Central Bank Publishes Second Payments and E-Money Newsletter
- Published
- in Industry Updates
Background
The Central Bank of Ireland (“CBI”) has published the second edition of its Payments and E-Money Newsletter (the “Newsletter”), providing an update on its supervisory priorities, regulatory developments and key focus areas for payment institutions and electronic money institutions.
E-Money Definition
Following its December 2025 communication, the CBI has found that many firms have not thoroughly assessed the impact of EBA Q&A 63361 (which clarifies the e-money definition) on their business models and has urged firms to prioritise this analysis ahead of intensified industry engagement in the coming months.
Material Changes of Business Model
The CBI has set out its expectations regarding the notification obligation under Regulation 18 of the European Communities (Electronic Money) Regulations 2011 (“EMR”) and Regulation 27 of the European Union (Payment Services) Regulations 2018 (“PSR”), which require firms to notify the CBI in advance of proposed material changes to their business model and not to proceed unless and until approved. The CBI has observed inconsistent engagement with this obligation, noting that firms’ strategic ambitions frequently outpace their control frameworks (particularly at local entity level within groups) and that some firms treat the obligation as a box-ticking exercise rather than engaging substantively.
Key expectations and observations include:
- Materiality is not defined in legislation; the board must articulate a firm-specific approach in a board-approved, regularly reviewed policy.
- Changes should be supported by a holistic strategy, not pursued on an ad hoc or siloed basis.
- Per the CBI’s December 2021 Dear CEO letter, firms must notify at the earliest opportunity of an expected material change.
The CBI provides five illustrative examples of material change: a substantive change to service or product offering; a material change to how services or products are provided (e.g., agent, distributor or branch networks); business projections significantly exceeding those in the authorisation process, whether organically or via acquisition; and a change likely to alter the firm’s overall risk profile or target market/customer profile.
Notifications must include a detailed risk assessment, signed off by the Board, assessing at a minimum the effect on safeguarding, AML/CFT, operational and IT, and consumer risk.
The risk assessment must evidence that governance, risk management, controls, and financial and operational resources support the proposed change and its implementation timeline. Firms must also document why any change is deemed non-material, as the CBI may test samples of such determinations.
Consumer Protection Code Update
The Consumer Protection Code 2025 (the “Code”) took effect on 24 March 2026. Key points for payment and e-money firms include:
- The definition of “consumer” under the Code extends beyond natural persons to groups of natural persons (partnerships, clubs, charities, trusts, unincorporated bodies) and incorporated bodies with turnover not exceeding €5 million in the previous financial year (and not part of a group exceeding that threshold). As a result, some B2B firms’ business customers may qualify as consumers under the Code.
- The Standards for Business Regulations apply to all business models (B2B, B2C and B2B2C), imposing obligations to secure customer interests, communicate effectively and mitigate financial abuse risks.
- The findings and expectations arising from the CBI’s 2025/2026 cross-sectoral thematic review of customer experience, focused on complaints handling, are expected to be published on the CBI website during H2 of 2026.
Authorisation Update
To date, five firms have been authorised in 2026, with a strong pipeline of varied business models under assessment. A growing trend is firms seeking multiple licences within a single entity (Payments/E-Money Institutions, Crypto Asset Service Providers and MiFID firms), adding complexity given the differing licensing regimes (MiCAR, PSD2, EMD2 and MiFID II.
The CBI has outlined its four-principle approach to managing multi-licence applications:
- Cross-Team Coordination — designated single points of contact, with ongoing
information-sharing between authorisation teams. - Holistic Assessment — single Key Facts Documents addressing multiple regulatory requirements, with aligned internal governance processes.
- Reliance on Previous Assessments — reliance on prior authorisation assessments where information remains current, with gaps addressed pragmatically (including targeted conditions to avoid delays).
- Proportionate Burden Reduction — attestations that previously submitted information remains accurate, rather than resubmission, to minimise duplication.
AML/CFT Risk Evaluation Questionnaire (REQ)
The CBI has been rolling out a new sector-specific enhanced AML/CFT Risk Evaluation Questionnaire (“REQ”) for Payments and E-Money firms. Key dates are:
- First submissions (2024 data) were received in February 2026.
- Second REQ submission (2025 data) is due 9 September 2026.
- From 2027, submission dates are standardised to align with AMLA reporting: March 2027 for 2026 data, and from 2028 onwards an annual March submission based on the preceding calendar year’s data.
Key Dates to Note
- 29 July 2026 — CBI webinar on the “Informing Effectively” obligation under the Code.
- 9 September 2026 — Second AML REQ submission (2025 data) due.
- 21 October 2026 — Payments and E-Money industry seminar at the CBI’s North Wall Quay office.
Conclusion
The CBI continues to intensify its engagement with the payment and e-money sector across several areas. Firms should prioritise their assessment of the impact of EBA Q&A 6336 on their business models ahead of the CBI’s anticipated engagement, prepare for the EU AML/CFT Single Rulebook (with the AMLR and 6AMLD applying from July 2027), and ensure the key dates set out above are diarised. Boards should review, and where necessary update, their policies on the materiality of business model changes to align with the CBI’s expectations.
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Further Information
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1 https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2022_6336
3 https://maples.com/wp-content/uploads/2025/02/Financial-Services-Regulatory-Core-Services.pdf
4 https://maples.com/wp-content/uploads/2026/06/MG_FinTech_A4-4.pdf
