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PSD3 merges the Second E-Money Directive into a new Payment Services Directive. In Ireland, every electronic money institution (EMI) and payment institution authorised by the Central Bank of Ireland will need to show that it meets the new requirements within 27 months of PSD3 entering into force. Those that do are treated as authorised under PSD3 and stay on the register. Those that do not must stop the services concerned when the transition ends.
The Central Bank has not yet published a PSD3 process for existing firms. But it has been clear about what it expects from the sector today, and those expectations line up closely with what PSD3 adds to the authorisation file: safeguarding, wind-down planning, governance and operational resilience. Institutions that close the gaps the Central Bank has already identified will be well placed when the formal process opens. Our PSD3 re-authorisation guide explains the EU-wide process.
Ireland's payments sector is smaller in number than Lithuania's or Malta's, but its firms are larger on average and many serve customers across the EU. The table counts firms with a current Irish home licence on the EBA Central Register at 30 October 2026, from the Buckingham register of licensed EU payment and e-money firms.
| Firms with a home licence in Ireland | Number |
|---|---|
| E-money institutions | 29 |
| Payment institutions | 26 |
| Registered account information firms | 6 |
| Firms passporting into at least one other country | 58 |
Many Irish institutions are EU hubs of global payment, card and fintech groups that moved or expanded in Ireland after Brexit. That shapes PSD3 work in two ways. Group policies and systems often sit outside Ireland, so the file must show how the Irish board oversees them. And because so many Irish firms passport widely, any interruption in authorisation would affect customers in many countries.
| Step | Timing |
|---|---|
| Council adopts its first reading position on PSD3 and the PSR | 29 October 2026 |
| European Parliament approves the texts in plenary | Expected around the end of 2026 |
| Entry into force | 20 days after publication in the Official Journal |
| PSD3 applies through national law; the PSR applies directly | 21 months after entry into force |
| Transition for existing institutions ends | 27 months after entry into force, extendable by up to 3 months in exceptional cases |
Ireland is expected to transpose PSD3 by regulations replacing the European Union (Payment Services) Regulations 2018 and the European Communities (Electronic Money) Regulations 2011. The Payment Services Regulation applies directly, so its conduct, fraud and open banking rules do not depend on Irish legislation.
Ireland has done this before. When PSD2 replaced the first Payment Services Directive, the Central Bank wrote to existing payment and e-money institutions explaining how it would assess them. It sent each firm an amended version of its draft PSD2 application forms, reflecting that the firm was already authorised but otherwise close to a new application. Firms were asked to return the information as soon as practicable, and the Central Bank set itself six months from the transposition date, 13 January 2018 to 13 July 2018, to decide whether each firm complied.
Three lessons carry over. First, the Central Bank treated existing firms as close to new applicants in substance, so a full file was needed. Second, the time between receiving the forms and the decision was short, so firms that had already done the work were at an advantage. Third, firms with open supervisory issues found those issues raised in the assessment. If PSD3 follows the same pattern, the forms could arrive around the time PSD3 applies, with a decision needed within the 27 month window.
The Central Bank's Regulatory and Supervisory Outlook Report 2026 set out its focus for payment and e-money firms. Several points map directly onto PSD3.
| Central Bank finding or priority | PSD3 link |
|---|---|
| No tolerance for shortcomings in safeguarding; a new Head of Safeguarding role from February 2026 | Safeguarding description in the authorisation file; next business day timing for EMIs; concentration risk |
| Many wind-down plans poorly integrated with risk management and lacking clear triggers; thematic review of financial resilience | New winding-up plan in the authorisation file, including return of safeguarded funds |
| Concerns about money laundering and terrorist financing risk assessments; AML inspections and fraud review | AML controls in the file; PSR fraud prevention and refund rules |
| More major outages; DORA checks on registers of information and incident reporting | Governance, ICT and business continuity sections relying on DORA |
| Board composition and governance; use of distributors and agents | Governance arrangements; agent and distributor registration |
The Central Bank also said it would monitor developments on PSD3 and the Payment Services Regulation. Its message is consistent: the areas it is already supervising closely are the areas PSD3 puts into the authorisation file.
Irish firms have faced detailed safeguarding scrutiny for several years, including audits of safeguarding arrangements and remediation programmes. Under PSD3 the rule tightens for EMIs, which lose the five business day allowance. Funds still held at the end of the business day after receipt must be safeguarded. Users must be told how their funds are protected and which insolvency law applies, and institutions must try to avoid holding all customer funds with one bank. Irish institutions should check that the Head of Safeguarding has a documented view of each of these points. Our PSD3 safeguarding rules guide explains the rule.
On wind-down, the Central Bank's findings match what PSD3 asks for. A plan should set measurable triggers linked to the risk appetite, model severe scenarios including the sudden collapse of the parent group, and show step by step how customers will get their money back. Irish firms that are part of larger groups should map which group services are critical and how they would continue during a wind-down. Our PSD3 winding-up plan guide sets out the contents.
The Payment Services Regulation applies directly in Ireland and brings changes that sit alongside re-authorisation. Payment service providers must check that the payee's name matches the account identifier for credit transfers, share fraud information with each other, and in defined cases refund customers who were deceived by someone impersonating their bank. The Central Bank's planned review of fraud controls and the fair treatment of fraud victims makes this a live topic for Irish firms now.
Agents and distributors are a second area. The Central Bank has said it will review how firms use them. Under PSD3, agents must still be registered, and institutions remain fully responsible for what agents do on their behalf. Irish institutions with agent or distributor networks in other countries should check that each one is registered, monitored and covered in the winding-up plan. The agreed texts also tighten the conditions of the commercial agent exclusion, which some platforms rely on, so Irish advisers have recommended that firms check whether current activities still fall outside the licensing perimeter.
Before the formal process begins, an Irish board should be able to answer five questions without notice. Which PSD3 services will we list, and do they match what we do? What did our last safeguarding audit find, and is every finding closed? What are the triggers in our wind-down plan, and when were they last tested? Which group services are critical to us, and how would they continue if the group were in difficulty? And who owns the PSD3 file, with what deadline? Boards that can answer clearly will find the Central Bank's questions easier when they come. Those that cannot have found the gap analysis, which is the right place to find it.
Under PSD3, e-money issuance becomes a listed payment service and an authorisation covers only the services the institution intends to provide. Irish EMIs should check that every service they actually provide, including acquiring, transfers and card issuing linked to e-money accounts, will appear on the PSD3 authorisation. Passport notifications should match. For groups that operate across the EU from Dublin, the passport list is as important as the home licence, because each host country relies on it.
Capital also changes. E-money issuance carries EUR 250,000 of initial capital and the core payment services EUR 150,000, and the amounts add together. Our PSD3 capital requirements guide explains the calculation.
Buckingham Capital Consulting has advised payment and e-money firms since 2013 on licensing, compliance and banking, including Own Solutions' EMI licence from the Central Bank of Ireland and FCA authorisations for Nexpay, Orbital and Hryze. We prepare PSD3 gap analyses and re-authorisation files for Irish institutions, review safeguarding and wind-down arrangements, and support groups whose EU hub is in Ireland. See our Ireland EMI licence and Ireland payment institution licence guides, or contact us to discuss your firm.
They must show the Central Bank of Ireland that they meet PSD3 within 27 months of entry into force. If they do, they are treated as authorised under PSD3.
Not yet. Under PSD2 it sent existing firms tailored application forms and decided within six months of transposition.
A pre-approval controlled function the Central Bank introduced in February 2026 for payment and e-money firms, responsible for safeguarding arrangements.
Many were poorly integrated with risk management and lacked clear triggers. It planned a thematic review of financial resilience.
The European Union (Payment Services) Regulations 2018 and the European Communities (Electronic Money) Regulations 2011 will be replaced by regulations transposing PSD3.
No. It applies directly across the EU from its application date.
Get in touch: +44 7563 115980 (phone and WhatsApp) or [email protected].
This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.
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