Ireland EMI and PI License in 2026: The Complete CBI Guide

Why Ireland is still the post-Brexit EMI/PI default

The Central Bank of Ireland (CBI) has licensed dozens of EMIs and PIs since PSD2 came into force, including a steady stream of post-Brexit relocations from the UK. Stripe, Modulr, Square, Coinbase, Gemini and many others chose Ireland for their EU entity. The pattern is driven by four factors: English is the working language, Ireland is an EU Member State with the full PSD2 passport, the CBI has a tier-1 reputation, and the local talent pool is deep.

The trade-off is that the CBI is one of the most thorough PI/EMI supervisors in the EU. Timelines are longer than Lithuania or Malta, substance expectations are higher and the application file is heavier. Ireland is the right home for firms that want a prestigious EU licence and accept the cost and timeline that come with it.

The CBI PSD2-specific guidance

In May 2025 the Central Bank of Ireland published an updated Guidance Note on Completing an Application for PI/EMI authorisation and AISP registration. It consolidates six years of CBI authorisation experience into an explicit checklist of CBI expectations.

Four themes dominate the document:

• Consumer protection. Firms must demonstrate how they protect consumers, from pre-contractual information through complaint handling and out-of-court dispute resolution.
• Safeguarding. Daily reconciliation, diversified safeguarding accounts, clear trust-structure documentation, and detailed evidence pack. The CBI has historically been the most safeguarding-focused EU supervisor.
• Financial and operational resilience. Viable business plan with stressed scenarios, DORA-aligned ICT, business-continuity testing, third-party risk management.
• Sustainable business model. The CBI refuses files where the business plan is marketing language without a credible revenue model, realistic assumptions and coherent capital plan.

Read the CBI guidance document before you file. Most refusals come from firms that did not.

Capital and fees

Application fee. None. Ireland is one of the few EU jurisdictions with a zero authorisation fee. Supervisory fees apply post-licence, tiered by size.

Process and timeline

1. Pre-application engagement. CBI accepts and encourages pre-submission discussions. Typical duration 2 to 4 months.
2. File preparation. Full CBI PI/EMI file (500-1500 pages typical), aligned with the Guidance Note.
3. Submission. Three working days to confirm receipt.
4. Completeness check. 10 working days for an initial review. Missing items reset the clock.
5. Substantive assessment. The CBI's own service standard is 90 business days for the assessment stage in 90% of cases. That clock pauses whenever an information request is open and can be switched off, for example while interviews take place.
6. Conditions precedent. Paid-up capital, key hires on board, IT tested, safeguarding account live, three-lines-of-defence functioning.
7. Passporting. Notifications to host NCAs; services start 15 calendar days later.

The legal limit is different from the service standard. The European Communities (Electronic Money) Regulations 2011 and the European Union (Payment Services) Regulations 2018 give the CBI 3 months from a complete application (or from receipt of all information it needs) to decide. In practice the clock starts late: the CBI itself warns that it can take firms over 12 months to provide everything it needs, so plan the whole project around the quality of your file rather than the statutory clock.

Substance: the Irish bar

CBI substance expectations are among the highest in the EU, on par with BaFin and CSSF.

• Local executive management. CEO, CFO, CCO, CRO and head of internal audit all resident in Ireland. Nominee or remote-only roles are refused.
• Board composition. Multi-director board with independent NEDs, local chair preferred.
• Staffing. Meaningful local headcount; dozens of roles, not three.
• Outsourcing. Intragroup outsourcing is allowed but CBI checks that substantive decision-making remains in Ireland.
• Office. Real Dublin or regional office, CBI site visits, local payroll.

Corporate income tax: 12.5% standard, 15% effective for in-scope large multinationals under OECD Pillar Two from 2024.

PSD3 preparation for Irish EMIs and PIs

Irish PIs and EMIs migrate to the unified "payment institution authorised to issue e-money" category under PSD3. See the PSD3 and PSR guide for the roadmap. Practical work for 2026-2027: run Verification of Payee on every euro credit transfer, regular and instant (mandatory for euro-area PIs and EMIs since 9 October 2025), upgrade APP-fraud detection, diversify safeguarding banks, align ICT with DORA.

Ship an Irish EMI or PI product with Crassula

The CBI file is the longest in the EU-mainstream set, and every policy document needs to match real operational reality. Crassula Core keeps the ledger, client accounts with virtual IBANs, SEPA and SEPA Instant flows and the audit trail. Cards come through pre-integrated issuers you contract with directly, and identity checks run through connected verification providers. Transaction monitoring, sanctions screening, safeguarding and regulatory reporting to the CBI stay with you and your chosen providers; Crassula supplies the ledger balances, transaction exports and, as your ICT provider, the incident and outsourcing information you need for DORA.

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