The Department of Finance has launched the National Payments Strategy following its 2023 Public Consultation (read our insights here).  The launch followed promptly after the publication of the ‘Access to Cash’ Bill (read our insights here) which is now before the Houses of the Oireachtas (albeit its progress is likely to be paused for several weeks if a general election is called in the coming days).

As expected, the Strategy seeks to balance two key priorities: the development of Ireland’s payment ecosystem and “vibrant and diverse payments sector”, and the preservation of access to cash to ensure that “those who depend on cash are not left behind.”  The ‘Access to Cash’ Bill is a key deliverable in respect of that second priority, as is the European Commission’s proposed Regulation on the legal tender of euro banknotes and coins which aims to ensure that euro notes and coins remain available to, and are accepted by, all euro-area residents and businesses.  Further progress is expected on that Commission proposal in 2025.

The Strategy is underpinned by four “vision statements” and contains 26 core recommendations / actions to be implemented by 2030 (and, in many cases, well in advance of that date).

The “vision statements” include:

• That the most modern payment features and functionality will be available to Irish consumers, while preserving access to cash for those who need it.
• The continued evolution of the Irish payment ecosystem, so that it keeps pace with its European equivalent.
• The importance of Irish consumers having trust in available payment methods (and reducing the risk of fraud).
• A more transparent Irish payments landscape, with greater insights on trends and use of payment types.

Some particularly notable recommendations / actions include:

• As signposted in the 2023 Public Consultation, that all Government departments and related bodies accept at least one form of electronic payment and cash payments (or facilitate cash payments by a third party) where a public body charges fines / fees or provides goods / services for a charge.
• That all Government departments and agencies engage with those under their remit on the impact of the Commission’s proposed Regulation on the legal tender of euro banknotes and coins at least 6-12 months before it comes into force.
• That the Central Bank of Ireland (CBI) publish a report on the national cash cycle within 4 years of the ‘Access to Cash’ Bill coming into force.
• That the Financial Stability Group’s crisis preparedness subgroup report to the Financial Stability Group by Q1 2026 on any actions needed to enhance system-wide resilience of payment services.
• That the Department of Finance (with CBI input) look at whether the CBI should have liquidation powers in relation to payment firms. Recommendations are to be made to the Minister for Finance by the end of June 2025.
• That, by the end of 2024, the Irish State provides a digital wallet allowing consumers and small businesses to securely authenticate their identity when accessing public services.
• That the Department of Justice legislate for a shared fraud database in 2025.
• A number of actions for an Anti-Fraud Forum (building on, and expanding, the existing cross-sectoral financial crime roundtable run by the Banking & Payments Federation Ireland) designed to combat payment fraud.
• That the Irish Retail Payment Forum set-up an Account-to-Account Working Group, with representatives from banks, payment providers, open banking providers, merchants and others. The forum is to focus on the full adoption of instant payments, identifying and addressing barriers to the full adoption of open banking, and identifying a roadmap towards integration with a European payments solution.  The CBI has also been asked to, in consultation with that working group, develop a proposal for the regular collection and publication of open banking indicators by Q2 2025.
• The CBI has been asked to lead on a payments-related research and insights programme. That programme will carry out surveys of consumer payment preferences and behaviours, carry out research on retail payment methods, look at the environmental impact of payments, progress the roll-out of the open data portal to identify available statistics on payments, look at how the use of payment instruments (particularly instant payments) is evolving in Ireland, collect and publish open banking indicators, and analyse emerging Irish fraud trends in its ‘Behind the Data’ series.

As work gets underway to address the recommendations / actions set out in the Strategy, the revised EU payment services framework is a priority item for the incoming EU Commissioner (see the mission letter for those priorities).  It is hoped that trilogue negotiations between the EU Council and European Parliament will begin in H1 2025.  Combatting payment fraud, levelling the playing field between banks and non-banks, improving the open banking framework and improving the availability of cash are key pillars of that June 2023 Commission proposal.