Authorisation Process for Credit Institutions

Authorisation Process for Credit Institutions under Section 9 of the Central Bank Act, 1971 and Third Country Branches under Section 9A of the Central Bank Act, 1971

Legislation

The European Central Bank ('ECB') is the competent authority in Ireland for the granting of banking licences in accordance with Section 9 of the Central Bank Act, 1971 (as amended).

In relation to applications for authorisation under Section 9A of the Central Bank Act, 1971, by relevant credit institutions headquartered in a non-European Economic Area country or territory, referred to as 'Third Country Branches', the Central Bank of Ireland (‘Central Bank’) is the competent authority for granting such authorisations.

Applying for an authorisation

Credit Institutions under Section 9 of the Central Bank Act, 1971

As of 31 January 2022, the ECB submission portal  IMAS portal is to be used for the submission of applications for authorisation under Section 9 of the Central Bank Act, 1971, and also for applications to revoke an existing banking licence which was granted under Section 9 of the Central Bank Act, 1971. Access to the IMAS portal will be arranged following initial engagement with the Central Bank.

A potential applicant should refer to the Central Bank’s Guidelines that provide guidance in relation to the Central Bank’s general requirements and expectations regarding such applications.

Third Country Branches under Section 9A of the Central Bank Act, 1971

Third country branch applicants, should consider proposed EBA requirements for third country branches under the Capital Requirements Directive (EU) 2024/1619 (CRD VI) which include:         

  1. Consultation on draft Guidelines on the sound management of third-party risk

    This Consultation relates to guidelines which focus on third-party arrangements in relation to non-ICT related services provided by third-party service providers and their subcontractors with a particular focus on the provision of critical or important functions. These Guidelines revise and update the previous EBA Guidelines on outsourcing, published in 2019, in line with the Digital Operational Resilience Act (DORA). The consultation period closed on 8 October 2025. Responses received are being considered by the EBA.

  2. Consultation on regulatory products on third-country branches under the Capital Requirements Directive

    This Consultation relates to draft regulatory technical standards (i) specifying the booking arrangements and (ii) on cooperation between competent authorities supervising third country branches and draft guidelines on instruments to meet the capital endowment requirement. The consultation period for these products closed on 10 October 2025. Responses received are being considered by the EBA.         

  3. Consultation on harmonised reporting for third-country branches across the EU

    This Consultation relates to implementing technical standards on harmonising supervisory requirements for third country branches and their head undertakings (uniform formats, definitions and reporting frequencies). The consultation period on these standards closed on 31 October 2025. Responses received are being considered by the EBA.

  4. Consultation on revised guidelines on internal governance under the Capital Requirements Directive 2013/36/EU

    This Consultation relates to guidelines which are being amended to reflect the changes – including on third country branches − introduced by CRD VI. The consultation period on these guidelines closed on 7 November 2025. Responses received are being considered by the EBA.

  5. Consultation on revised Guidelines on supervisory review and evaluation process and supervisory stress testing

    This consultation covers new CRD VI requirements including those related to third country branches. The deadline for responses to this consultation is 26 January 2026.

  6. Consultation on Guidelines on authorisation of third country branches under the Capital Requirements Directive

    This consultation relates to implementation of a new EU framework applicable to third country branches. These Guidelines will contribute to harmonised access to the EU market and consistent application of the framework. The deadline for responses to this consultation is 3 February 2026.

  7. Joint ESMA and EBA Guidelines on the assessment of the suitability of members of the management body and key function holders under Directive 2013/36/EU and Directive 2014/65/EU

The EBA and ESMA issued joint guidelines on the assessment of the suitability of members of the management body and key function holders under Directive 2013/36/EU and Directive 2014/65/EU. These guidelines provide common criteria to assess the following aspects with respect to members of the management body:

  • Time commitment
  • Good repute, honesty, integrity and independence of mind
  • Individual and collective knowledge, skills and experience
  • Induction and training
  • Diversity

The EBA has set out its intention to update these Guidelines within its 2025 Work Programme.

Third country branch applicants should also consider the following existing requirements/guidance:

The Individual Accountability Framework (IAF)

The Central Bank Individual Accountability Framework Act 2023 (the IAF Act) was signed into law on 9 March 2023, partially commenced on 19 April 2023, and was fully commenced on 29 December 2023. The IAF includes the Senior Executive Accountability Regime (SEAR), Conduct Standards and Enhancements to the Current Fitness and Probity (F&P) Regime. Third country branch applicants should pay particular attention to the SEAR and the application of its requirements to third country branches. 

Cross-Industry Guidance on Outsourcing

This Central Bank Guidance was created to supplement existing sectoral legislation, regulations and guidelines on outsourcing, by setting out the Central Bank’s expectations of good practice for the effective management of outsourcing risk.

All licence applications follow a three stage process:

Exploratory Phase

  • The applicant will submit an initial high level proposal
  • Following review, if no significant issues are identified the applicant moves to stage 2

Draft Application

  • The applicant will submit a draft application
  • The majority of the assessment work is completed during this stage
  • The assessment will be conducted by the Central Bank and ECB for section 9 Applications, and the Central Bank for section 9A applications

Application and Decision

  • The applicant will submit an application
  •  A decision will be made on whether to grant authorization
    •  The ECB is the competent authority for the decision on section 9 Applications
    •   The Central Bank is the competent authority for the decision on section 9A Applications

Contact Us

For questions relating to the Credit Institutions authorisation process, or to arrange a preliminary meeting, please contact us at [email protected].