knowledge 24 June 2025 |

Central Bank of Ireland’s Authorisations Report: Authorisation Activity in 2024

The Report provides an overview of CBI authorisation activity that took place in 2024, along with details on fitness and probity (“F&P”) applications. The Report is the CBI’s second edition of its Authorisations and Gatekeeping Report, having published the first edition in 2024 covering 2023 activity (the “First Edition”).

Our briefing provides a sectoral overview of CBI authorisation activity in 2024, with comparison to data from 2023 as set out in the First Edition, and outlining some of the factors that the CBI notes may delay processing times. Further information on those factors is set out in our briefing linked above.

Introduction

The CBI continues to exercise its authority in relation to the authorisation, registration and approval of financial service providers (“FSPs”), prospectuses, and regulated financial products. It also approves key personnel for pre-approval controlled functions (“PCFs”), as part of the F&P regime, which is given a dedicated chapter in the Report and is also discussed in our briefing linked above.

Similar to the First Edition, the Report provides a sectoral breakdown of authorisation activity for 2024, outlining: (i) authorisation activity rates by volume; (ii) average authorisation times; and (iii) an explanatory narrative for each sector. The Report also notes authorisation timelines remain dependent on a number of factors, namely (i) the nature, scale and complexity of an applicant firm’s proposals; (ii) the completeness and quality of the application; and (iii) the responsiveness of the applicant to the CBI’s queries during the assessment process, and the quality of those responses.

Based on the CBI’s experience during 2024, it advises that applicants who do best when seeking authorisation will (i) be adequately prepared for the authorisation process; (ii) submit high quality applications; (iii) be conscious of timeframes; and (iv) ensure there is no incomplete information in their application submission.

Authorisation Information by Sector

1. Funds Authorisation

In 2024, the CBI received 787 funds authorisation applications, an increase of 111 compared to 2023. 69 applications were closed or withdrawn.

710 applications were approved in 2024.  This includes 481 Undertakings for Collective Investment in Transferable Securities (“UCITS”), nine Retail Investor Alternative Investment Funds (“RIAIFs”), one Retail European Long-term Investment Fund (“ELTIF”), 10 Professional ELTIFs and 209 Qualifying Investor Alternative Investment Funds (“QIAIFs”). Compared to 2023, the number of UCITS, RIAIFs and Retail ELTIFs authorised in 2024 increased by 26%.

The average processing time for applications was 88 calendar days, a decrease of 10 days compared to 2023.  The CBI states that certain applications received in 2024 required a more extensive review due to complex asset-classes or higher levels of leverage; this may have impacted processing times.

On QIAIF applications, the CBI notes that the quality of QIAIF applications received in 2024 was similar to that received in 2023. There was a small increase in the number of rejected QIAIF applications, increasing from 11 in 2023, to 14 in 2024. The CBI says that this is due to the relevant cross border management passport clearance not being received.

In relation to post-authorisations, there were 3,141 applications received, and 1,210 approvals, in 2024. This represents an improvement in relation to the applications received/approvals given ratio compared to 2023. The submissions reviewed by the CBI included domestic and cross-border UCITS mergers, service provider changes, changes regarding investment strategies, and changes due to regulatory developments at a European level.

During 2024, 153 investment manager applications were reviewed by the CBI, down by 24 compared to 2023. This consisted of 11 submissions from EU authorised entities and 142 submissions from non-EU entities.  The average processing time for investment manager clearance remained the same as 2023, taking one day for EU investment managers and four days for non-EU investment managers.

2. Retail Intermediaries / Debt Management Firms

In 2024, the CBI received 309 authorisation/registration applications in respect of retail intermediaries / debt management firms. This represents an increase of 46 compared to 2023. 122 applications were either withdrawn or closed.

There were 200 retail intermediary authorisations/registrations in 2024, an increase of 26 compared to 2023.  One application for authorisation as a debt management firm was received by the CBI in 2024, and the Report notes the authorisation would be concluded in the first half of 2025.

There was a significant improvement in the average processing time for applications in 2024. The average processing time for applications for authorisation and registration was 119 calendar days in 2024, down by 50 calendar days compared to 2023. The CBI notes that it met all service standards and expected processing times in 2024.

The Report states that poor quality and/or incomplete applications are a common occurrence and unchanged from last year, with 100 applications of the 309 mentioned above having failed the key information check stage. The CBI maintains that the most common reasons for the withdrawal or return of an application were:

• applicants being unable to show that persons proposed for PCF roles met the F&P requirements (including minimum competency requirements);
• errors or inaccuracies in Individual Questionnaires (“IQ”); and
• applicants failing to submit IQs within 20 working days.

The number of applications from firms seeking approval to complete an acquiring transaction in 2024 was 67, which was a small increase on 2023 figures. 142 applications were received from firms seeking to appoint a tied agent. This was a notable increase compared to 2023 figures (40 applications) but the CBI notes the increase was because of intergroup tied agency moves by one entity.

There were 157 revocations in the retail intermediary/debt management firm sector in 2024, down by 26 compared to 2023, with 156 of these voluntary retail intermediary firm revocations.

3. High-Cost Credit Providers (“HCCPs”)

In 2024, the CBI received zero authorisation applications relating to HCCPs and processing times in respect of authorisation applications by HCCPs were not made available. There were also zero HCCP licence renewals in 2024 due to entities renewing in 2023 and those renewals lasting for five years.

4. Retail Credit Firms / Credit Servicing Firms

In 2024, the CBI received two authorisation applications in respect of retail credit firms / credit servicing firms.  Six applications were either withdrawn or closed.

Four applications were approved in 2024. The average processing time for applications was 854 calendar days, an increase of 121 days compared to 2023. The CBI states that this increase was caused by delay from a single ‘atypical’ business which took a long time to meet the requirements set out in the ‘minded to authorise’ letter, thereby impacting the average figures.

5. Trust or Company Service Providers (“TCSPs”)

TCSPs are authorised under Chapter 9 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 to 2021.  The CBI is the competent authority for the anti-money laundering and countering the financing of terrorism (“AML/CFT”) supervision of TCSPs that are subsidiaries of credit or financial institutions (accounting for approximately 10% of the total TCSP population).

In 2024, the CBI received 10 TCSP authorisation applications and all 10 applications were approved in the year. The number of TCSP applications has decreased by 15 compared to 2023. A TCSP authorisation is valid for a period of three years from the date of authorisation. There were also two TCSP voluntary revocations in 2024.

TCSPs must seek renewal of their authorisation every three years and in 2024, five firms sought renewal of their authorisation. This figure is included in the 10 applications made. The average processing time for applications was 75 calendar days, representing an increase of 37 days compared to 2023.

6. Fund Service Providers

In 2024, the CBI received 18 authorisation applications in respect of fund service providers and 15 were approved. Only two were either withdrawn or closed. 

The average processing time for applications was 202 calendar days, a significant improvement compared to 2023’s figure of 327 calendar days.

The CBI also processed 21 “other” applications. These were three EEA branch inwards notifications, nine EEA branch outwards notifications, six registrations, one additional alternative investment fund (AIF) registration and two revocations.

In respect of post-authorisations, 52 acquiring transactions were received by the CBI in 2024 and the CBI notes that all deadlines for acquiring transactions were met in 2024.

7. Insurance Undertakings

In 2024, the CBI issued authorisation in principle to one insurance/reinsurance undertaking, five Solvency II special purpose vehicles (“SPVs”), and three SPV arrangements.

The average processing time for applications for all insurance types was 21 calendar days, down by 10 days compared to 2023.

In terms of post-authorisations, the Report sets out the number of applications received and average processing times for a number of types of post-authorisations including acquiring transactions (qualifying holdings) of which there were 14 applications received in 2024, with an average processing time of 43 calendar days, and changes of business plan of which there were 15 applications received in 2024, with an average processing time of 80 calendar days.

8. MiFID Investment Firms

In 2024, the CBI received eight authorisation applications. The CBI notes in the Report that the process for authorisation for investment firms involves a (i) pre-application/preliminary stage; (ii) key facts document stage; and (iii) formal application stage.

Five applications were either withdrawn or closed in 2024. Three of the five withdrawn applications were at the second or third stage of the application process.

Six applications were approved in 2024, of which three were for new investment firms in Ireland and three were extensions to authorisation for Irish entities holding existing authorisation as an investment firm.

The average processing time for applications was 256 calendar days, a decrease of 71 calendar days compared to 2023.

In respect of post-authorisations in 2024, the CBI assessed 12 acquiring transaction notifications and processed two voluntary revocations of investment firm licenses and two EEA MiFID Branch Inward Notifications.

For a detailed overview of the regulatory landscape for MiFID investment firms, see our briefing ‘Ireland as a Location for MiFID Investment Firms 2025’ (here).

9. Crowdfunding Service Providers

Regulation (EU) 2020/1503 established an EU regulatory regime for Crowdfunding Service Providers requiring firms providing crowdfunding services to be authorised by a national competent authority.

In 2024, the CBI received zero authorisation applications, and zero applications were either withdrawn or closed.

Two applications were approved in 2024.  Of these, one was a new entrant to the Irish market, and one was an existing firm operating in the market on a transitional basis, in accordance with the regime provided for by Regulation (EU) 2020/1503.

The average processing time for applications increased significantly to 420 calendar days in 2024.  According to the CBI, the main contributing factor to this was incomplete applications being submitted at the initial stage.

The CBI expects similar levels of application activity for 2025.

10. Payment and Electronic Money Institutions

In 2024, the CBI received three authorisation applications from payment institutions (“PIs”) or electronic money institutions (“EMIs”).  Only one application was either withdrawn or closed during the year.

Six PI/EMI authorisations were approved in 2024; the same level as 2023.

The average processing time for applications increased by 74 calendar days, reaching 688 calendar days in 2024. This however is the average time and can be skewed by certain applications. The Report contains similar comments to the First Edition in relation to the increase; attributing this to a lack of preparedness by applicants and delays in submitting responses to CBI queries. In response to this, the Report notes that the CBI released its “Expectations for Authorisation of Payment and Electronic Money Institutions and Registration of Account Information Service Providers”¹ in April 2024 which applicants should have regard to.

In respect of post-authorisations, the CBI processed six post-authorisation acquiring transaction notifications and two revocations (one PI and one bureau de change).

For a detailed overview of the regulatory landscape for PIs and EMIs, see our briefings ‘Ireland as a Location for Payment Institutions 2025’ (here) and ‘Ireland as a Location for Electronic Money Institutions 2025’ (here).

11. Credit Unions

Zero credit unions were authorised in 2024.  A total of twelve credit unions were deregistered or revoked, an increase of eight compared to 2023.

According to the CBI, at the end of 2024 there were 206 credit unions on the credit union register. However, the Report notes that 23 were not actively trading and that those 23 credit unions will be de-registered during 2025/2026.

12. Virtual Asset Service Providers (“VASPs”)

VASPs are registered pursuant to section 108 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.  VASPs are supervised by the CBI for AML/CFT purposes only.

In 2024, the CBI received four authorisation applications by VASPs.  10 applications were either withdrawn or closed. 11 applications were approved in 2024.  The average processing time for applications was 382 calendar days, representing a significant improvement of 148 calendar days compared to 2023 data. 

The entry into application of the Markets in Crypto-Assets Regulation² (“MiCA”), which applied from January 2025, significantly altered the regulatory landscape in Ireland for entities seeking to provide crypto-asset services. In this regard, the Report notes that the CBI has issued guidance for VASPs in respect of MiCA³.

13. Credit Institutions

In 2024, the CBI received two applications by credit institutions, an increase on the one application received in 2023. However, no approvals were issued during 2024.

The Report notes that there are three expressions of interest and at least one of those is anticipated to enter the exploratory phase during 2025.

The Report also notes that two new EEA branches on the freedom of establishment basis were set up in 2024. Further, one credit institution licence was withdrawn in 2024 and one third-country branch licence lapsed during 2024.

14. Prospectus Approval

The CBI approves prospectuses under the Prospectus Regulation[4] for equity securities, a variety of different debt securities, and closed-end investment funds.

In 2024, the CBI received 644 applications for approval. 

759 applications were approved in 2024 and largely related to debt securities.  The average processing time for applications remained the same as 2023, at 15 calendar days.

Insights into the F&P Regime

The main purpose of the F&P regime is to ensure that individuals in key and customer facing positions (known as controlled functions (CFs), and which includes PCFs) within regulated FSPs and certain holding companies, are competent, capable, honest, ethical, of integrity, and financially sound.

Over the course of 2024, the CBI received 3,060 PCF applications.  2,683 applications were approved in the year.  No applications were rejected in the year; however, 301 were returned as incomplete and 128 were withdrawn by the applicant.  444 PCF applications remained in progress with the CBI at year end 2024.

The average approval time for PCF applications in 2024 was 52 calendar days, and 82% of PCF applications were approved within 90 calendar days.

In 2024, the CBI conducted 47 F&P interviews, a decrease of 79 compared to 2023. The CBI notes that interviews remain an effective method of gathering information from an applicant as a means of explanation or clarification. The Report further provides a breakdown of these interviews in relation to sector and role, with VASPs being the sector most interviewed (nine entities had interviews), followed closely by credit institutions (eight entities interviewed) and PCF-1 Executive Director being the most interviewed role (from 11 entities) followed by PCF-12 Head of Compliance (from eight entities).

How Can McCann FitzGerald LLP Help?

McCann FitzGerald LLP is a premier law firm in Ireland and advises on the full range of legal, tax and compliance activities undertaken by regulated financial service providers in Ireland. We have substantial experience in successfully guiding applicants through the regulatory authorisation process for all types of authorisations, and in helping them to comply with their legal obligations, once established.  If you are considering seeking CBI authorisation, please contact us for further information as to how we can help guide you through the process.

Also contributed to by Ben Robertson