The Central Bank's July 2026 newsletter documents its expectations on material business model change, EBA Q&A 6336, CPC 2025 and AML data before it starts testing firms against them. Firms without a Board-approved materiality policy or a completed Q&A 6336 analysis will start that conversation on the back foot.
Finvisor Regulatory Briefing, issued 22 July 2026. Board, CEO and Head of Compliance reading for payment institutions and e-money institutions.
In July 2026 the Central Bank of Ireland published the second issue of its Payments and E-Money Newsletter, building on the February 2026 Regulatory and Supervisory Outlook. The Central Bank is seeing strategic ambition outpacing control environments, regulatory obligations not being treated seriously enough, and inconsistent engagement on material business model changes across the sector.
It has also found that many firms have not assessed the impact of EBA Q&A 6336 on their business models, and it will intensify engagement in the coming months to force the issue. Separately, the second AML Risk Evaluation Questionnaire, covering 2025 data and amended to reflect AMLA technical standards, is due on 9 September 2026.
Our view: the Central Bank is documenting its expectations on material change, consumer protection and AML data before it starts testing firms against them. Firms that cannot evidence a Board-approved materiality policy or a completed Q&A 6336 analysis when contacted will start that conversation on the back foot.
EBA Q&A 6336: complete the impact assessment now. Following its December 2025 communication, the Central Bank has found many firms have not thoroughly assessed the impact on their business models. Engagement will intensify to drive changes and align with European counterparts.
Material change requires prior approval. Under Regulation 18 of the E-Money Regulations and Regulation 27 of the Payment Services Regulations, firms must notify proposed material business model changes in advance and may not proceed until approved. Notify at the earliest possible opportunity.
Materiality is the Board's to define, and to evidence. The legislation does not define materiality. Each Board must document firm-specific criteria in an approved, regularly reviewed policy. Non-material decisions must be documented too; the Central Bank may test samples during supervision.
Notifications need a Board-signed risk assessment covering, at minimum, safeguarding, AML/CFT, operational and IT, and consumer risk, with evidence that capital, liquidity, resilience and staffing support the change, plus execution timelines.
CPC 2025 is live, and B2B firms are not exempt. The revised Consumer Protection Code has applied since 24 March 2026. The consumer definition captures incorporated bodies with turnover of €5m or less, so B2B firms may have in-scope customers. The Standards for Business regulations apply to all firms regardless of model.
Complaints handling is under thematic scrutiny. A cross-sectoral thematic review examined customer experience through the lens of complaints, and the Central Bank continues to see service quality below expectations. Findings and expectations publish in H2 2026.
Board. Have we approved a documented materiality policy for business model changes, and when was it last reviewed? Are changes we deemed non-material documented well enough to withstand sample testing? Has the impact of EBA Q&A 6336 on our business model been assessed, documented and reported to us? Does our control environment show it is evolving with our growth ambitions, or would the Central Bank see ambition outpacing controls?
CEO. Do any initiatives on our 2026/27 roadmap (new products, agents, distributors, projections above the authorisation plan) trigger prior approval? Have we re-verified which of our business customers fall within the CPC 2025 consumer definition? Can we produce a Board-signed risk assessment for our next material change? Is someone accountable for the 9 September REQ submission, with the 2025 data they need?
Head of Compliance. Have the 5 June 2026 changes to the REQ been mapped against our data capture, with gaps closed before 9 September? Has an AMLR gap analysis started ahead of July 2027, covering CDD, PEPs, outsourcing, de-risking, sanctions and virtual IBAN identification? Will our complaints framework stand up against the thematic findings publishing in H2 2026? Are we tracking the AMLA consultations we should respond to?
We produce Board-ready materiality policies, change assessment templates and the risk assessment pack the Central Bank expects with a notification; structured EBA Q&A 6336 impact assessments documented for Board sign-off; REQ data readiness for the September submission and AMLR gap analysis ahead of July 2027; and CPC 2025 customer classification, Standards for Business implementation and complaints framework review ahead of the H2 thematic. See how we support payment and e-money firms or email info@finvisor.global.
This briefing reflects Finvisor's interpretation of the Central Bank of Ireland Payments and E-Money Newsletter, Issue 2 (July 2026) and does not constitute legal or regulatory advice.
We use strictly necessary cookies to run this site, and optional analytics cookies (Google Analytics) to understand how it is used. Analytics cookies are only set if you accept them. See our Cookie Policy and Privacy Policy.