Payments & E-Money in Ireland

Key dates

2020-11-01

Beginning of the period during which the Central Bank found Coinbase Ireland breached safeguarding and outsourcing obligations under the Electronic Money Regulations 2011.

2025-08-19

End of the enforcement period identified by the Central Bank.

2026-10-21

Central Bank of Ireland and Coinbase Ireland reached the settlement under the undisputed-facts settlement process.

2026-10-22

Central Bank published the enforcement outcome and announced the proposed reprimand and discounted monetary penalty.

Suggested considerations

• Firms should map all safeguarding responsibilities to the specific Irish or EU-authorised entity that holds the regulatory obligation and document how the entity retains effective control despite group or third-party outsourcing.
• Compliance teams may wish to assess whether the regulated entity has sufficient local expertise, decision-making authority and management information to oversee safeguarding and challenge outsourced providers on an ongoing basis.
• Firms should consider independently validating the design of safeguarding calculations, reconciliations, treasury-rebalancing processes and designated safeguarding-account funding, including testing for data, systems and mapping errors.
• Firms may wish to perform daily or otherwise risk-appropriate reconciliations between customer liabilities, safeguarding obligations and funds held in designated accounts, with documented investigation and remediation of exceptions.
• Boards and senior management should consider whether control testing covers the complete safeguarding process, including outsourced components, and whether testing is sufficiently independent and frequent to identify prolonged shortfalls.
• Firms should review escalation procedures for safeguarding incidents, control failures, underfunding and material changes to operating models, including criteria and ownership for notifying the Central Bank of Ireland.
• Authorised firms should compare their current operating model with representations, commitments and governance arrangements submitted during authorisation and assess whether any material changes were notified to the Central Bank.
• Outsourcing registers, contracts and service-level arrangements should be reviewed to confirm clear regulatory access, audit rights, information rights, incident reporting, business-continuity provisions and accountability for safeguarding outcomes.

What changed

The publication does not introduce a new statutory rule; it applies existing obligations under the Electronic Money Regulations 2011 and establishes a substantial enforcement precedent. Coinbase Ireland admitted that it lacked an adequate outsourcing-governance framework, relied excessively on a US Coinbase Group entity, lacked sufficient local skill and expertise to oversee safeguarding, used inadequately designed and tested systems that left its designated safeguarding account underfunded, and lacked adequate escalation and reporting arrangements for material safeguarding changes.

Key dates

End of 2026

- The ECB Governing Council is expected to make the final decision on the new banknote design

23 July 2026

- The Central Bank of Ireland publishes the press release encouraging public participation in the ECB consultation

21 September 2026

- The public survey on the shortlisted euro banknote designs closes

Suggested considerations

• Review the ECB consultation materials and assess whether your firm has any direct operational exposure to future euro banknote changes.
• Monitor ECB and Central Bank of Ireland updates for the final design decision expected around the end of 2026.
• Prepare internal stakeholder briefings for cash operations, branch operations, payments, customer service, and communications teams on the expected euro banknote redesign timeline.
• If your firm accepts or processes cash, begin a preliminary review of any systems, controls, or vendor dependencies that could be affected by future note specifications, authentication features, or rollout timing.
• Update external messaging and FAQs only after the ECB publishes the final banknote design and implementation details.

What changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the themes “European culture” and “Rivers and birds.”
• The ECB has opened an online public survey to gather feedback on the proposed designs.
• The survey is open until 21 September 2026.
• The ECB Governing Council is expected to make the final design decision around the end of 2026.
• The current publication does not impose any immediate compliance obligation on firms; it is a consultation and design-selection step, not an enacted regulatory rule.

Key dates

Late 2026

- Expected Governing Council decision on the final design proposal for the new euro banknote series

Subsequent years (post‑2026)

- Progressive introduction of new‑series euro banknotes into circulation, co‑circulating with existing series which retain value

21 September 2026

- Closure of the ECB public online survey on the ten shortlisted euro banknote design proposals

Suggested considerations

• Establish an internal project workstream to monitor ECB communications on the banknote redesign and plan for operational impacts on cash handling, ATM networks and merchant devices.
• Conduct a preliminary impact assessment of how new banknote security and design features may affect existing banknote sorting, authentication and recycling equipment, and identify likely upgrade or replacement needs.
• Engage with ATM and cash‑handling hardware vendors to understand expected firmware, sensor and software changes required to support the new banknote series and to secure upgrade slots ahead of issuance.
• Review and update internal cash‑handling and banknote authentication procedures, including staff training materials, to incorporate new design and security features once technical specifications are published.
• Plan customer communications strategies to explain the coexistence of old and new series banknotes, reaffirm the continued validity of previous series, and address any fraud or counterfeiting concerns.

What changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the two themes “European culture” and “Rivers and birds”.
• An EU‑wide online public survey has been launched to collect feedback on the shortlisted designs, forming part of the ECB’s inclusive approach to banknote design.
• The ECB’s Governing Council will select a single design proposal around the end of 2026, informed by the Design Contest Jury conclusions, technical assessments and survey results.
• The chosen design will undergo further development and testing before production, including integration of new and improved security features.
• The new series of euro banknotes will be introduced into circulation in subsequent years, alongside existing series, which will retain their legal value and continue to circulate.

Key dates

01 January 2025

– CBI established a dedicated team to investigate and prosecute offences under financial services legislation

2025 (effective date – specific day not stated)

– The modernised Consumer Protection Code came into effect for Irish‑regulated firms

2025 (throughout the year)

– CBI implemented its new supervisory approach centred on four safeguarding outcomes and reorganised into multi‑disciplinary supervisory teams

2025 (theme year)

– CBI’s Innovation Sandbox focused on combatting financial crime, with seven projects selected on information sharing, identity verification and fraud prevention

December 2025

– CBI published “Regulating & Supervising well – a more effective and efficient framework,” detailing its simplified and outcomes‑focused regulatory framework

Suggested considerations

• Map the modernised Consumer Protection Code requirements against existing policies, procedures and customer journeys to identify and remediate gaps, particularly in digital channels, disclosure, sales practices and complaints handling.
• Update vulnerable customer policies, customer‑facing procedures, training materials and systems flags to ensure systematic identification, recording and tailored treatment of consumers in vulnerable circumstances.
• Review mortgage switching processes and documentation to ensure customers receive clear, comparative information on switching options, are not subject to unreasonable barriers or retention tactics, and that conflicts of interest are controlled and documented.
• Conduct a comprehensive review of insurance auto‑renewal practices (including communications, timing, consent mechanisms and pricing) and implement changes to align with the strengthened consumer protection expectations.
• Strengthen fraud and scam prevention frameworks by enhancing customer education, warnings, authentication, monitoring, incident response and redress processes, with particular focus on online and mobile channels.

What changed

• - The modernised Consumer Protection Code entered into effect in 2025, updating the existing Irish conduct framework to reflect digital delivery of financial services and strengthen protections in...
• Requirements on informing consumers effectively were tightened, implying higher expectations on clear, fair, not misleading disclosures across digital and traditional channels, and more robust...
• New or enhanced obligations concerning consumers in vulnerable circumstances now apply, requiring firms to identify, record and respond to vulnerability and to embed vulnerability considerations into...
• Mortgage switching processes are subject to strengthened conduct standards, increasing expectations on how options are presented, how customers are supported to switch, and how potential conflicts or...
• Insurance auto‑renewal practices are now more tightly controlled, requiring clearer pre‑renewal information, active consent and controls to mitigate consumer detriment from inertia or unsuitable...

Key dates

29 May 2026

- CBI issues and publishes the warning notice identifying Fire Financial Services Limited (CLONE) as an unauthorised firm and clone of the legitimate Fire Financial Services Limited (C58301), and lists it under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Review and update internal fraud‑risk and financial crime risk assessments to explicitly cover clone‑firm risks, including inheritance scams and impersonation of authorised entities.
• Integrate the specific domains, email addresses, and phone numbers listed in the CBI notice into fraud‑monitoring tools, allow‑/block‑lists, and case‑management systems, and ensure they are treated as high‑risk indicators.
• Ensure front‑line, call‑centre, and relationship‑management staff receive targeted training and briefing on this specific clone case and on common clone‑firm red flags, including requests related to inheritance payments and use of unofficial domains.
• Enhance onboarding and counterparty due diligence procedures to include systematic checks against the CBI “unauthorised firms” list and the CBI public registers, especially where firms claim Irish regulation or use names similar to existing authorised firms.
• Update third‑party and introducer due diligence controls to verify that any firm referring business or presenting as an intermediary is properly authorised and not listed as unauthorised under section 53 of the Central Bank (Supervision and Enforcement) Act 2013.

What changed

• - CBI has formally identified Fire Financial Services Limited (CLONE) as an unauthorised entity that is not authorised to provide banking business or payment services in Ireland and is misusing the...
• CBI has published specific fraud indicators associated with this clone, including website domains (e.g.
• The warning explicitly states that the clone firm appears to be running an inheritance scam, including the use of fake documentation allegedly from third parties, which should be treated as a red...
• CBI reiterates that there is no connection between the legitimate authorised Fire Financial Services Limited (C58301) and this fraudulent entity, thereby clarifying the status of the genuine firm and...
• The firm’s name is formally published on CBI’s list of unauthorised firms under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, increasing regulatory expectation that firms...

Key dates

24 March 2025

- CBI publishes revised CPC 2025, Standards for Business Regulations, Consumer Protection Regulations, and guidance

24 March 2026

- CPC 2025 takes effect; existing 2012 Code ceases (12-month implementation period ends)

Until 24 March 2026

- 2012 Code (with addenda) remains in force

Suggested considerations

• Gap analysis: Map current policies/processes against CPC 2025 using CBI's mapping tool; update for new obligations like digital service design, vulnerability screening, fraud measures.
• Policy/system updates: Implement "secure customers’ interests" framework; enhance disclosures (e.g., mortgages, charges, unregulated activities); train staff on conduct standards/vulnerable consumers.
• Governance/risk: Strengthen board oversight, risk management for cyber/fraud/digital risks; distinguish regulated/unregulated activities.
• Testing/monitoring: Develop records/compliance systems; test advertising/bundling; integrate sustainability claims checks.
• Stakeholder engagement: Review CBI guidance/FAQs; prepare for supervision during implementation.

What changed

• The CPC 2025 comprises Standards for Business Regulations (governance, resources, risk management, conduct standards) and Consumer Protection Regulations (cross-sectoral and sector-specific rules for...
• Core obligation: Firms must "secure customers’ interests," shifting to a proactive, customer-focused mindset.
• Cross-sectoral requirements: Knowing the consumer/suitability; conflicts of interest/remuneration; vulnerable consumers (updated definition); digitalisation (customer-focused design); effective...
• Specific enhancements: Fraud/scam protections; mortgage switching disclosures; greenwashing prevention via clear sustainability claims; expanded consumer definition (e.g., SMEs up to €5m turnover...
• Supporting materials: Guidance on securing interests/vulnerable consumers, mapping tool for legacy codes, redline amendments.

Key dates

5 June 2026 Deadline

- Deadline for stakeholder submissions responding to the 16 questions in DP12

Post

5 June 2026; - CBI to publish a feedback statement assessing responses and existing policy fit. (Source: https://www.centralbank.ie/news/article/press-release-discussion-paper-tokenisation-and-distributed-ledger-technology-in-financial-services-5-march-26 [publication]; https://www.arthurcox.com/insights/central-bank-issues-discussion-paper-on-dlt-tokenisation-in-financial-services/ )

Suggested considerations

• Review DP12 (PDF available via CBI site) and prepare/ submit responses to the 16 questions by 5 June 2026, focusing on legal clarity, risks, funds tokenisation, and enablers like interoperability.
• Engage in CBI's structured stakeholder dialogues to influence future frameworks.
• Assess internal DLT/tokenisation pilots or plans against discussed risks (e.g., operational resilience, scalability) and opportunities (e.g., fractional ownership, 24/7 liquidity).

What changed

This is a non-binding discussion paper, not a regulatory change or new requirement; it poses 16 questions on topics including legal recognition of tokenised instruments, governance, infrastructure, funds (e.g., tokenised MMFs and ETFs), payments, and risks like operational resilience and interoperability. It highlights needs for policy intervention to avoid fragmented "walled gardens," ensure central bank money's role, and address challenges in fractionalisation, transparency, and settlement finality, but no mandates are imposed yet.

Key dates

Second half 2026

- Ireland assumes EU Council Presidency; CBI will support government during this period

10 February 2026

- CBI published its 2026 Regulatory and Supervisory Priorities, which establish the operational framework within which this governance philosophy applies

18 February 2026

- This speech delivered, reinforcing institutional independence principles

Suggested considerations

• *Understand CBI decision-making philosophy: Recognize that CBI supervisory decisions are grounded in long-term economic stability objectives, not short-term political cycles.
• *Align governance with credibility principles: The speech identifies four credibility pillars—competence, engagement, coherence, and public trust. Regulated firms should ensure their governance frameworks reflect these principles in their own operations.
• *Monitor 2026 supervisory priorities: The speech references CBI's published 2026 Regulatory and Supervisory Priorities, which include maintaining resilience to geopolitical risks, securing consumer and investor interests, and delivering new responsibilities under Access to Cash legislation.

What changed

• This is not a regulatory change document but a governance clarification with compliance implications:
• Reframing of independence: Central bank independence is characterized as an "anchor" enabling long-term decision-making rather than isolation from society.
• Credibility framework: Credibility depends on competence, engagement, coherence, and public trust—not institutional distance alone.
• Accountability emphasis: Independence requires continuous dialogue with society and other economic governance institutions; it "does not mean isolation."
• Historical validation: The speech references the 1960s-1970s macroeconomic instability under political pressure versus post-pandemic effectiveness of credible central banks in controlling inflation.

Key dates

30 June 2025

– Finance (Provision of Access to Cash Infrastructure) Act 2025 commenced

5 December 2025 – 4 March 2026

– Public consultation period for local deficiency guidelines and ATM service standards

Early 2026

– First publication of quarterly cash infrastructure data expected

2026

– Central Bank to publish final ATM service standards regulations

Q1 2026

– Direct engagement with consumers, people with disabilities, older people, and SMEs

Suggested considerations

• *For designated credit institutions:
• Monitor consultation developments and prepare for compliance with minimum cash infrastructure maintenance levels once regulations are finalized
• Prepare to provide quarterly data on ATM numbers, locations, and availability hours
• *For ATM operators:
• Engage with the consultation process to provide feedback on proposed service standards

What changed

• The consultation covers two primary regulatory components: 1. Local Deficiency Guidelines The Central Bank will establish procedures for identifying geographical areas where individuals and SMEs...
• Hours of ATM availability
• Cash withdrawal limits
• Banknote denomination stocking requirements
• Maximum ATM unavailability periods

Key dates

23 April 2021

19 March 2025; Period of breaches, including 12-month window of unmonitored €176 billion transactions

5 November 2025

Settlement reached between CBI and Coinbase Europe

6 November 2025

CBI public announcement and Settlement Notice published

12 January 2026

High Court confirmed sanctions, making them final and effective

Suggested considerations

• Conduct Gap Analysis: Review transaction monitoring systems for configuration errors, back-testing historical data, and ensuring 100% coverage of high-risk transactions.
• Enhance Controls: Implement robust internal policies, automated alerts, and governance to detect/prevent ML/TF; test systems regularly for faults affecting >1% of volume.
• Accelerate STR Processes: Ensure real-time suspicion flagging and filing; remediate delays via prioritized back-monitoring with FIU coordination.
• Board/Compliance Reporting: Document remediation plans, as Coinbase did, and prepare for audits/enforcement; train staff on VASP-specific risks under MiCA/AMLA.
• Third-Party Review: Engage independent auditors to validate fixes, mirroring Coinbase's post-error cooperation.

What changed

This is an enforcement action, not new legislation, but it reinforces existing CJA 2010 requirements for VASPs: ongoing transaction monitoring, immediate STR filing to the Financial Intelligence Unit (FIU) and Revenue Commissioners upon suspicion of money laundering or terrorist financing, and adoption of internal policies/controls to prevent/detect financial crime.