knowledge 7 August 2026 |

The CBI’s Second Payments and E-Money Newsletter: What Firms Need to Know

This briefing provides an overview of the key takeaways for those authorised as payment and e-money institutions, and for those who are seeking or plan to seek authorisation in Ireland.

The European Banking Authority (the “EBA”) Q&A 6336 in relation to the definition of e-money

The CBI had communicated with firms on this important EBA Q&A in December 2025 but notes that many firms have not fully assessed the impact of this Q&A on their business models. The CBI intends to increase its engagement with the sector in the coming months and is encouraging firms to prioritise this review. 

Material Changes to Business Model

The CBI notes that not all firms have been communicating with it regarding material changes to business models and has reminded payment and e-money firms that, under the Electronic Money Regulations and Payment Services Regulations, prior approval is required before implementing any such material changes and to engage with the CBI early.

Firms seeking approval for a material business model change should submit a board-approved risk assessment addressing the impact of the proposed change on key risk areas, including safeguarding, AML/CFT, operational, IT and consumer risks. Firms must also demonstrate that they can support the change from an operational, financial and risk perspective. Where a firm is of the view that a change is not material, it should appropriately document this.

The CBI notes that Boards are responsible for determining what constitutes material change for their firm but gives examples of what may be material including:

• proposed significant changes to a product or service, including the way the product is provided, such as through branches or agents; 
• business growth significantly beyond that envisaged during authorisation;
• a material change that would affect the firm’s risk profile; and/or
• a material change that would alter the firm’s target market or customer profile.

Consumer Protection

The CBI reminds firms to ensure it is familiar with the obligations applying to payment and e-money firms under the Consumer Protection Code 2025 (the “CPC”), that came into effect on 24 March 2026, including to know who its customers are and whether they fall within the definition of a consumer under the CPC.

The CBI notes it is focused on ensuring better outcomes for consumers, particularly regarding complaints handling. The CBI carried out a thematic review of customer experience in 2025 and 2026 which focused on complaints. While the CBI notes the outcome of that thematic assessment will be published later this year, including expectations for firms, it notes now that it continued to see instances of poor customer service being provided by firms. It reminds firms that complaints must be handled fairly, effectively and in a timely way.

The CBI also reminds firms of the CPC obligation to inform customers effectively. The CBI held an industry webinar on this on 29 July 2026 during which it set out examples of good practice and well as industry observations. The CBI will also host a Payments and E-Money industry seminar on 21 October 2026.

Multi-license Applications

The CBI has observed a growing number of firms seeking multiple regulatory authorisations within a single legal entity, including authorisations as payment institutions, e-money institutions, crypto-asset service providers and MiFID firms. In response, the CBI has adopted a coordinated supervisory approach designed to streamline the authorisation process including placing reliance on previous assessments where appropriate, reducing multiple documentation requests and having a single key facts document that covers various regulatory requirements.

AML/CFT

The CBI is encouraging firms to prepare for the significant changes arising from the EU AML/CFT package, and to assess the impact of the new framework on their business. The CBI advises firms to ensure they are familiar with the Anti-Money Laundering Regulation (AMLR) and to monitor the Anti-Money Laundering Authority’s (“AMLA”) website to ensure awareness of any hearings and consultations that would allow them to input into technical standards and guidelines.

Risk Evaluation Questionnaires (REQs)

Following the introduction of the new sector-specific REQ for payments and e-money in 2025, the CBI notes that it will be staggering submissions for REQs in 2026 to allow firms to familiarise themselves with the new requirements. The first REQ submission for payment and e-money institutions, covering 2024 data, was completed in February 2026. The next submission, covering 2025 data, is due by 9 September 2026.

The CBI intends to align REQ reporting timelines with the reporting framework being developed by AMLA. As a result:

• REQs covering 2026 data will be due in March 2027; and
• from 2028 onwards, firms will be required to submit REQs annually each March, based on data from the preceding calendar year.

Key Takeaways

The Newsletter gives firms helpful information on what the CBI is focusing on from a payments and e-money perspective, including key dates to allow forward planning. Firms should ensure they have regard to the various matters that the CBI has flagged in the newsletter, including ensuring that they have appropriate systems and governance arrangements in place to support timely and accurate submission of REQs, and consider whether any updates to business models or processes are required.

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 and in helping them to comply with their legal obligations, once established. If you are considering setting up a payment or e-money institution authorised under Irish legislation or if you are already authorised and require our assistance with ongoing obligations, please contact us for further information as to how we can help.