IRELAND Law and Practice Contributed by: Niall Esler, Shane Martin, Laura Whitson and Coleen Wegmann, Walkers
AI Act The AI Act entered into force on 1 August 2024, with most of its provisions set to apply two years after this date, although certain exceptions apply. The ban on prohibited AI systems has applied since 2 February 2025. The AI Act establishes a regulatory framework aimed at harmonising rules for AI across the EU. It seeks to regulate providers who market or deploy AI systems within the EU, as well as users of these systems. On 19 November 2025, the European Com - mission released its Digital Omnibus Package, which proposes adding targeted simplification measures to the AI Act’s provisions. Payments In 2023, the European Commission published the pro - posal for a Directive on payment services and elec - tronic money services (PSD3), which will modernise and repeal the revised Payment Services Directive (PSD2) and the revised Electronic Money Directive (EMD2), and a new Payment Services Regulation (EU PSR). In November 2025, the European Parliament and the Council of the EU announced a provisional political agreement on PSD3 and the EU PSR, and it is expected that its provisions will apply by late 2027/ early 2028. The Instant Payments Regulation has a phased imple - mentation schedule extending from January 2025 to July 2027. It aims to ensure that instant euro pay - ments are accessible to both consumers and busi - nesses throughout the EU by amending existing EU payments regulations. Markets integration package On 4 December 2025, the European Commission pro - posed a comprehensive package of measures aimed to simplify the EU regulatory and supervisory land - scape. The legislative package proposes to amend the Markets in Crypto-Assets Regulation (MiCAR) to transfer the authorisation, monitoring and supervi - sion of all CASPs from national competent authori - ties (NCAs) to the European Securities and Markets Authority (ESMA). Regarding tokenisation, the pro - posed Regulation on settlement finality together with proposed amendments to the Central Securities Depository Regulation and the EU DLT Pilot Regula - tion aim to remove regulatory barriers to innovation
related to DLT and to encourage the adoption of new technologies in the financial sector.
2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models
Outside of payments business, which has driven the majority of fintech activity, significant growth has appeared in the CASP sector. Other areas for inno - vation include regtech, insurtech and digital identity. Traditional players are also looking to incorporate new technology such as blockchain and AI into their exist - ing operations, for example through tokenisation ini - tiatives in the asset management space. 2.2 Regulatory Regime Fintech firms must look to the existing regulatory regimes that may be applicable to their business model on a case-by-case basis. Payments In relation to the provision of payment services or the issuance of electronic money, the primary rules to be considered are: • the European Union (Payment Services) Regula - tions 2018 (PSR), which transpose PSD2 into Irish law; and • the European Communities (Electronic Money) Regulations 2011 (EMR), which transpose EMD2 into Irish law. The domestic Irish regime governing money transmis - sion businesses under the Central Bank Act, 1997 (CBA 1997) may be relevant to a money transmission service falling outside the PSR. Banking Challenger banks seeking to undertake “banking busi - ness” or accept deposits from the public require a bank licence under the Central Bank Act, 1971 and will be subject to the Irish implementation of the EU Capital Requirements Directive (as amended) and the directly applicable EU Capital Requirements Regula - tion.
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