As part of our series on the Central Bank of Ireland's (CBI) 2026 Regulatory and Supervisory Outlook, we have produced a practical paper examining the Payments and E-Money sector and the areas where supervisory scrutiny is now intensifying.

Mid-year check: are payments and e-money firms delivering on the CBI's heightened expectations for 2026? The paper explores where supervisory focus is now being applied in practice, with a particular focus on:

  • Safeguarding of customer funds
  • Financial crime, AML/CFT and fraud risk
  • Operational and cyber resilience, including DORA
  • Business model viability and wind-down planning
  • Governance, culture and customer outcomes
  •  Regulatory change readiness, including PSD3 and the Payment Services Regulation (PSR)

It also examines what payments and e-money firms must now evidence in practice as supervisory activity intensifies across the sector. Practical actions are included to help firms strengthen safeguarding arrangements, enhance fraud and financial crime controls, improve operational resilience, demonstrate credible wind-down readiness and prepare for upcoming regulatory change.

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Colm Laird
Consulting Partner - Risk and Governance lead
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