Payments

The payments sector is undergoing its most significant period of change in a generation. Regulatory reform is accelerating, new entrants are disrupting incumbents, and consumer expectations continue to evolve.

Whether you are a payment institution, e-money institution, bank, or fintech, the challenges you face today demand expert, senior-level advice.

Our team is uniquely positioned to partner with you at every stage of your firm's journey, from authorisation and launch right through to strategic growth and transformation.

We bring together regulatory specialists, risk professionals, technology experts, and product strategists - coordinating the full global reach of KPMG directly into your boardroom.

Shane Garahy

Partner, Risk Consulting

KPMG in Ireland

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The changing landscape:
A sector at an inflection point

The payments industry in Ireland and across Europe is being reshaped by forces that are structural, not cyclical. The rise of non-bank payment service providers, the explosion of real-time payment rails, the emergence of digital currencies, and the rapid evolution of open banking are fundamentally altering how value moves and who captures it.

Ireland's status as a leading European hub for global payments firms means domestic operators are at the centre of this transformation. The competitive dynamics are shifting. Firms that previously relied on established positions are now facing pressure from agile challengers, while new entrants are navigating a regulatory environment of unprecedented complexity.

The window to adapt is narrowing. Firms that move decisively, building robust operational and compliance foundations while investing in product innovation will be best positioned to compete and grow. Those that do not risk being left behind.

A demanding and rapidly evolving regulatory environment

The regulatory framework governing payment and e-money institutions has never been more complex or more consequential. The Central Bank of Ireland's supervisory expectations have intensified significantly, and a wave of EU legislative reform is placing new obligations on every authorised firm operating in the market.

PSD3 and the Payment Services Regulation (PSR) will overhaul the framework that has governed payment services since 2018 - bringing enhanced strong customer authentication requirements, expanded open banking obligations, and tighter rules on liability and consumer protection.

At the same time, the Instant Payments Regulation is requiring firms to offer euro credit transfers in real time, with fee parity obligations and new sanctions screening requirements that challenge existing technology architectures.

The Digital Operational Resilience Act (DORA) is now in force, imposing binding requirements on ICT risk management, third-party oversight, incident reporting, and resilience testing across all financial entities and their critical service providers.

Proposed reforms to the safeguarding regime will raise the bar significantly for how payment and e-money institutions hold and reconcile client funds. And the EU's forthcoming AML Regulation, together with the establishment of the Anti-Money Laundering Authority (AMLA), will introduce harmonised, directly applicable financial crime obligations that demand immediate attention.

The cost of non-compliance is high - in enforcement, in reputational damage, and ultimately in authorisation. We will help you understand what these changes mean for your specific business model and guide you through what needs to be done.

How KPMG can help

A multidisciplinary team, committed to your success

We aim to partner with you at every stage of your firm's evolution. We are committed to investing senior resource into each of our Payments Advisory clients, and we will evolve that relationship as you grow.

From your initial licence application right through to strategic transformation and international expansion, our team is here to provide practical, commercially grounded advice - delivered directly to your senior executive team.

Our Payments Advisory practice is built around five core areas of expertise:

Regulatory & compliance

Navigating the Central Bank of Ireland's authorisation and supervisory process requires deep knowledge and strong relationships. We support payment institutions and e-money institutions through every stage - from licence applications and passporting to ongoing compliance programme design and regulatory gap assessments. As PSD3, the PSR, and the AML Regulation take effect, we will help you understand your obligations, assess your readiness, and implement the changes required.
Payment operations, including safeguarding

Operational excellence is the foundation of a sustainable payments business. We work with firms to design and strengthen the processes, controls, and governance frameworks that underpin reliable, scalable operations. This includes a dedicated focus on safeguarding - helping firms build robust frameworks for the protection of client funds that are fit for the evolving regulatory standard, with strong reconciliation disciplines, governance structures, and Board-level reporting.
Security, risk, privacy & fraud

The threats facing payment firms are growing in sophistication and frequency. Authorised push payment fraud, social engineering, and cyber attacks on payments infrastructure are rising sharply, and regulators are increasingly holding firms accountable for consumer outcomes. We help firms build layered, proportionate defences - across fraud strategy, transaction monitoring, cyber resilience, and data protection - while meeting their obligations under DORA, GDPR, and the shifting fraud liability framework under PSD3.
Payments strategy

Understanding the competitive landscape, identifying the right business model, and building the capabilities to execute - these are the questions that determine whether a payments firm thrives or merely survives. We work with leadership teams to develop clear strategic direction, evaluate new market opportunities, assess build-versus-buy decisions, and design the operating models needed to deliver sustainable growth. Whether you are a new entrant defining your positioning or an established firm facing strategic disruption, we bring the market insight and analytical rigour to help you make the right calls.
Digital product strategy & innovation

The next generation of payments products - instant credit transfers, embedded finance, digital wallets, and open banking-enabled propositions - presents significant opportunity for firms that are ready to move. We partner with product and technology leaders to design, validate, and build innovative payments propositions that are commercially viable and regulatory-ready. From real-time payment rails readiness to Digital Euro impact assessment and API strategy, we help you turn product ambition into reality.

Why KPMG

As one of the largest professional services firms in the world, KPMG brings unmatched global reach combined with deep local expertise in the Irish market. Our Payments Advisory team draws on a unique combination of regulatory knowledge, industry experience, and technology insight - giving you the breadth of advice you need from a single, senior-led team.

We work with a wide range of clients across the payments ecosystem - from domestic fintechs and challenger banks to global card networks and established payment institutions. We understand the commercial realities you face, and we deliver advice that is practical, precise, and directly actionable by your leadership team.