Authorised Electronic Money Institution (AEMI) License in Ireland
Ireland is one of the most respected EU jurisdictions for regulated e-money and payment services. An Authorised Electronic Money Institution (AEMI) licence, issued by the Central Bank of Ireland (CBI), allows companies to issue electronic money, manage IBAN accounts, and provide SEPA-based payment services across the entire European Economic Area via passporting — without separate approval in each member state.
The requirements are substantive: €350,000 minimum capital, at least two Ireland-resident directors, and a real compliance footprint in-country. The CBI review process takes 9–14 months in practice, but the outcome is long-term regulatory credibility in one of Europe’s most established financial ecosystems. Ireland also applies a 12.5% corporate tax rate, provided economic substance requirements are maintained.
This page covers Irish AEMI entities currently available for transfer, alongside a full breakdown of eligibility criteria, capital obligations, and post-acquisition compliance expectations.
Legasset assists clients with both ready-made Irish AEMI acquisitions and new licence applications — compliance documentation, CBI liaison, and director appointments included.
Ready to Buy Irish AEMI Licenses
Irish EMI for Sale
Main details:
- Passported to all of the EU.
- EMI applied for the acquiring license Visa and Master Card.
- Safeguarded and business accounts in reputable banks.
- Full scope license with all the permissions.
- Experienced board and senior management team ready to stay.
- All the necessary technological infrastructure – a payment gateway, payment card processing for acquiring and issuing, and Banking-as-a-Platform services.
- Low history, clean records.
Related EU e-money licences available for transfer
Key Takeaways for the Irish AEMI License
- The Irish AEMI license enables full e-money and payment service operations across the EU via passporting, ideal for fintechs scaling beyond a single market.
- Regulatory oversight by the Central Bank of Ireland includes a €350,000 capital minimum, two local directors, and ongoing compliance obligations under PSD2 and AMLD5.
- MiCA will require a separate CASP registration for AEMIs offering crypto services – no grandfathering applies, and the transition deadline is June 30, 2025.
- New applications take 6–9 months under CBI review. Purchasing a ready-made AEMI with clean records can reduce time-to-market significantly.
- Post-licensing duties include audits, transaction monitoring, and periodic regulatory reporting – non-compliance risks include financial penalties or license revocation.
- Legasset assists with both ready-made purchases and new license applications and helps clients prepare for MiCA onboarding, director appointments, and bank setup.
What You Need to Know About the Irish AEMI License
Table of Contents
The Irish AEMI license isn’t just a regulatory label – it’s a fully operational framework for running e-money and payment businesses across the EU. Below, we outline exactly what this license enables, who it suits, and what limitations you should plan for from day one.
What the Irish AEMI License Allows and Who It’s For
An Authorised Electronic Money Institution (AEMI) license issued by the Central Bank of Ireland (CBI) allows a company to issue electronic money, manage client IBAN accounts, and provide payment services such as SEPA transfers, card issuance, and merchant settlement across the European Economic Area (EEA).
This license is designed for regulated payment and fintech firms, including:
- Digital wallet providers
- Cross-border payment processors
- Challenger banks and EMIs
- Payment gateways with B2B or B2C models
The license enables EU passporting, meaning once approved in Ireland, you can operate across all 27 EEA member states without needing separate local approvals.
Key limitations include:
- You cannot offer crypto-asset custody or exchange services under this license without separate CASP authorization under MiCA.
- Irish banking access is limited, and most firms use safeguarding accounts in other EU jurisdictions.
Firms must meet strict CBI expectations on governance, risk management, and AML systems. The license also requires a €350,000 capital base, Irish resident directors, and a real compliance footprint in Ireland.
Regulatory Overview and Legal Framework
The AEMI license is governed by the Electronic Money Directive (EMD2), as transposed into Irish law under S.I. No. 183/2011, and regulated directly by the Central Bank of Ireland. Firms must also comply with PSD2and Irish AML legislation, including the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.
Tax-wise, Ireland applies a 12.5% corporate income tax, with no withholding tax on outbound dividends to treaty countries. However, maintaining this rate requires ongoing economic substance – typically a local office, 2+ employees, and core control functions within Ireland.
MiCA Compliance: Does It Affect Your AEMI?
MiCA does not replace the Irish AEMI license. However, if your business includes crypto custody, exchange, or stablecoin issuance, you’ll need to secure CASP authorization under MiCA by June 30, 2025.
- There is no grandfathering from an AEMI license into CASP status.
- The CBI has not confirmed whether joint authorization (AEMI + CASP) will be streamlined.
- AEMIs with crypto functions should prepare for a parallel application process.
If your services remain fiat-only, MiCA does not apply.
Eligibility Requirements for Obtaining an AEMI License in Ireland
Applying for an Authorised Electronic Money Institution (AEMI) license in Ireland involves more than forming a company and funding it – it requires a full compliance framework tailored to the Central Bank of Ireland’s supervisory standards. Here’s what your business must demonstrate to qualify.
Legal Entity and Ownership Requirements
The applicant must be an incorporated company in Ireland or another EEA jurisdiction with a clear ownership structure. The Central Bank of Ireland requires transparency over ultimate beneficial owners (UBOs) and applies fit and proper tests to shareholders, directors, and key function holders.
The board must include at least two directors residing in Ireland, with proven financial services or compliance experience. Individuals acting as directors must have clean regulatory records, and one typically assumes day-to-day oversight of Irish operations.
Capital and Financial Obligations
The minimum paid-up capital is €350,000, deposited before licensing and unimpaired by losses. This capital must remain available and cannot be used for operating expenses unless approved. If the firm scales significantly, additional safeguarding or liquidity buffers may be required.
Applicants should also budget for:
- Annual CBI supervision fees (variable)
- External audits, often mandatory post-licensing
- Potential PII (professional indemnity insurance) if outsourcing is involved
Substance and Local Presence
Ireland mandates that licensed AEMIs have a physical presence, meaning a local office and genuine control functions performed from Ireland – not outsourced to third-party consultants abroad.
In practice, the Central Bank expects:
- A local AML officer
- Irish-resident directors engaged in day-to-day governance
- Internal compliance capacity, not proxy-only setups
Required Documentation and Process
To initiate an application, firms must prepare:
- A detailed three-year business plan
- Organizational chart and internal control description
- Proof of capital funding
- CVs and regulatory references for directors and key staff
- AML/CFT framework and safeguarding strategy
- UBO disclosures, passport copies, and tax residence proof
Documents often require notarization or certified translation. All materials must be submitted via the CBI’s Portal system and are subject to follow-up queries or interviews.
Approval Timeline, Fees, and Common Pitfalls
While official timelines suggest 6 months, real cases in 2023–2025 average 9 to 14 months. Delays often stem from:
- Incomplete or vague AML policies
- Missing local control functions
- Overreliance on outsourced compliance
- Underqualified directors
Hidden costs include banking setup (which may require cross-border safeguarding accounts), extended legal support during CBI Q&A phases, and recurring compliance audits post-approval.
How Can Legasset's Team Help You?
You can acquire a ready-made AEMI-licensed company in Ireland or apply for a new one. Legasset supports both pathways, including regulatory filings, business plan preparation, director onboarding, and full compliance architecture.
Legasset helps clients structure applications to pass review the first time – advising on everything from capital formation to director onboarding and post-license substance setup. In the next sections, we’ll walk through the full application process step-by-step.
Pros & Cons of Acquiring an AEMI License in Ireland
+ EU-wide passporting with one license. The AEMI license from the Central Bank of Ireland enables access to all 27 EEA markets without needing additional authorizations.
+ Tier-1 regulatory reputation. Ireland’s Central Bank is one of the most respected financial supervisors in the EU – an advantage when onboarding with SEPA schemes, Mastercard, or correspondent banks.
+ Attractive corporate tax rate. Ireland applies a 12.5% corporate tax rate on trading income – provided local substance requirements are met under Irish Revenue guidelines.
+ Wide service coverage. The license permits e-money issuance, card programs, SEPA/IBAN payment accounts, merchant settlement, and direct integration with EU payment rails.
+ Strategic fintech base. Ireland offers a stable common law framework, strong financial talent pool, and full EU market access – ideal for scaling compliant B2B or wallet-driven platforms.
– Long and intensive approval process. In practice, licensing takes 9–14 months – compared to 3–6 months in jurisdictions like Lithuania or Estonia.
– Strict substance and governance criteria. Two Irish-resident directors are mandatory, with decision-making and compliance oversight expected to occur from within Ireland.
– Banking environment is restrictive. Most Irish commercial banks do not onboard newly licensed EMIs. Firms typically secure safeguarding accounts in Lithuania, Belgium, or the Netherlands.
– No crypto service integration. AEMI licensees that offer custody, stablecoins, or exchange functions must obtain separate CASP authorization under MiCA by June 30, 2025 – there is no grandfathering.
– Post-license compliance burden. Annual audits, transaction monitoring, and regular AML reporting to the Central Bank are mandatory. Outsourced-only compliance setups are typically rejected.
How to Get an AEMI License in Ireland
Businesses have two options for entering the Irish payment services market: acquiring a ready-made AEMI-licensed company, or applying for a new AEMI license from scratch. Legasset supports both – handling legal setup, compliance architecture, director onboarding, and post-approval structuring.
A ready-made transfer is faster (typically 6–10 weeks), but regulatory approval of UBO change and compliance revalidation is still required. A new application offers full control but requires significantly more documentation, planning, and time (typically 9–14 months in 2023–2025 cases). Below is the full licensing pathway.
Step-by-Step AEMI Licensing Process in Ireland
- Step 1: Define Corporate Structure and Capital 2–3 weeks if incorporated entities are used
Set up an Irish or EEA-incorporated entity and plan for €350,000 in paid-up share capital, which must be fully deposited before licensing and held unimpaired.
Key Documents: certificate of incorporation, capital confirmation letter, shareholder structure chart.
Estimated Cost: €5,000–€10,000 for setup, legal drafting, and capital verification. - Step 2: Appoint Directors and Compliance Staff 3–5 weeks, assuming candidates are pre-vetted
Ireland requires at least two directors resident in Ireland. One must have day-to-day executive oversight. A local AML/CFT officer is also expected, not outsourced fully.
Key Documents: director CVs, fitness & probity declarations, Irish PPS numbers.
Estimated Cost: €3,000–€6,000/month for director retainer, depending on involvement. - Step 3: Draft and Submit the Business Plan 4–6 weeks to compile, depending on complexity
Prepare a detailed three-year business plan that covers your services, risk strategy, governance model, AML controls, safeguarding approach, and projected financials.
Key Documents: AML policy, safeguarding structure, organization chart, outsourcing register.
Estimated Cost: €8,000–€15,000 for full documentation package. - Step 4: File Application via CBI Portal 6–12 months of review, including back-and-forth Q&A
Submit all documents through the Central Bank of Ireland’s online portal, including notarized shareholder documents, identity proofs, and declarations. Respond to queries or clarifications during the review.
Key Documents: full CBI application form, notarized passports, UBO declarations, risk & compliance annexes.
Estimated Cost: €5,000–€7,500 in legal fees; CBI does not charge a filing fee. - Step 5: Register for VAT & TaxationStep 5: Final CBI Approval and Setup 4–6 weeks post-approval
Upon approval, the company must finalize safeguarding accounts, onboard local audit partners, activate payment infrastructure, and notify CBI of go-live readiness. Since most Irish banks avoid onboarding EMIs, firms commonly establish safeguarding relationships with EU-based fintech institutions such as Banking Circle, ClearBank, LHV (Estonia), or Paytend (Hungary).
Key Documents: safeguarding account contracts, audit engagement letter, IT system report (if applicable).
Estimated Cost: €10,000–€25,000 for infrastructure, banking, and audit onboarding.
Total Timeframe Overview
- Ready-made transfer: 6–10 weeks (post-approval of ownership change)
- New license: 9–14 months (from incorporation to go-live)
- Post-approval onboarding: 1–2 months
Post-Licensing Compliance Obligations for AEMI License in Ireland
Getting licensed is only the beginning – operating as an authorised electronic money institution (AEMI) in Ireland comes with ongoing compliance demands that are closely monitored by the Central Bank of Ireland (CBI). These obligations are not optional. Failing to meet them can lead to penalties, public warnings, or even revocation of the license.
Ireland’s compliance standards are among the most rigorous in the EU. AEMI holders must implement real governance structures, not outsourced facades. This includes regular filings, local oversight, and full alignment with evolving frameworks such as MiCA if crypto services are introduced.
Key Ongoing Compliance Requirements
- AML/KYC monitoring. AEMIs must maintain continuous customer due diligence, monitor transactions for suspicious activity, and file suspicious transaction reports (STRs) with Ireland’s FIU.
- Annual and quarterly reporting. This includes audited financial statements, transaction volume breakdowns, complaints logs, and safeguarding reconciliations submitted to the CBI.
- Tax and accounting compliance. Companies must submit corporate tax returns, maintain real economic presence to qualify for Ireland’s 12.5% rate, and file VAT returns where applicable.
- Change notification. Any changes to directors, shareholders, service scope, outsourcing arrangements, or operational structure must be cleared with the CBI.
- Audit and supervisory reviews. AEMIs undergo routine inspections by the CBI and may be subject to on-site visits, thematic reviews, or data audits.
How Legasset Supports You
Legasset doesn’t stop at licensing. We assist clients with ongoing compliance management, including quarterly reporting packages, director replacement, audit preparation, and restructuring support if service offerings evolve (e.g. crypto integration requiring a CASP license). Our goal is long-term license sustainability – not just regulatory box-checking.
Common Pitfalls and Challenges of Operating Under an AEMI License in Ireland
While Ireland’s AEMI license opens the door to full EU market access and institutional-grade credibility, businesses must be prepared for several operational challenges. These hurdles often arise after approval – when firms shift from compliance planning to live execution.
Key Challenges Businesses Face
- Banking and safeguarding limitations. Most domestic Irish banks refuse to open accounts for newly licensed EMIs, especially if their operations involve crypto. Most licensees must secure safeguarding accounts abroad – usually in Lithuania, Estonia, or with fintech providers like Banking Circle or ClearBank.
- Substance and staffing requirements. The Central Bank of Ireland expects real governance – not token directors. At least two Irish-resident directors are mandatory, with daily management and AML oversight handled locally.
- Compliance costs and audit cycles. Annual audits, quarterly filings, and reporting obligations can quickly add €20,000–€40,000 in ongoing costs. This is often under-communicated during initial license sales.
- MiCA overlap and crypto expansion risk. Adding crypto-related services post-license triggers an entirely new CASP licensing process under MiCA – AEMIs are not grandfathered.
How Legasset Helps You Navigate This
We help clients solve these issues before they become roadblocks – by structuring local operations correctly, placing vetted directors, securing cross-border banking, and preparing crypto-compliant service models. We don’t just sell licenses – we ensure they’re sustainable.
Frequently Asked Questions About Purchasing an AEMI License in Ireland
What does an Irish AEMI license allow us to do?
An authorised electronic money institution (AEMI) license in Ireland allows your company to issue e-money, offer digital wallets, and provide payment services such as money remittance, direct debits, and credit transfers across the EEA. It also enables passporting into other EU states without separate licensing.
Can I purchase a ready-made AEMI license, or must I apply from scratch?
Both are possible. A ready-made licensed entity offers faster entry, typically with infrastructure, directors, and some reporting history already in place. Applying from scratch takes longer – usually 12 months or more – but allows full customization. Legasset supports both routes depending on your operational goals and urgency.
How much capital is required to operate an Irish AEMI?
The Central Bank of Ireland requires a minimum initial capital of €350,000, held as paid-up equity. This amount must be maintained unimpaired at all times. In addition, firms must maintain safeguarding accounts and cover ongoing costs such as compliance staffing, audits, and regulatory filings.
Does the AEMI license cover crypto services?
Not by default. If your firm intends to custody, exchange, or transfer crypto-assets, you will need to apply separately for a CASP license under MiCA, which becomes fully enforced in Ireland from June 30, 2025. AEMIs are not grandfathered into MiCA.
Can non-Irish residents act as directors or shareholders?
Yes, but at least two directors must be Irish residents. These directors must demonstrate real local governance involvement – the Central Bank does not accept passive or nominal appointments. Ultimate Beneficial Owners (UBOs) may be non-resident.
How does Legasset support clients beyond licensing?
We assist with the full compliance journey: placing local directors, securing safeguarding accounts, preparing for CBI audits, and transitioning to MiCA compliance if needed. We also help firms apply for AEMI licenses from scratch, restructure existing entities, or onboard crypto offerings in a compliant way.
Additional Links and Resources for the AEMI License in Ireland
Official guidelines from the Central Bank of Ireland outlining the steps, documents, and legal basis for applying for an AEMI license.
II. Irish Statute Book – European Communities (Electronic Money) Regulations 2011
Full legal text establishing the regulatory framework for electronic money institutions in Ireland, aligned with EU Directive 2009/110/EC.
III. ESMA – MiCA Grandfathering Periods
An up-to-date overview from ESMA on transitional rules and timelines under the Markets in Crypto-Assets Regulation, including deadlines for CASP compliance.
IV. Revenue.ie – Irish Corporation Tax Guidance
Ireland’s official corporate tax portal, offering insights into rates, obligations, and tax treatment for AEMIs and financial institutions operating in Ireland.
