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. 90 working days statutory. Pauses if additional information is requested. Real-world 6 to 12 months.
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.

End-to-end for a well-prepared PI: 8 to 14 months. EMI: 10 to 16 months. Heavier than Lithuania and Malta; similar to the Netherlands.

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: deploy IBAN-name check across all rails (mandatory for SEPA Instant 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 delivers the operational core - ledger, IBANs, wallets, cards, SEPA rails, KYC and AML, safeguarding reconciliation, DORA ICT and CBI-ready reporting - aligned with the CBI Guidance Note expectations.

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