knowledge 3 July 2026 |

The CBI’s Authorisations and Gatekeeping Report 2025: Key Updates for Applicants

The Central Bank of Ireland (“CBI”) has published the third edition of its ‘Authorisations and Gatekeeping Report’ (“the Report”). Building on the first two editions, it provides a comprehensive sectoral breakdown of authorisation activity, including average processing times, CBI expectations, clear metrics with sector-specific commentary, detailed information on the processing of fitness and probity (“F&P”) applications, and an update on the CBI’s 2025 service standards. The Report reaffirms the CBI's commitment to a risk-based, outcomes-focused and proportionate approach to authorisation, within the context of legislative requirements, guidelines and best practice. For an overview of the key takeaways from the First and Second Editions, which remain relevant for consideration by applicants, please see our original two briefings (First Edition) and (Second Edition). In this briefing we set out what the CBI notes it expects from applicants, including in relation to F&P applications.

Authorisation expectations

Similar to last year’s report, the Report reiterates the CBI’s expectations as set out in the cross-industry ‘Guidance on expectations for applicants seeking authorisation from the Central Bank of Ireland to operate as a regulated Firm,’ published in November 2024 (the “Guidance”), which firms should ensure they are familiar with. The Guidance sets out key principles on the clarity, accuracy and completeness of applications, building on existing material and outlining the CBI’s expectations of applicant firms. Applicants are expected to demonstrate a strong understanding of legal and sectoral requirements, engage openly and cooperatively, and provide forward-looking information such as business plans and projections. Firms must also show sufficient presence in Ireland, with key decisions and risk management carried out locally. In addition, the Guidance outlines expectations relating to outsourcing, safeguarding customer funds (which the CBI notes is of “paramount importance”), robust capital arrangements, compliance frameworks, clear ownership, environmental, social and governance (ESG) risk management, recovery and wind-down planning, and anti-money laundering and combating the financing of terrorism (AML/CFT) arrangements.

How to ensure a more efficient authorisation process

The CBI has set out a number of helpful points for applicants on how to speed up the application process. These include:

• demonstrating a strong understanding of applicable regulations and being properly prepared for the authorisation process;
• engaging with the CBI as early as possible, being transparent and providing timely responses to the CBI throughout the authorisation process;
• being open to feedback from the CBI;
• having a strong culture, with “tone from the top”;
• having a clearly defined business model and no significant changes to that model during the application process;
• having robust governance and local risk management frameworks;
• ensuring compliance with regulatory capital requirements and safeguarding;
• having strong consumer protection measures; and
• having a proper presence in Ireland and commitment to the jurisdiction.

In relation to crypto-asset service providers (“CASPs”), the CBI notes that firms are expected to implement strong, consumer-focused governance, supported by clear disclosures and transparent marketing practices. This is due to the elevated risks in areas such as consumer protection and safeguarding of client assets that CASPs can present compared to more traditional trading firms and venues. To further streamline the CASP application process, the CBI intends to shortly introduce a new online portal, which will provide a more efficient and transparent submission and communication channel.

Further progress in relation to F&P Gatekeeping

The CBI has included a specific section in the Report on F&P gatekeeping activity which discusses the 2025 progress related to F&P gatekeeping, activity levels and what the CBI has planned.

In 2025 the CBI’s F&P function underwent significant transformation following the 2024 review by Andrea Enria (the “Enria Review”). The Gatekeeping Decisions Committee, established on 1 March 2025, deals with pre-approval controlled function and authorisation application refusals, involuntary revocation of authorisations and opposing acquiring transactions. The Report notes that during the year, the Committee handled three cases resulting in two refusals and one involuntary revocation.

The Report also provides statistical data on the F&P application process for 2025. Overall F&P volumes remained comparable to 2024, with 3,032 PCF applications received and 2,684 approved. The top role applied for was non-executive director (PCF-2A). A total of 97% of assessments completed within the 90-day service standard, with an average approval time of 50 calendar days. Applications were spread across various sectors, with 64% related to Funds, Fund Service Providers and Retail Intermediaries. Insurance applicants declined from 15% in 2024 to 11% in 2025. The number of interviews conducted fell from 47 to 26, reflecting a shift to a single comprehensive interview model following the Enria Review and increased use of alternative information-gathering tools. The CBI also notes that it interviewed several firm proposers in 2025 which it found to be a useful tool to gain further information regarding applications and therefore intends to continue this process.

A total of 282 incomplete applications were returned, representing a 6% reduction from 2024. Where key information is missing, the CBI cannot begin its assessment, which can lead to delays and applicant frustration. To address this, the CBI is hosting yearly webinars on how to use the portal, introducing system enhancements to flag common mistakes before applications are submitted, reducing documentation burden, and clearer internal standards on what ‘incomplete’ means. The CBI notes that where applications were returned, the most common issues were an invalid proposer, failure to show compliance with the minimum competency code (MCC), selecting the incorrect company structure, and legal attestations for PSD2 or crowdfunding applications (which is now removed).

Planned enhancements related to F&P for 2026

The CBI has outlined several planned enhancements for 2026 aimed at reducing processing times:

• requiring employer references only for sole traders/single-director firms, removing them for all other sectors to reduce burden while maintaining a risk‑based approach where necessary;
• extending Garda vetting validity to 12 months to support recently approved applicants seeking further approvals;
• expanding the streamlined application process to more firms for same-role/same-sector applications, enabling faster, simpler assessments; and
• updating the Individual Questionnaire to reflect reduced evidence requirements for PCF applicants for payment institutions/e-money institutions and crowdfunding service providers.

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.