Buy-side acquisition
Buy an EMI in Ireland
Cadena brokers the change-of-control acquisition of authorised Irish Electronic Money Institutions. You take over a Central Bank of Ireland-supervised entity that is already on the register, with banking rails in place and the safeguarding individual approved.
Why an Irish EMI
A scarce passport, not an off-the-shelf one
The Central Bank of Ireland authorises Electronic Money Institutions under the European Communities (Electronic Money) Regulations 2011, as amended, transposing Directive 2009/110/EC and read together with the European Union (Payment Services) Regulations 2018 (PSD2). An authorised Irish EMI passports e-money issuance and the full PSD2 service set across all 27 EU and EEA Member States from a Dublin head office.
The authorised population is small. Roughly two dozen firms hold the licence, and only six PI/EMI authorisations were approved in 2024. Average application processing now sits near 688 calendar days. For an acquirer that needs to be live in the EU and cannot afford to spend the better part of two years in pre-authorisation, the secondary market is not a convenience — it is the route.
Ireland also reads well to acquirers’ boards. Common-law jurisdiction, English-language regulator, deep professional services bench, and a regulator whose reputation for thoroughness shortens the diligence path with downstream banks and card schemes.
What the licence permits
Service scope and statutory architecture
An Irish EMI may issue, distribute and redeem electronic money, and provide the full range of payment services listed in Schedule 1 of the PSR — account services, payment instrument issuing, acquiring of payment transactions, money remittance, and account information services. Services are supplied directly across the Single Market under the EMI passport, with branch and agent notifications routed through the Central Bank.
The statutory minimum initial capital is €350,000. Own funds must be maintained at the higher of that floor or the Method-D calculation under the EMR; the Central Bank revisits the calculation each year and at change-of-control. Safeguarding obligations require segregation of received funds in a designated account at a credit institution, or coverage by a comparable insurance policy, with an annual specific safeguarding audit and a board-approved attestation on control effectiveness.
Any acquisition of a qualifying holding triggers a formal “Proposed Acquisitions of Qualifying Holdings” notification to the Central Bank and a fitness-and-probity assessment of the incoming controllers. From the December 2025 PIEMI Newsletter onward, the safeguarding role itself must be performed by a single named senior individual with prior CBI approval (it can no longer be diffused across compliance, finance and operations).
What we broker here
The acquirer profile that fits an Irish EMI
Cadena introduces buy-side principals to vendors of authorised Irish EMIs. The acquirer profile that closes here is usually a fintech group with existing payments operations elsewhere in Europe or a non-EEA group seeking a clean EU foothold. We do not represent sellers and we do not name targets in marketing.
Three diligence gates determine whether a deal is workable, in this order. First, banking continuity: the safeguarding bank account and any sponsor-bank relationships must survive the change of control, because re-onboarding a freshly-controlled entity in Dublin is the slowest part of a recovery. Second, the AML programme and the named MLRO — both will be re-tested by the Central Bank under the new individual-accountability framework. Third, FTE retention, particularly the safeguarding individual and the head of compliance; their CBI approvals are entity-specific, and replacing them resets the clock on a number of supervisory expectations.
Non-EEA acquirers should also factor in the Screening of Third Country Transactions Act, which can subject foreign acquisitions of regulated Irish firms to a separate ministerial review. We surface the screening question at term-sheet stage rather than at signing.
Acquisition process
How a Cadena deal moves
Confidential brief from the acquirer, vendor introduction under NDA, structured diligence against the three gates above, SPA negotiation in parallel with the change-of-control filing to the Central Bank, and completion conditional on regulatory clearance. The full sequence is documented on the acquisition process page; the Irish-specific overlays are the qualifying-holdings notification and, for non-EEA buyers, the third-country transactions screening.
Why Cadena
Buy-side only, fintech only, EU + UK only
- One side of the table. We act for acquirers exclusively. No double-end. No vendor-paid retainers that bend the diligence narrative toward closing.
- EMI is a sub-specialism, not a brochure line. Our coverage is the EU 27 plus the UK and the licence families that matter for cross-border payments (EMI, PI, AEMI, API, SEMI and SPI).
- Ireland-specific reading. We track CBI authorisations and supervisory output (the December 2025 PIEMI Newsletter, the 2025 sectoral safeguarding inspection, the new individual-accountability rules) so the diligence question list reflects what the regulator is actually looking at this quarter.
For sibling jurisdictions, see the Lithuanian EMI alternative and the French EMI alternative, or browse the full EU 27 + UK coverage.
FAQ
Acquirer questions
What does obtaining an EMI licence in Ireland involve from the acquirer side?
From the acquirer side the work is concentrated in two streams. The first is commercial diligence on the target — banking relationships, customer book quality, safeguarding history, audit trail, AML file. The second is the Central Bank workstream: a “Proposed Acquisition of a Qualifying Holding” notification, fit-and-proper questionnaires for the incoming controllers and any new directors, a safeguarding-individual approval if the incumbent is leaving, and updated business plan addenda for the post-change-of-control entity. Both streams run in parallel against the SPA timetable.
How does registering an EMI license in Ireland differ from acquiring one?
Direct authorisation is a de novo Central Bank application: business plan, capital injection of at least €350,000, full governance build-out, individual approvals for all PCFs, safeguarding architecture, and roughly 688 calendar days of average processing in 2024. Acquiring an authorised entity collapses most of that into a change-of-control filing and a fit-and-proper review of the new controllers. The licence itself is already issued; you are stepping into it rather than building it.
Can a non-EEA acquirer obtain an EMI licence in Ireland through acquisition?
Yes, and it is the most common route for non-EEA payments groups that want EU passporting. The Central Bank reviews the qualifying-holding notification on its merits regardless of the acquirer’s domicile, focusing on financial soundness, fit-and-proper standards and group-level governance. Separately, the Screening of Third Country Transactions Act can apply where the acquirer is from outside the EEA and Switzerland and the transaction crosses certain value or sector thresholds. Cadena flags screening exposure at term sheet so it is priced into the timetable, not discovered at signing.
What is the change-of-control approval process for an Irish EMI?
The acquirer files a “Proposed Acquisition of a Qualifying Holding” notification under the EMR / PSR, with an information pack covering the acquirer group, source of funds, governance plan and proposed senior individuals. The Central Bank has a statutory assessment period during which it can request further information and, in practice, will. Completion of the SPA is conditional on the Central Bank issuing its non-objection. Where the acquirer is non-EEA, the third-country transactions screening can run as a parallel ministerial review.
How long do EMI applications and acquisitions take with the CBI?
Direct authorisations averaged 688 calendar days in 2024 — close to two years from a complete application to issue. Acquisitions are materially faster because the licence is already in place; the bottleneck is the change-of-control assessment and the parallel fit-and-proper reviews. We do not quote fixed timelines on this site; a deal-specific estimate emerges once the target is identified and the Central Bank correspondence file is reviewed.
Next step
Acquire an authorised Irish EMI
If your group is ready to look at authorised targets in Ireland, send a one-page brief and we will route it under NDA. We act for acquirers only.
