A payment, e-money or crypto licence in Ireland for a founder from outside the EU
You run a payments, e-money or crypto business from outside the EU and want an Irish licence to reach EU customers. The Central Bank of Ireland decides, and its own report puts the average payment or e-money authorisation at 763 days in 2025. It also expects real substance in Ireland, with independent directors on the board and control of the safeguarding accounts kept in the Irish company.
What a non-EU founder faces in Ireland
Nine points, who carries them and how long they take.
| Obligation | Rule | Who | When or how long | Official source |
|---|---|---|---|---|
| Licensing authority | The Central Bank of Ireland (CBI) authorises payment institutions, e-money institutions and CASPs | The Irish company that will hold the licence | Before any regulated service | CBI report 2025 |
| PI or EMI decision | Legal deadline of 3 months after a complete file | The applicant | 763 days on average in 2025 | PSD2 art. 12, CBI report |
| CASP decision | 25 working days to check completeness, 40 working days to decide after a complete file | The applicant | 171 days on average in 2025 | MiCA art. 63, CBI report |
| Irish establishment | Head office in Ireland and part of the business there; for a CASP, effective management in the EU and one EU-resident director | The company and its board | At application | PSD2 art. 11, MiCA art. 59 |
| Substance and board | Substance in Ireland; executive, non-executive and independent non-executive directors; PCF roles approved | Board and senior managers | Chair and chief executive named early in the process | CBI expectations |
| Client funds | Approval of safeguarding accounts stays in the Irish entity; safeguarding bank authorised in the EEA | The PI or EMI | Part of the authorisation file | CBI expectations |
| Initial capital | PI EUR 20,000 to EUR 125,000 by service; EMI at least EUR 350,000; CASP EUR 50,000 to EUR 150,000 by class | The company | At authorisation | PSD2 art. 7, EMD2 art. 4, MiCA art. 67 |
| Passport | Notification through the CBI to each host country | The authorised firm | PI: 1 month plus 1 month; CASP: 10 working days, start by day 15 | PSD2 art. 28, MiCA art. 65 |
| E-money tokens | Services on e-money tokens may need a payment licence; 5 CASPs applied for one in the fourth quarter of 2025 | CASPs offering services on e-money tokens | Deadline of 1 March 2026 | CBI report |
The sections below take each line in turn. The CBI figures come from its authorisations report for 2025, published in June 2026.
How long the Central Bank of Ireland takes
The legal deadlines are short. The published averages are not.
One authority handles all three licences. The Central Bank of Ireland authorises payment institutions (PI), e-money institutions (EMI) and crypto-asset service providers (CASP) under MiCA, and publishes how many files it decided and how long they took (CBI Authorisations and Gatekeeping Report 2025).
763 days on average
The average time for a PI or EMI authorisation went from 614 days in 2023 to 688 days in 2024 and 763 days in 2025. The CBI granted 4 authorisations in 2025, received 9 applications and had 13 still pending. The sector counted 58 firms holding EUR 11.8 billion of safeguarded funds (CBI report).
171 days on average
The CBI authorised 10 CASPs in 2025, 8 of them previously registered crypto providers. The average processing time was 171 days. It received 11 applications and had 10 pending (CBI report).
Three months in the directive, 763 days in practice
PSD2 gives the authority three months to decide once the file is complete, or once all the information it asked for has arrived (PSD2 art. 12). The CBI's own average for 2025 was 763 days, and it has risen every year since 2023. Plan salaries, office and capital on the published average, not on the legal deadline.
Ireland chose a 12-month transition period for crypto firms already active before MiCA (ESMA list, MiCA art. 143(3)). Every transition period in the EU ended by 1 July 2026 at the latest, so no crypto firm can rely on one any more.
What the CBI expects from the Irish company
The licence goes to an Irish company with its own board and managers.
A payment institution must be a legal person established in an EU state, with its head office in the state of its registered office and part of its business there (PSD2 art. 11). For an Irish licence, that means an Irish company run from Ireland. A CASP needs its registered office in a member state where it provides part of its services, effective management in the EU and at least one director resident in the EU (MiCA art. 59(2)).
The CBI notes that most PI and EMI applicants are groups that create an Irish subsidiary to passport their services across the EU (CBI report). A founder from outside the EU goes through the same route, with the people below in place.
Executive, non-executive and independent directors
The applicant has to show appropriate substance in Ireland. The CBI expects a board that combines executive directors, non-executive directors and independent non-executive directors (CBI expectations for PI and EMI authorisation).
PCF roles, chair and chief executive
Pre-approval controlled functions (PCF) are subject to the CBI's approval. The CBI expects the chair and the chief executive to be appointed early in the process (CBI expectations).
This guidance dates from April 2024. Before you recruit around it, check with the CBI or a licensed adviser that it has not been replaced.
Safeguarding and initial capital
Who controls the client accounts, and how much capital the company holds.
The CBI expects the power to approve safeguarding accounts, where customer funds are held, to stay within the Irish entity, and the safeguarding bank to be authorised in the EEA (CBI expectations). If a parent company outside the EU runs your treasury, that approval still has to sit in Ireland.
Minimum capital is set by EU law. A PI needs EUR 20,000 for money remittance alone, EUR 50,000 for payment initiation and EUR 125,000 for the services in points 1 to 5 of the PSD2 annex (PSD2 art. 7). An EMI needs at least EUR 350,000 (EMD2 art. 4). A CASP needs EUR 50,000, EUR 125,000 or EUR 150,000 depending on its class (MiCA art. 67). The legal deadlines and passport rules on this page come from the same EU texts; our comparison of fintech licences across Europe sets Ireland against the other countries.
Using the Irish licence across the EU
The CBI sends your notification to each host country.
One month, then one month
The CBI forwards your notification to the host country within one month of receiving the complete file. The host authority then has one month to assess it (PSD2 art. 28(2)).
10 working days, start by day 15
The CBI transmits your notification within 10 working days. You can start in the host country no later than the 15th calendar day after you notified (MiCA art. 65).
Crypto firms that handle e-money tokens
The CBI report records that 5 CASPs applied for a payment institution licence in the fourth quarter of 2025, ahead of the 1 March 2026 deadline for services on e-money tokens (CBI report). If your service transfers or holds e-money tokens for clients, ask the CBI whether you need a payment licence of your own or a payment provider to work with.
Offering crypto services to Irish clients from outside the EU without a MiCA licence is possible only when the client takes the exclusive initiative. Any solicitation in the EU, by any means and including through a related entity, ends that exemption whatever the contract says (MiCA art. 61).
From plan to passport in Ireland
In the order a newcomer meets them, with the legal deadlines where the law sets one.
Pick the licence
Payment services, e-money issuance and crypto-asset services lead to different licences and capital levels. A crypto firm that will transfer or hold e-money tokens checks at this stage whether it also needs a payment licence.
Set up the Irish company and its board
Head office in Ireland, a board with independent non-executive directors, and a chair and chief executive named early. For a CASP, at least one director resident in the EU.
Capital, safeguarding and PCF approvals
Initial capital at the level of your services, a safeguarding bank authorised in the EEA, and the PCF roles put to the CBI for approval.
Receipt and completeness check
MiCA sets both deadlines for a CASP. For a PI, the three-month clock starts once the file is complete.
Decision
A CASP decision is notified within 5 working days. Plan on the CBI's 2025 averages, 171 days for a CASP and 763 days for a PI or EMI.
Passport notifications
One month plus one month for a PI. For a CASP, 10 working days, with a start by the 15th calendar day.
What official sources do not settle yet
We could not read the CBI's page of service standards, so this page gives no official figure for how fast the CBI acknowledges a file, checks its key information and completes its assessment, or for when it wants the key facts document ahead of a meeting. We have not confirmed in an official source whether the CBI charges an application fee, or which Irish regulation sets the e-money capital requirement. We have not read the EBA letter behind the e-money token deadline, nor the MiCA technical standards on what the file must contain. This page does not cover the lighter national options EU law allows for small payment and e-money firms. PSD3 and the Payment Services Regulation could change the rules: on 25 October 2026 they were close to adoption but not yet voted in plenary or published, so PSD2 and EMD2 still apply (European Parliament). Confirm each point with the Central Bank of Ireland or a licensed adviser in Ireland.
What Balt Partners coordinates
We are based in Riga. We map the Irish steps and bring in a licensed adviser in Ireland for the filing.
Licence map and timeline
The Irish obligations for your planned services: capital, board and PCF roles, safeguarding and passport steps, set against the CBI's published averages, with a source for each point.
The CBI file through a licensed adviser
For the application, the PCF approvals and the passport notifications, we bring in a licensed adviser in Ireland, who handles the filing with the CBI.
Ireland against other countries
If an average of 763 days does not fit your plan, we compare authority, timing and substance with the other countries in our guide to fintech licences in Europe.
A Latvian company for non-regulated work
If your group also needs an EU company for work outside the licensed activity, such as development or support, we form a Latvian SIA with its bank account and accounting set-up. See how a foreign company opens a Latvian subsidiary.
Questions from non-EU founders about Ireland
The Central Bank of Ireland reports an average of 763 days for payment and e-money authorisations in 2025, against 688 days in 2024 and 614 days in 2023. EU law gives the authority three months to decide once the file is complete, so plan on the published average.
In 2025 the Central Bank of Ireland authorised 10 crypto-asset service providers, with an average processing time of 171 days. MiCA sets 25 working days to check that the file is complete and 40 working days to decide after that.
Yes, through an Irish company with its head office and part of its business in Ireland. The Central Bank expects substance in Ireland, a board with independent non-executive directors, approved PCF roles and a chair and chief executive named early. A crypto firm also needs effective management in the EU and at least one director resident in the EU.
EU law sets the minimum. A payment institution needs EUR 20,000 for money remittance alone, EUR 50,000 for payment initiation and EUR 125,000 for the services in points 1 to 5 of the PSD2 annex. An e-money institution needs at least EUR 350,000. A crypto-asset service provider needs EUR 50,000, EUR 125,000 or EUR 150,000 depending on its class.
Yes. Most payment and e-money applicants in Ireland are groups that set up an Irish subsidiary for this purpose. For a payment institution, the Central Bank forwards the notification within one month of a complete file and the host country has one month to assess it. For a crypto-asset service provider, it transmits within 10 working days and you can start no later than the 15th calendar day after notifying.
We have not confirmed this in an official source we could read. Ask the Central Bank or a licensed adviser in Ireland before you budget the application, alongside the cost of the board, the staff and the capital.