Background
The Central Bank of Ireland (“CBI”) has published the second edition of its Payments and E-Money Newsletter (the “Newsletter”), providing an update on its supervisory priorities, regulatory developments and key focus areas for payment institutions and electronic money institutions.
E-Money Definition
Following its December 2025 communication, the CBI has found that many firms have not thoroughly assessed the impact of EBA Q&A 63361 (which clarifies the e-money definition) on their business models and has urged firms to prioritise this analysis ahead of intensified industry engagement in the coming months.
Material Changes of Business Model
The CBI has set out its expectations regarding the notification obligation under Regulation 18 of the European Communities (Electronic Money) Regulations 2011 (“EMR”) and Regulation 27 of the European Union (Payment Services) Regulations 2018 (“PSR”), which require firms to notify the CBI in advance of proposed material changes to