RegAlertIreland: fintech & payments regulation — 2026-09
RegulatedIreland fintech: CBA under PSD2/MiCAR; strict CASP licensing; no specific payment capital in docs
Frozen snapshot — the guide as it stood at the end of 2026-09. See the live guide for the current state.
Ireland is a highly regulated hub for fintech, supervised primarily by the Central Bank of Ireland (CBI). Payment services are governed by the 2018 Regulations transposing PSD2, while crypto-assets fall under the EU MiCAR regulation. The CBI has established a rigorous, two-phase authorization process for Crypto-Asset Service Providers (CASPs), emphasizing local substance and robust governance. The regulatory environment is mature, with clear expectations for consumer protection and AML compliance.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Payment processing / gateway | LicencePayment Institution Requires authorization under EU Payment Services Regulations 2018. | — | — | Central Bank of Ireland |
| E-money & wallet issuance | LicenceElectronic Money Token Issuer[1] MiCAR authorization required for issuing Electronic Money Tokens. | — | — | Central Bank of Ireland |
| Domestic money transfer | LicencePayment Institution Domestic transfers fall under Payment Institution authorization. | — | — | Central Bank of Ireland |
| Cross-border remittance | LicencePayment Institution Cross-border payments require Payment Institution authorization. | — | — | Central Bank of Ireland |
| Agent network | Uncertainverify with regulator Agent arrangements for payment services are not detailed in provided documents. | — | — | — |
| Open banking / account information | LicencePayment Institution / AIS Provider AIS providers must be authorized payment institutions under PSD2. | — | — | Central Bank of Ireland |
| Foreign-exchange services | LicencePayment Institution FX services are payment services requiring authorization. | — | — | Central Bank of Ireland |
New — what changed recently
- 2026-05-12MiCAR CASP Authorization Guidance — CBI issued detailed guidance on the three-stage assessment process for CASP authorization under MiCAR.[1]
- 2025-07-28MiCAR and PSD2 Interplay FAQs — CBI clarified EBA recommendations for CASPs seeking Payment Institution authorization, setting a March 2026 deadline.[2]
- 2024-12-16MiCAR Supervisory Expectations — CBI established expectations for robust governance and risk frameworks for MiCAR applicants.[3]
Market-entry checklist
- 1Determine CASP vs. PI AuthorizationAssess if crypto activities require MiCAR CASP authorization or if traditional payment services fall under PSD2.
- 2Prepare Pre-Application SubmissionComplete the Pre-Application stage on the CBI portal before submitting the formal authorization application.
- 3Demonstrate Local SubstanceEnsure robust local presence and control structures as emphasized in CBI CASP briefing documents.
- 4Submit Key Facts DocumentPrepare the standardized Key Facts Document (KFD) as required for MiCAR authorization applications.
- 5Disclose AML/CFT FrameworksProvide comprehensive details on risk frameworks using the Pre-Authorisation Risk Evaluation Questionnaire.