New Evidential Requirements Of Probity For PCF Candidates In A PI/EMI/AISP

• Published date: 05 December 2025
• Law Firm: William Fry
• Author: Mr Shane Kelleher, Louise McNabola and John O'Connor

On 24 November 2025, following a Consultation on the Fitness and Probity regime (CP160), the Central Bank of Ireland (Central Bank) published revised Guidance on the Standards of Fitness and Probity (the Guidance) (effective 20 November 2025).

For a broader overview of the outcome of CP160 and related documents please see our article here.

The Guidance clarifies the evidential requirements for the Central Bank's assessment of a Pre-approval Controlled Function (PCF) applicant's fitness and probity, when applying for a PCF role in a Payment Institution (PI), Electronic Money Institution (EMI) or Account Information Service Providers (AISP). A Garda Vetting process managed by the Central Bank will now be used as part of the PCF application process for Irish residents applying for such PCF roles.

Although this article focuses on new evidential requirements of probity for PCF candidates in a PI/EMI/AISP, it should be noted that the new Garda Vetting process managed by the Central...