AML REQ for Payment & E-money Institutions
The AML REQ is the Central Bank of Ireland’s annual data return on your firm’s money laundering and terrorist financing risk. Customers, products, jurisdictions, controls.
The return must be submitted through the Central Bank Portal using the prescribed XML schema. Only XML submissions are accepted.
Why it matters:
Statutory: Mandatory under your AML/CFT obligations.- Supervisory: The data directly shapes whether the CBI lines you up for a deep-dive inspection.
- Strategic: Feeds into the incoming EU AMLA framework
- Visible: Quality and completeness signal the maturity of your AML programme.
What’s the scope?
Entities in scope
Payment and E-money Institutions regulated by the CBI must each submit their own REQ, with group and branch reporting determined by the institution’s legal structure.
Group & branch reporting
Irish branches should report Irish branch data only, EU parent undertakings must aggregate EEA branch information excluding non-EEA branches, and non-parent group firms should report for the Irish institution only.
Activity covered
The PI/EMI REQ captures data across payment and e-money services, including PSD2 activities, merchant acquiring, remittance, payment accounts, onboarding channels, and transaction monitoring and sanctions controls.
Reporting dates
Standard reference date: 31 December of the preceding calendar year
First submission deadline: 13 February 2026
Reporting frequency
Annual reporting
File format
XML format only, aligned with the prescribed XSD schema and required XML wrapper. The XML file must be validated before upload to the Central Bank Portal.
Key data areas
The PI/EMI REQ requires information across:
- Legal structure and business model
- PSD2 activity and activity comments
- Integrated or partnered crypto-asset services
- Customer segments and customer risk ratings
- High-risk customers and sectors
- Transaction volumes and values
- Merchant acquiring activity
- Money remittance activity
- E-money products and digital accounts
- Prepaid cards and vouchers
- Payment accounts and virtual IBANs
- Currency exchange
- Cash deposits and withdrawals
- Crypto-asset related services, where applicable
- Lending and crowdfunding
- Correspondent relationships
- Funding methods and payment instruments
- BWRA, risk appetite and AML/CFT controls
- Policies, procedures, governance, audit and training
- Compliance with the Fund Transfers Regulation
Reporting considerations to keep in mind
- All questions are mandatory, even where a data point is not applicable
- Non-applicable fields must use the prescribed default values, such as 0, N/A, 2000-01-01 or the required default enumeration
- All values should be reported in euroCustomer risk ratings may be based on the rating as at the reference date, even if the rating changed during the year
- XML submissions must follow the required table structures and strict table ordering
- Incorrect XML structure or table order may result in rejection
- Firms must complete both the “Finalise” and “Sign-Off” steps in the Portal
- Material issues should still be raised through normal supervisory channels, not solely through the REQ
So, what do you need to do?
There are no shortcuts, here is what the CBI requires end-to-end.
Download and review the REQ guidance pack
Download and review the sector-specific REQ pack, including the guidance notes, XML schema and reference files, to understand the reporting requirements in full.
Prepare and map your reporting data
Align internal AML/CFT, customer, product and transaction data to the required REQ fields. Every field is mandatory & has a strict format.
Validate against the XSD schema
Validate the XML file against the Central Bank’s schema and formatting rules to identify structural or mandatory field errors before submission. Excel won’t fly. XML schema only.
Obtain internal sign-off
Complete internal review and approval processes before submission (typically MLRO and board-level).
Upload the return via the Central Bank Portal before 13 Feb 2026
Submit the validated XML file through the Central Bank Portal and resolve any validation issues raised during upload.
Maintain an audit trail
Retain supporting documentation, validation records and reporting evidence to support audit and regulatory review requirements. The CBI will ask.