Applying for a permission

Payment Service Provider

About

The purpose of this page is to make sure that the application process is fully understood.

This section sets out:

  • What a Payment Service Provider is and what this regulated activity would allow you to do
  • Authorisation Process
  • Capital Requirements
  • Additional Information

What is a Payment Service Provider and what would this regulated activity allow you to do?

The term Payment Service Provider refers to a category of payment services that facilitates or acts as an intermediary in a cash transaction. The authorisation of this regulated activity falls under the scope of the Financial Services Act 2019.

Payment services may consist of:

  • Enabling cash withdrawals;
  • Enabling cash to be placed in a payment account;
  • Credit transfers, including standing order;
  • Issuing payment instruments or acquiring payment transactions; or
  • Money remittance.

Any firm wishing to provide these type of services must be authorised by the GFSC as a Payment Services Provider and is required to comply with certain rules when providing services or completing payment transactions.

As an Authorised Payment Service Provider, firms will be authorised to provide one or more payment services and will be required to comply with all legislative requirements.

A Payment Service Provider can apply for one of the below three classes of permissions, depending on the services to be provided:

Class AClass BClass C
6. Money remittance.

7. Payment initiation services.

8. Account information services.

1. Services enabling cash to be placed on a payment account as well as all the operations required for operating a payment account.

2. Services enabling cash withdrawals from a payment account as well as all the operations required for operating a payment account.

3. Execution of payment transactions, including transfers of funds on a payment account with the user’s payment service provider or with another payment service provider:

a. Execution of direct debits, including one-off direct debits.

b. Execution of payment transactions through a payment card or a similar device.

c. Execution of credit transfers, including standing orders.

4. Execution of payment transactions where the funds are covered by a credit line for a payment service user:

a. Execution of direct debits, including one-off direct debits.

b. Execution of payment transactions through a payment card or a similar device.

c. Execution of credit transfers, including standing orders.

5. Issuing and/or acquiring payment services.

If an applicant requests an authorisation for a range of services that falls within two different classes of permissions, then the applicant should select the class of permissions with the highest capital requirement. For example, we expect a firm wishing to conduct service 6 and 7 to request a Class B permission; a firm wanting to conduct service 6 and 4 to request a Class C permission. This means that a firm is only able to hold one class of payment services permission.

Agents

A Payment Service Provider may appoint agents. Agents provide payment services on behalf of the Payment Service Provider. These must register with the GFSC.

Credit Institutions / Electronic Money Issuers

Authorised Credit Institutions or Electronic Money Issuers are not required to apply for a separate payment service permission. These institutions will however need permission to ensure they carry on payment services under their authorisation and that they comply with the relevant payment services requirements.

 

Application Process

Following successful completion of the pre-application process, applicants should submit an application in line with the Staged Application for Authorisation Approach.

Initially, the applicant will only submit the Stage 1 application information - it is important that only Stage 1 information is provided at the outset of the application process.

The GFSC will communicate to the applicant that the application can progress to the next stage once the GFSC is satisfied with the content provided at the current stage. The applicant will then be invited to submit the further information required at the next stage of the application process.

Please request cloud access from the GFSC to submit the information requested, via e-mail to [email protected], stating in the subject field: ‘Name of Applicant – Application’.  Paper copies are not required unless indicated by the team.

Please note that we accept signed signature copies sent via e-mail and electronic signatures, which must originate from the Regulated Firm /Applicant’s domain.  

Stage 1 - Business Model, Capital & Key Individuals

The following is to be submitted for Stage 1: 

On receipt of the application fee and Stage 1 documents, the GFSC will confirm the GFSC Supervisor who has been assigned to assess the application for authorisation.

Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 1 will be communicated to the applicant during Stage 1.

When the GFSC is satisfied with all the responses and information/documentation received, the GFSC will inform the applicant that its application can progress to Stage 2.  

Stage 2 - Risk Management, IT Systems, Corporate Governance & Financial Crime

The following is to be submitted for Stage 2: 

  • Stage 2 of the General Comprehensive Business Plan (not including Stage 3);
  • Documentation and information including, but not limited to:
    • Corporate Governance and control
    • Business Continuity Management Plan
    • IT infrastructure, Cyber and systems including outsourcing arrangements
    • Operational & Outsourcing Risk including material outsourcing arrangements
    • Systems controls & Risk Management
    • Financial Crime controls, compliance with Anti-Money Laundering/Combating the Financing of Terrorism requirements (as applicable)
    • Risk Methodology and framework policy documents
    • Risk Register & controls
    • Disaster Recovery Plan 
    • Updated business plan, if required.

Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 2 will be communicated to the applicant during Stage 2.

When the GFSC is satisfied with all the responses and information/documentation received from an applicant, the GFSC will inform the applicant that its application can progress to Stage 3.

Stage 3 - Conduct of Business, Non-Financial Resource, Policies & Procedures

The following is to be submitted for Stage 3: 

  • Stage 3 of the General Comprehensive Business Plan;
  • Documentation and information including, but not limited to:
    • Non-financial resources
    • Compliance structure
    • Conduct of Business (Full Conduct Risk Framework documents)
    • Detail of KPIs
    • Consumer Duty compliance (as applicable)
    • Operational Resilience compliance (as applicable)
    • Remuneration Policy 
    • Conflict of Interest Policy
    • Conflict of Interest Register
    • Liquidity/solvency policies 
    • Internal Audit Plan 
    • Complaints Handling Policy 
    • Terms of Reference of the Board, Board sub-committees, Risk Committee and/or Audit Committee, Underwriting/Pricing committees, as applicable 
    • Audit, accounting, and banking arrangements 
    • Professional Indemnity Insurance 
    • Contracts with parties to whom material operational functions are outsourced 
    • Completed and signed Regulated Individual Forms and Non-Executive Director Forms
    • Mobilisation Plan (if applicable).

When the GFSC is satisfied with the Stage 3 responses and information, the application will move to a GFSC decision for authorisation. 

Additional Services

Regulated Firms that are already authorised by the GFSC may apply to extend their permission to provide additional financial or professional services. If you are seeking authorisation for additional services, please contact the Authorisation team in order for us to determine what documents are required for submission.

The below sets out an overview of the expected information requested:

  • Application Fee (if applicable);
  • Revised Business Plan;
  • Financial Projections for the next 3 years, clearly identifying the impact of the additional business:
    • Profit and Loss account
    • Balance Sheet
    • Stress Test on Financial Projections
  • Regulated Individual Form (for any new individual carrying out a Regulated Individual function);
  • Controller Form (for any new Controllers within the structure); and
  • Any other document the applicant considers the GFSC should take into consideration as part of the application.

 The Regulated Firm should consider the following:

  • What new services/permissions it requires;
  • The type of new business/activity;
  • Where the business will be sourced;
  • Resources to deal with the additional business;
  • The impact of the additional business on its capital requirements; and
  • What changes are being effected to its systems and controls.

Capital Requirements

The type of services conducted by the firm determines the capital requirements for a Payment Service Provider and hence the type of licence obtained.

The initial and ongoing minimum capital requirements are:

  • Class A Licence: €20,000
  • Class B Licence: €50,000
  • Class C Licence: €125,000

Details on the different methods of calculating the own fund required can be found in the Payment Services Regulations. An applicant should agree with the GFSC which method of calculating its own funds it should apply before we issue a final approval.

Before being authorised to conduct the proposed activity, regulated firms holding multiple permissions may be required to hold the aggregate of the capital required for each licence, and on an ongoing basis. In these cases, we will consider the level of capital on a case-by-case basis. Applicants should discuss this with the GFSC ahead of their application.