Hiring Your First PCFs During Central Bank Authorisation
Building a PCF team for a Central Bank authorisation comes with one constraint worth planning around from day one: there's no temporary route.
No temporary route
"A notification for the appointment of a Temporary Officer will not be accepted as part of an authorisation application where PCF IQ applications must be submitted." (Guidance on the Standards of Fitness and Probity, November 2025, para 2.42)
Every PCF role in the application needs a real, named person with a completed Individual Questionnaire.
Obligations start before authorisation
The Fitness and Probity regime puts obligations on firms, and the guidance is explicit that this includes "firms in the process of application for authorisation" (para 1.3). Firms are expected to carry out due diligence on proposed PCF holders before submitting their applications (para 1.5).
Extra evidence for PIs and EMIs
For payment institutions, e-money institutions and account information service providers, PCF applications must provide additional evidence of reputation, honesty and integrity (para 3.25). In summary:
Applications must provide objective evidence of an absence of criminal convictions, investigations and proceedings.
Irish residents can meet this through a Garda Vetting process managed by the Central Bank as part of the PCF application.
Non-Irish residents can provide an official police certificate from their country of residence, where available, or other objectively reliable evidence, including lawyer testimony.
This evidence is generally considered valid for six months from the date of issue.
Anyone previously assessed by a different regulator must provide the authority's identity, the date of the assessment and evidence of the outcome.
An affidavit from the individual doesn't count. The guidance notes that affidavits sworn by the individual are not objective evidence (para 3.25, footnote 23).
What this means for hiring
Start the PCF search early. Your application depends on having the right people signed up, vetted and documented. People who have been through Central Bank assessment before know what's coming and what they'll need to produce.
Plan the whole team as one project, not one role at a time. Because every role needs a named person, one slow hire can hold up the whole application.
Leaders who have taken a firm through Central Bank authorisation before are among the hardest profiles to find. Related: The Hardest PCF Roles to Fill in Irish FinTech, and How Long They Take
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