Updated CBI Expectations for PI and EMI Authorisation and AISP Registration

PUBLISHED: 10th April 2024

On 9 April, the Central Bank of Ireland published updated authorisation expectations for firms that are seeking authorisation as a Payment Institution (PI) or Electronic Money Institution (EMI), or registration as an Account Information Service Provider (AISP).

The Central Bank highlights that the authorisation and supervision of firms operating in the PI and EMI sector is an important and growing part of its mandate.  The updated expectations build on the Central Bank’s experience of authorising and supervising firms in the sector and on previous communications and guidance to industry. 

The revised expectations will provide welcomed clarity, transparency and predictability for applicant firms seeking to be authorised.

The updated expectations list the following top five challenges experienced by the Central Bank in authorisation assessments:

1. Inadequate preparation and application completeness.
2. Lack of clarity/changing business models.
3. Inordinate delays in responding by applicant firms.
4. Lack of localised risk frameworks.
5. Pre-Approval Controlled Function (PCF) suitability.

Firms that wish to enter or operate within the payments and electronic money legal and regulatory framework, supervised by Central Bank, will need to adhere to these expectations during the authorisation application process.  

For further information on the Central Bank’s updated expectations and how they may impact your firm’s authorisation process, please do not hesitate to contact a member of our Financial Services team.

The updated expectations can be viewed here.