisory priority. The Consumer Protection Code (the Code) took effect on 24 March 2026, following a 12-month implementation period that allowed firms time to make the relevant process and system changes to ensure compliance. The Code aims to reflect how financial services are delivered in the current digital era and to provide firms with greater clarity on their consumer protection obligations. Regulation 9 of the Consumer Protection Regulations restricts how the Code applies to firms providing payment services or issuing electronic money, and it operates alongside their obligations under the PSRs and EMRs.

Under the Code, the definition of ‘consumer’ extends beyond individual customers and includes partnerships, clubs and other unincorporated bodies, as well as incorporated bodies whose turnover does not exceed €5 million. Accordingly, firms operating primarily on a business-to-business basis may still be subject to the Code. In any event, the Standards for Business Regulations apply to all firms, whatever their B2B, B2C or B2B2C model.

A key focus of the Central Bank is supporting better consumer outcomes. As part of its 2025/2026 work programme it carried out a cross-sectoral thematic review of customer experience through the lens of complaints, and it continues to see cases where service falls short of its expectations. It has identified that poor service standards can increase the risk of consumer harm, and thus firms are expected to resolve complaints efficiently, fairly, and in a timely manner. The output of that review, including the Central Bank’s expectations, is due to be published later in H2 2026. The Central Bank will host a webinar on 29 July 2026 on the ‘Informing Effectively’ obligation.

3. Authorisations Update

The Central Bank has authorised five firms in 2026 to date, and the authorisation pipeline remains strong, with a large number of firms exhibiting a wide variety of business models at various stages of the process. One notable growing feature of the pipeline has been the increase in firms seeking multiple authorisations within a single legal entity. As well as PI and EMI authorisations these include crypto-asset service provider (CASP) and/or MiFID investment firm authorisations. These applications can be complex because they span different regimes and legislation, including PSD2, EMD2, MiCAR and MiFID II. This introduces the risk of duplicative information requests, creating unnecessary compliance costs.

To address these challenges, the Central Bank has adopted a streamlined approach involving:

• enhanced cross-team coordination;
• holistic assessments across different regulatory regimes;
• greater reliance on previous authorisation assessments; and
• proportionate reductions in the information and documentation provided by firms.

With the increase in fintech business models, the Central Bank expects its approach to multiple licence holders to become increasingly important to its goal of protecting consumers and it is centralising its broader gatekeeping functions to bring greater consistency, efficiency and clarity to this work.

4. The EU AML Package and the Anti-Money Laundering Authority

The Central Bank has highlighted the significant changes arising from the EU’s Anti-Money Laundering package (the AML Package), which was published in the Official Journal of the EU in June 2024 and is designed to create a more harmonised AML/CFT framework. The AML Package comprises the AML Regulation, the sixth AML Directive (6AMLD) and the AML Authority Regulation (AMLAR); 6AMLD must be transposed into Irish law by July 2027, although certain beneficial ownership register provisions take effect earlier, in mid-2026. At the centre of the reforms is the new AML Authority (AMLA) which will oversee the consistent application of AML/CFT requirements across EU Member States and will directly supervise up to forty of the most complex high-risk institutions, including at least one from each EU Member State, from 2028. Firms that are not directly supervised by AMLA, which will be the position for most Irish regulated Fintech firms, will continue to be supervised by their national competent authority, the Central Bank. AMLA will also play a crucial role in supporting and coordinating Financial Intelligence Units (FIUs) across the EU, facilitating joint analysis of financial intelligence and effective information sharing between them.

In addition, from July 2027, the AML Regulation (AMLR) will establish a single AML/CFT rulebook and introduce enhanced requirements. Existing rules on customer due diligence, outsourcing, politically exposed persons and AML/CFT governance are amended, and new obligations are added on targeted financial sanctions, third-country money laundering and terrorist financing threats, information-sharing partnerships, de-risking, limits on large cash transactions and the identification of users of virtual IBANs.

The Central Bank is encouraging PIs and EMIs to begin preparing for the new framework by familiarising themselves with the AMLR and engaging with AMLA’s consultations on the development of technical standards and guidance. The Central Bank will also continue to enhance its AML/CFT supervisory approach through the roll-out of new risk evaluation questionnaires (REQs). These are used to assess firms’ AML/CFT risk profiles and inform supervisory strategy. Following the first PI and EMI sector submissions in February 2026, firms should note that the next submission is due on 9 September 2026. That return uses an updated template reflecting the AMLA regulatory technical standards, and firms were notified of the changes through the Central Bank portal on 5 June 2026. REQ reporting will then be standardised to align with the AMLA framework, with returns for 2026 data due in March 2027 and annual submissions each March from 2028.

5. Key dates for H2 2026 returns.

Contact Us

Our Financial Regulation team can assist you with any regulatory queries. For more information, please contact Shane Kelleher, Louise McNabola or your usual William Fry contact.

Contributed by: Charlotte McCorry