CBI Authorisation and Gatekeeping Report for 2025

On 11 June 2026, the Central Bank of Ireland (CBI) published its Authorisation and Gatekeeping Report for 2025 (the Report). The Report sets out the CBI’s authorisation expectations, as well as providing valuable insight into the performance of regulated investment funds and financial services firms during 2025. 

For organisations considering where to establish their European business, the Report offers more than a snapshot of regulatory performance - it provides an important indicator of the efficiency, predictability and maturity of Ireland's regulatory gateways.

The Report was presented during the policy speech delivered by Deputy Governor Mary-Elizabeth McMunn at the Financial Services Leadership Forum hosted by Byrne Wallace Shields LLP, in association with BDO and Financial Services Ireland (Ibec), at which Deputy Governor McMunn spoke about the CBI’s progress on gatekeeping and its simplification agenda (Policy Speech). 

Positive Outlook for Ireland 

The Report’s numbers tell an encouraging story – showing that during 2025:

• The CBI approved 198 firm authorisations across the relevant sectors and 934 investment fund authorisations.
• 99.9% of Irish authorisation applications were completed within the CBI's target service standards.
• The average authorisation timeframes compare favourably with many other European jurisdictions, for:
  • investment funds (91 calendar days);
    • QIAIF and Professional European Long-term Investment Funds applications (1 business day);
  • Crypto Asset Service Providers (171 days),
  • Retail Credit Firms/Credit Service Firms (76 days); and
  • MiFID investment firms (245 days).

Applications supported by complete and high-quality submissions progressed significantly more efficiently than those requiring substantial additional information.

The Report also identifies continued improvements in authorisation performance compared with 2024, with average processing times improving by 42%.

Taken together, these figures reinforce Ireland's position as one of Europe's leading jurisdictions for establishing regulated financial services businesses.

Speed matters - but certainty matters more

For firms entering Europe, authorisation timelines are naturally an important commercial consideration. Equally important, however, is the confidence that comes from engaging with a regulator operating within a transparent, experienced and well-established supervisory framework. Ireland continues to offer:

• an internationally recognised regulatory framework;
• a sophisticated ecosystem of legal, tax and professional advisers;
• decades of experience supervising globally significant financial institutions;
• deep expertise across investment funds, banking, payments, insurance, asset management and fintech; and
• full access to the European Single Market through established passporting regimes.

The Report's findings reinforce the attractiveness of that proposition. 

The Report also provides clarity on the CBI’s key authorisation expectations for financial services firms, with the CBI identifying that applicant firms are expected to:

• demonstrate that they have sufficient substance in Ireland (this includes not only a meaningful and substantive presence in Ireland, but also that the management of key risks and the making of key decisions by those within the entity take place in Ireland and not elsewhere in a group);
• demonstrate that they have the responsibility and capability to fully manage any outsourced activities and are compliant with the relevant guidance;
• have adequate and sufficient frameworks in place to assess compliance risks and to monitor the adequacy and effectiveness of their compliance monitoring processes as well as on-going compliance with relevant legal and regulatory obligations; and
• where applicable, evidence suitable arrangements to safeguard customers’ funds - an area highlighted as being of paramount importance to the CBI. 

Preparation remains the key differentiator

One of the strongest messages emerging from the Report is that successful authorisations are built long before an application is formally submitted.

The CBI notes that applications supported by clear governance structures, robust business plans and complete documentation progressed more efficiently through the authorisation process. This reflects the experience of many market participants: careful preparation, early project planning and constructive regulatory engagement remain the foundations of a successful authorisation.

For firms establishing in Ireland, investing time in preparation can make a meaningful difference to both the quality and predictability of the overall application process. The Report also highlights that the most successful applicant firms tend to demonstrate certain characteristics, including:

• Transparency - early and meaningful engagement with the CBI, including timely responses throughout the authorisation.
• Openness and a willingness to reflect on CBI feedback.
• Good culture, vision, values and strong “tone from the top”.
• Clear articulation of the proposed business model and rationale for authorisation for specific activities or services provided. Not making fundamental changes to the business model mid-stream.
• Strong governance and local risk frameworks as opposed to an overreliance on group risk frameworks.
• Compliance with regulatory capital requirements and financial viability/resilience.
• Strong commitment to the jurisdiction and substantive presence.
• Incorporation of strong consumer protection measures and adopting a client-centric approach.
• Emphasis on the importance of safeguarding client assets (if this is a feature of the business model).

Fitness and Probity

2025 saw comparable volumes of PCF assessment applications received and approved compared to 2024. 97% of F&P assessments were completed within 90 days, with a 50-day average for PCF approvals being issued across all PCF applications.

Only one application (for two authorisation types) was refused in 2025, as the sole proposed Pre Approval Controlled Function (PCF) role holder did not demonstrate that he met the F&P requirements.

43% of all PCF applications made to the CBI came from the investment funds sector, again highlighting the continued strength of this industry.

A positive signal for international firms

As firms continue to review their European operating models and consider new market opportunities, the Report provides another positive signal for those evaluating Ireland as a location from which to serve European clients.

Whether establishing an investment fund, management company, investment firm, payment institution, electronic money institution or other regulated financial services business, organisations benefit from a jurisdiction that combines regulatory credibility with a mature professional services infrastructure and a proven track record of supporting international investment.

The publication of this authorisation data by the CBI brings welcome transparency to the market. For Ireland, the findings reinforce what many international firms already recognise: a well-established, internationally respected jurisdiction that continues to provide an attractive gateway to Europe.

The statistics above are drawn from the CBI’s 2025 Authorisation and Gatekeepers Report. While each application will depend on its individual facts and complexity, the Report provides valuable benchmarking for firms planning to establish regulated operations within the European Union.

Our Investment Funds and Financial Services Regulation team regularly advises promoters, asset managers, banks, payment firms and other regulated businesses on establishing and expanding their European operations from Ireland. For more information, reach out to the team or to Head of Investment Funds and Financial Services Regulation, David Naughton.