Domestic

Financial Services and Pensions Ombudsman (Amendment) Act 2025 (Commencement) Order 2025

On 7 May 2025, Paschal Donohoe, the Minister for Finance, published the commencement order for the enactment of the Financial Service and Pensions Ombudsman (Amendment) Act 2025. The 2025 Act came into operation on 9 May 2025 and amends the Financial Services and Pensions Ombudsman Act 2017 by:

• making provisions regarding the calculation of expenses incurred by the Ombudsman in the performance of their functions
• provides for the appointment of additional persons to act as Ombudsman
• provides for the conduct of investigations
• other consequential amendments

Remarks by Central Bank of Ireland Deputy Governor McMunn at the National Fintech Summit

On 13 May 2025, Deputy Governor of the Central Bank of Ireland (CBI), Mary-Elizabeth McMunn, spoke at the National Fintech Summit about the perspectives of a central bank and regulator on innovation in the financial sector. Deputy Governor noted that the key role of such a public sector organisation is to enable innovation but also to ensure its safe adoption. It was noted that the areas of regulation, authorisation and supervision are key to ensuring the enablement of innovation whilst staying within appropriate guardrails.

Deputy Governor also spoke of recent CBI projects, such as the work on the CBI’s Innovation Hub and Innovation Sandbox Programme. The Innovation Hub has helped the CBI to gain a deeper understanding of financial sector innovation. The theme of last year’s first programme was combatting financial crime.

With regards to crypto, Deputy Governor noted that the inherent risks in crypto-assets have led to the CBI issuing warnings to consumers concerning crypto and expressing scepticism about business models which heavily market, offer and distribute unbacked crypto-assets to retail customers for speculative purposes. Whilst welcoming the provisions of the Markets in Crypto Assets Regulation ((EU) 2023/1114) (MiCAR), Deputy Governor also noted that the provisions will not afford as extensive protections to consumers as those which exist for traditional financial products.

With regards to tokenisation, Deputy Governor mentioned the wide ranging use-cases for tokenisation and noted that the role of the CBI in this area will be:

• from a regulatory perspective, ensuring that there are no unintended regulatory impediments to tokenisation
• to drive and influence change at system level whilst also deepening their knowledge and engagement with innovation

Passing of the Finance (Provision of Access to Cash Infrastructure) Bill 2024

On 13 May 2025, the Finance (Provision of Access to Cash Infrastructure) Bill 2024 (Access to Cash Bill) was passed by the Oireachtas. The Bill seeks to ensure sufficient and effective access to cash infrastructure for individuals and SMEs across Ireland. Under the Bill, sufficient and effective access to cash infrastructure is ensured through the setting of access to cash criteria for the defined regions throughout Ireland.

Cash infrastructure pertains to both ATMs and ‘cash service points’ where cash services and related in-person assistance are provided during normal business hours. The specific access to cash criteria will be set by the Minister for Finance in consultation with the CBI and under the proscribed guidelines. In addition to the access to cash criteria, the Access to Cash Bill also brings ATM operators, including ATM deployers, and cash-in-transit companies within the regulatory remit of the CBI.

On 21 May 2025, the Access to Cash Bill 2024 was signed into law by Uachtarán na hÉireann, welcoming the passage of the Finance (Provision of Access to Cash Infrastructure) Act 2025.

CBI Guidance Note on applications for authorisation under the European Union (Payment Services) Regulations 2018 and the European Communities (Electronic Money) Regulations 2011 (as amended)

On 12 May 2025, the CBI published its guidance note on completing applications for:

• authorisation as a payment institution
• authorisation as an e-money institution
• registration as an account information service provider
• registration as a small electronic money institution under the European Union (Payment Services) Regulations 2018 and/or the European Communities (Electronic Money) Regulations 2011 (as amended)

Guidance note on applying for authorisation under CJA 2010

On 15 May 2025, the CBI published a guidance note in relation to the requirements for applying for authorisation as a trust or company service provider (TCSP) under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021(CJA 2010).

Each potential applicant should assess whether its proposed business model requires authorisation in advance of making an application. Part 4 of the CJA 2010 sets out that any person wishing to carry on the business of a TCSP must obtain the authorisation to do so.

Information as listed in the application form must be provided to the CBI in support of a TCSP application. The application and supporting documentation should be submitted electronically to tcsp@centralbank.ie. Upon condition of approval, the CBI issues formal authorisation by post. Authorisation is valid for three years and applications for renewal should be submitted ten weeks in advance of expiry.

CBI updates guidance on Beneficial Ownership Register of Certain Financial Vehicles

On 28 May 2025, the CBI issued updated 2025 Guidance on the Beneficial Ownership Register of Certain Financial Vehicles. The Beneficial Ownership Register of Certain Financial Vehicles aims to deter money laundering and terrorist financing, with the guidance note seeking to provide transparency to the scope of the register, outlined the processes to the submission of data to the register, and provide information in relation to the use and safeguarding of the data provided. The updated version contains updates to:

• chapter 2 in relation to person code
• chapter 3 updates in relation to legislative framework regarding access to the register under legitimate interest
• chapter 4 updates in relation to access control

CBI Annual Report 2024 and Annual Performance Statement 2024-2025

On 29 May 2025, the CBI published the Annual Report 2024 and Annual Performance Statement 2024-2025. Gabriel Makhlouf, Governor of the CBI, published a blog summarising the 2024 Annual Report & Performance Statement. The key takeaways from the blog were as follows:

• Economic outlook - since 2025, trade policy, policy uncertainty and increased market volatility have led to declining growth projections for the global and domestic economy. Ireland needs to focus on addressing underlying vulnerabilities and enhance our long-term economic resilience throughout this period of uncertainty.
• 2024 achievements - summarising the recently published 2024 Annual Report, some of the key highlights of 2024 included the establishment of a new fitness and probity team, the launch of the Innovation Sandbox, and work on a number of key policy objectives in the area of macro-prudential policy including new measures for liability driven investment funds.
• Challenges - despite losses incurred as a result of monetary policy actions necessary to achieve price stability, our financial position is robust. It is expected that throughout 2025, any losses will be covered by financial buffers, although ultimately this will depend on many factors including ECB monetary policy decisions.

The Governor concluded that the CBI strategy continues to focus on enabling agility, resilience and intelligent-led responses to the profound changes underway within the economy in order to strengthen public trust.

European

ECB Partners with private sector through digital euro innovation platform

On 5 May 2025, the European Central Bank (ECB) announced that it had established an innovation platform to collaborate with 70 chosen market participants in the context of the digital euro project. The innovation platform will simulate the digital euro ecosystem wherein the ECB will provide the technical support and infrastructure for European intermediaries to develop digital payment features and services.

The market participants will join one of two workstreams; ‘pioneers’ who will investigate conditional payments, and ‘visionaries’ who will research new digital euro use cases and how such use cases might address societal challenges. Both workstreams will report back to the ECB with their findings which will be published by the ECB later this year.

ESMA calls on social media companies to tackle unauthorised financial ads

On 28 May 2025, the European Securities and Markets Authority (ESMA) issued letters to X, Meta, TikTok, Alphabet, Telegram, Snap, Amazon, Apple, Google and Reddit. The letters urge these social media platforms to engage proactively in prevention of promoting unauthorised financial services, amidst the increased in online scams. The recent trend sees the spread in advertising of unlawful financial services with the potential to mislead consumers and exploit their trust, causing financial losses.

ESMA hopes that this will build on the recently released statement by the International Organisation of Securities Commissions on combatting online harm and the role of platform providers in tackling online harm and financial misconduct.

The EBA releases final technical package for its 4.1 reporting framework to support compliance assessment of issuers and the Pillar 3 data hub

On 28 May 2025, the European Banking Authority (EBA) released its final package for version 4.1 of its reporting framework. The package provides the standard specifications which include the validation rules, data point model and the XBRL taxonomies. The package aims to support the assessment and identification of significant crypto assets providers.

For more information on these topics please contact any member of A&L Goodbody's Financial Regulation Advisory team.

This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.