knowledge 6 July 2026 |

The CBI’s Authorisations and Gatekeeping Report 2025: Authorisation Activity

Overview by Sector

Processing times improved across most sectors but continued to increase in others. The CBI highlights that timelines remain strongly influenced by the complexity of the proposed business model, the completeness and quality of the application and how promptly applicants respond to queries. We set out some key points on many of the sectors covered in the Report below.

1. Funds

• Activity: Strong growth in application numbers and approvals. Authorisations of Undertakings for Collective Investment in Transferable Securities (UCITS), Retail Investor Alternative Investment Funds (RIAIFs), Retail European Long-term Investment Funds (“ELTIFs”), Qualifying Investor Alternative Investment Funds (QIAIFs) and Professional ELTIFs all increased. Post-authorisation activity also grew.
• Average Processing Time: 91 calendar days, a slight increase from 2024, with timelines influenced by complexity of applications, whether they were atypical and the length of time applicants took to respond to the CBI’s queries. Review times remained unchanged for investment manager applications, averaging at one day for EU investment managers and four days for non-EU investment managers.

2. Retail Intermediaries/ Debt Management Firms

• Activity: Decrease in retail intermediary authorisations, partly due to less mortgage intermediary renewals in 2025 but it continues to be an active sector. Following several years of no debt management authorisations, one firm was authorised in 2025. There was an increase in acquiring transactions, while tied agent authorisations decreased but this was influenced by intra-group movements by one entity. Voluntary revocations also decreased.
• Average Processing Time: 105 days; an improvement from 2024. The quality of applications has improved and there are fewer incomplete applications. Processing times aligned with CBI expectations and are expected to improve further in 2026. Withdrawals/returns of applications by the CBI was largely down to fitness and probity (“F&P”) issues, including failure to show that proposed role holders met the F&P requirements.

3. High-Cost Credit Providers (“HCCPs”), Retail Credit Firms (“RCFs”) and Credit Servicing Firms (“CSFs”):

• Activity: One HCCP application was approved, with no new applications received during the year. No renewals were due as licences were renewed for five years in 2023. Seven RCF/CSF applications were approved with one non-transitional RCF application and no CSF applications received.
• Average Processing Time: 76 days for RCFs/CSFs. Most ongoing RCF applications relate to the 2022 indirect credit legislation, with firms operating on a transitional arrangement while applications are being assessed.

4. Trust or Company Service Provider (“TCSP”)

• Activity: The CBI received five TCSP renewal applications in 2025, with all applications approved.
• Average Processing Time: 55 calendar days, a decrease compared to 2024.

5. Insurance

• Activity: Eight insurance applications were received with the same amount receiving authorisation. Authorisation in principle was granted to two (re)insurance undertakings, three Solvency II special purpose vehicles (“SPVs”), and three SPV arrangements.
• Average Processing Time: 21 days for insurance generally but 208 days for (re)insurance undertakings, 41 for Solvency II SPVs and 13 for SPV arrangements. Timing largely depends on the time taken to submit a complete application and to satisfy the authorisation-in-principle letter requirements. The average time for post-authorisation approvals depends on the entity type, with acquiring transactions taking 57 days, branch applications taking 32 days and change of business plans taking 74 days.

6. Markets in Financial Instruments Directive (“MiFID”) Investment Firms

• Activity: Nine applications for MiFID investment firms were received in 2025, with six authorisations completed. The CBI also observed an increased trend in complex acquiring transactions throughout 2025. The pipeline for 2026 remains robust.
• Average Processing Time: A decrease to 245 calendar days. The average key facts document (“KFD”) stage for new applicants was 128 calendar days, with applicants taking an average of 95 days to submit a formal application after being invited to. Common causes of delay included non‑compliant business models and significant changes to business models or governance structures during the assessment process.

7. Payment Institutions (“PIs”) and Electronic Money Institutions (“EMIs”)

Activity: Strong growth in both sectors in 2025 with nine applications received, an increase from three in 2024. This is due to the requirements for certain crypto-asset service providers (“CASPs”) that undertake activity related to electronic money tokens to obtain PI authorisation. There was a slight decrease in approvals but an increase in the number of firms at pre-application stage which indicated strong activity for 2026. Greater emphasis will be placed on early engagement with firms to improve readiness before application submission.

Average Processing Time: 763 days; an increase from 2024. This is mainly due to incomplete applications, changes to business models and paused applications. Some firms took additional time to progress or amended their applications in response to the EBA’s 2025 Q&A, which impacted the electronic money sector.

8. CASPs

• Activity: 11 applications received with ten approved (eight previously virtual asset service providers). A strong pipeline of CASP applications is expected to continue into 2026, including global groups and Irish firms. Due to the European Banking Authority’s ‘No Action Letter’ clarifying the interaction between the Markets in Crypto-Assets Regulation (“MiCAR”) and the Payments Service Directive 2 (“PSD2”), with some firms requiring authorisation as a CASP and under PSD2, the CBI adopted a streamlined PI authorisation process. This leverages information already provided in CASP applications, meaning firms can continue operating while progressing through the authorisation process in line with European Banking Authority’s timelines.
• Average Processing Time: 171 calendar days, reflecting only the first year of authorisation and relating solely to KFD and formal application assessments.

9. MiCAR

• Activity: Under MiCAR, the CBI is responsible for receiving notifications of whitepapers for certain crypto‑assets (excluding ARTs and EMTs). In 2025, 305 whitepapers were notified and approved for transmission to European Securities and Markets Authority (ESMA) and the national competent authority of the other EU jurisdictions where the crypto-asset will be marketed.
• Average Processing Time: Five calendar days. 

10. Credit Institutions (“CIs”)

• Activity: Three applications received, with one CI authorised in 2025, marking the first Irish-domiciled authorisation since 2019. Two CI licences were voluntarily withdrawn during 2025. 31 EEA CIs were operating in Ireland through branches, including one new branch.
• Average Processing Time: 355 calendar days.

11. Prospectus Approval

• Activity: 658 applications received, with 649 applications approved. All applications related to debt securities. A number of issuers also provided for the issuance of debt securities with the EU Green Bond label following the introduction of the EU Green Bond Regulation which came into force in December 2024.
• Average Processing Time: 15 calendar days, remaining the same as 2024.

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.