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

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 Bank is required in other contexts including in relation to an Irish resident applying for a PCF role in a Credit Institution.

While the Central Bank had previously required applicants to provide supporting evidence in relation to absence of criminal convictions, investigations and proceedings as part of the PCF application process, the absence of an applicable Garda Vetting process meant that this was typically provided by way of testimony by a lawyer or a third-party investigation.

This new process means that Irish residents will fulfil the requirement to provide objective evidence of an absence of criminal convictions, investigations and proceedings by way of a specific Garda Vetting process. The evidential requirements for non-Irish resident PCF applicants will differ and are outlined below.

Evidence required – Irish residents

Irish residents can meet the evidential requirement through a Garda Vetting process managed by the Central Bank. The substance of this process is now outlined on the Central Bank's website. The vetting is conducted by the National Vetting Bureau (NVB).

The steps involved in the process are as follows:

1. Invitation Form: Together with the individual questionnaire (IQ) submission, an Irish resident applying for a PCF role in a relevant entity will be invited to complete the 'Garda Vetting Invitation Form'. This form will be issued by the Central Bank via secure message. The form must be completed in writing, signed, and submitted via secure message (as scanned copies or photos) with proof of identity to the Central Bank. The message should include the unique IQ reference number and the title 'Garda Vetting documentation'.
2. Following receipt of the completed form and proof of identity, the Central Bank will send the prospective PCF an email with a link inviting them to complete a 'Vetting Application Form' on the Garda eVetting portal.
3. The applicant must promptly complete and submit the Vetting Application Form online.
4. The NVB will respond in time with a 'vetting disclosure' to the Central Bank, while the applicant will also receive an email confirming the processing of their application.
5. The Central Bank will then review the vetting disclosure response and continue to assess the IQ application.

Evidence required – non-Irish residents

As non-Irish residents cannot go through the Garda Vetting process, the Guidance sets out that the requirement may be fulfilled via the provision of an official police certificate from their country of residence (where available), or through other objectively reliable sources, such as through lawyer testimony from any jurisdiction in which the applicant has resided.

Evidence produced to fulfil this requirement is generally considered valid for six months from the date of issue.

Applicants who have been assessed by another financial regulator or regulatory authority

For individuals who have previously undergone an assessment of their reputation, as an acquirer or as a person who directs the business of an institution, by a different financial regulator; and for individuals who have previously been assessed by an authority from a non-financial sector, in accordance with the relevant EBA Guidelines, applications must provide:

1. the identity of that authority;
2. the date of the assessment; and
3. evidence of the outcome of this assessment.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.