The Central Bank Publishes Its First Payment And E-Money Newsletter

On 10 December 2025, the Central Bank of Ireland (Central Bank) published the first edition of its Payment and E-Money Newsletter (Newsletter), which it intends to publish regularly.

The purpose of the Newsletter is to provide updates on key regulatory developments in the Payment and E-Money sector and to signpost relevant upcoming changes.

The first edition of the Newsletter covers the following topics

1) Feedback to industry from Central Bank thematic inspection on safeguarding

The Central Bank published its findings from a thematic inspection on safeguarding to assess the operational effectiveness of firms' safeguarding processes and control infrastructure together with its safeguarding practice expectations. For further information on this topic please see our article  here. The Central Bank reminds firms that it has no tolerance for weaknesses in safeguarding arrangements.

2) Feedback to industry from Central Bank cross-sectoral customer experience review

The Central Bank conducted a review examining customer experience through the lens of customer complaints across firms in several sectors. The review underscored that firms need to take additional steps to support customers in getting effective customer service and information throughout the customer journey.

The Central Bank expects firms to manage customer service risk and take a consumer-centric approach that helps deliver fair outcomes for customers. It reminds firms of the regulatory requirements under the Consumer Protection Code (CPC) and highlighted its expectation that firms proactively identify complaints at the earliest available opportunity and not place the onus on the customer to lodge or follow up on a complaint.

Central Bank expectations of firms regarding customer service

• Robust and effective governance and control frameworks, processes and procedures are in place to ensure that all customer complaints are handled speedily, efficiently and fairly.
• Clear, timely and accurate information is provided to customers and employees have the requisite knowledge across products, services and processes to engage with customers.
• Communication is clear, effective, and conducted in a timely manner, providing customers with sufficient information and updates as necessary.
• Engagement with customers in a respectful and helpful manner, including when listening to customers' complaints.
• Demonstrate evidence of thorough investigation and resolution of complaints, as set out under Chapter 12 of the CPC.
• Proactive support of customers and addressing dissatisfaction when it is raised and adopting a consumer focused approach when engaging with customers.
• Taking a holistic approach to undertaking robust root-cause analysis of issues arising from complaints. Firms should investigate the effectiveness of governance and oversight as well as behavioural and cultural root-causes that may be contributing to deficiencies in the customer journey.
• Firms should have and use appropriate and timely management information, e.g. for complaints monitoring and for conducting effective complaints trend analysis.

3) Qualifying Holdings Applications

The Central Bank reminds firms that all persons who directly or indirectly propose to acquire a qualifying holding or increase a qualifying holding in a Payment Institution (PI)/Electronic Money Institution (EMI) must apply for Central Bank approval in advance of such acquisitions taking effect. Failure to secure Central Bank approval renders the purported acquisition null and void. The Newsletter provides further information on the following aspects of application:

A qualifying holding means a direct or indirect holding that reaches or exceeds a prescribed percentage (i.e. 10%, 20%, 30% or 50%). Persons who directly/indirectly dispose of a qualifying holding or decrease a qualifying holding below a prescribed percentage must notify the Central Bank.

Documentation required for notification of a Qualifying Holding – Submission via Kiteworks of the following:

1. PI/EMI Qualifying Holding Notification Form including the specific information and documentation requested therein.
2. Qualifying Holder Assessment Forms for each relevant person who proposes to acquire or increase a qualifying holding: (a) Application for a Natural Person with a Qualifying Holding (QH). (b) Application for a Legal Person or Other Entity Type with a QH. (c) Application for a Director of a Legal Person or Other Entity Type with a QH.
3. Fitness and Probity Individual Questionnaires for each individual who proposes to both acquire/increase a qualifying holding and hold a PCF role (i.e. board members, senior management, key function holders) in the PI/EMI.

Assessment of Qualifying Holding 

Once the required documentation has been provided, the notification is acknowledged as complete and the assessment phase commences. The Central Bank is legally required to complete its assessment of the notification within 60 working days of acknowledgement. If further information or clarification is sought, the 60 working days is paused for the shorter of:

• the period of the request and receipt of a complete response, and
• 20 working days (within the EU) or up to 30 working days (outside the EU).

Approval of Qualifying Holding

On completing the assessment of a proposed acquisition, the Central Bank will notify the applicant of its decision in respect of the notification, as follows: a) No Opposition to Proposed Acquisition b) No Opposition to Proposed Acquisition with Specific Conditions c) Proposed Opposition to Proposed Acquisition.

Central Bank Tips

• Ensure applications are signed and dated by the acquirers, the target entity and any disposers,
• Legal entities must provide the signature of two directors, including the CEO.
• Ensure applications are fully complete and include all relevant supporting documents, such as ID and CV for Directors.
• On completion of QH the acquirer provides a certified copy of the share register and letter from acquirer stating it is the beneficial owner of the shares and voting rights.

4) Upcoming changes

Guidance on the Fitness and Probity Standards – The Central Bank has published new Guidance on the Fitness and Probity Standards. The Guidance removes the need for separate third-party lawyer/notary attestation for PI, EMI & AISP in most instances. For further information on the revised Guidance, please see our articles  here and  here.

Head of Safeguarding Oversight PCF Role – As mentioned above, in 2026, PI/EMIs will be required to appoint a designated responsible person for the role of PCF-56 Head of Safeguarding. Further information will be provided by the Central Bank in 2026.

SEPA reporting –  Firms providing SEPA Instant Payments will be required to submit a new return, the “SEPA Instant Payment Transfers Individual” via the Central Bank Portal by 9 April 2026. The first submission of information from PI/EMIs requires aggregated data for the periods 26 October 2022 to 31 December 2022 and the 2023 calendar year.

AML REQ – Following consultation with firms and representative bodies, the Central Bank has published revised AML REQ templates and guidance, with the first return covering the calendar year 2024 to be submitted to the Central Bank by 13 February 2026.

Revised Consumer Protection Code – The Central Bank has published a revised CPC which will take effect on 24 March 2026. For further information, please see our article  here.

5) Key dates for 2026 returns

Contributed by Jane Balfe

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.