Safeguarding Requirements For Payment And E-Money Authorisations

At the core of electronic-money and payment institutions' regulatory obligations is the safeguarding of “user funds”. At its essence and in broad terms, funds received and held by such institutions for the provision of payment services and issuance of e-money should be protected in such a way that the insolvency of those institutions does not result in losses for their customers. As we have advised clients through their application processes with the Central Bank of Ireland and further through ongoing supervisory arrangements, it is clear that safeguarding is of critical importance to the Central Bank. The potential for users to lose money as a result of an institution's failure represents key financial and conduct risks, in particular in the context of the expansion of fintech offerings in Ireland.