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SettleADebt C_IE PASS-01 — Ireland

Independent provider perimeter and authorisation research

Focused research complete subject to identified evidence gaps — not accepted or publication-readyResearch baseline: 22 October 2026, America/Los_Angeles Public-source verification: 26 October 2026 (UTC, Pacific and Ireland local date; exact retrieval times not recorded) Jurisdiction: Republic of Ireland. Northern Ireland is a separate UK jurisdiction and is excluded. Method: Read-only, ordinary public-source browsing in regular Chat. No private provider, person, licence, customer or case lookup; no application, filing, contact, purchase or site publication.

Principal determination

Ireland has a specific debt management firm authorisation regime in Part V of the Central Bank Act 1997, as amended by Part 10 of the Central Bank (Supervision and Enforcement) Act 2013. A person providing debt management services for direct or indirect remuneration to at least one statutory consumer can come within this regime unless a precisely defined excepted-person provision applies. The competent authorising body is the Central Bank of Ireland. The core provisions commenced on 1 August 2013. [C_IE-P01-C001–C005] Law Reform+3

The decisive classification questions are these:

These are classification and authorisation findings, not findings that a particular consumer contract is enforceable, that any provider will achieve a settlement, or that any creditor must accept a reduced amount.

Particularly important 2026 currentness correction

The Consumer Protection Code 2025 took effect on 24 March 2026. Its regulations contain a specific Chapter 12 for debt management firms. The older 2012 Code, still referenced in some historical Central Bank application documents, must not be treated as the current conduct framework. Chapter 12 also expressly distinguishes a firm engaged solely in negotiation for particular conduct-rule purposes; that is not an exemption from the underlying debt-management-firm authorisation definition. Detailed conduct, disclosures, consumer charges and contracts remain reserved for later passes. [C_IE-P01-C032] Central Bank of Ireland+2

The following registers state precisely what was verified, where the evidence stops, and which conclusions remain on hold.

A. Operative perimeter, definitions and commencement

A1. The statutory test

The starting point is Central Bank Act 1997, Part V, section 28(1), as amended in 2013.

A provider is potentially a debt management firm when all four elements exist:

1. A person provides a debt management service.
2. The service is provided to at least one statutory consumer.
3. The person receives remuneration, directly or indirectly.
4. The person does not qualify as an excepted person.

Section 29 then prohibits carrying on the regulated business without the relevant authorisation. It expressly removes excepted persons from treatment as carrying on the business of a debt management firm. [C003–C005, C009–C016, C028; S003–S006] Law Reform+2

The European Commission describes a microenterprise as having fewer than 10 staff and either annual turnover or balance-sheet total not exceeding €2 million. Group and linked-enterprise figures may matter. This Commission page is an official explanatory source; the complete operative Annex to Recommendation 2003/361/EC could not be read directly in this pass. Therefore borderline classifications remain partial. [C005–C007; S005, S008] Law Reform+1

Examples of distinctions that matter:

• A private individual asking about household debts is potentially within the consumer limb.
• A sole trader seeking help solely with business obligations does not automatically qualify through the individual/nonbusiness limb; the microenterprise limb still has to be tested.
• An incorporated microenterprise can potentially satisfy the consumer definition even though it is a business.
• A larger commercial debtor outside both limbs does not qualify as a “consumer” for this particular statutory definition. That is not a conclusion that no other regulation applies.
• For a guarantor, determine whose obligation is being discussed, whether a present debt is owed by that guarantor, their capacity, and whether an applicable consumer or microenterprise limb is satisfied. No automatic guarantor-wide rule was located in section 28. [C005–C007, C042]

A2. Commencement and transition

The 2013 amendment introducing this category is in Central Bank (Supervision and Enforcement) Act 2013, section 59. The operative commencement instrument, S.I. 287/2013, article 2, brought the relevant Act into operation on 1 August 2013; its exception for section 72 is not the debt-management-firm introduction. [C001–C002; S003–S004] Law Reform+1

Section 34D of the 1997 Act provided a historic transition for firms already carrying on that business immediately before commencement and applying within the specified three-month period. The Central Bank could impose conditions or temporarily direct a qualifying transitional applicant not to operate. This is not an application window for new firms in 2026. No historic deadline has been converted into a newly usable current deadline. [C030; S007] Law Reform

Currency qualification: The Law Reform Commission’s revised Central Bank Act 1997 is updated to 1 August 2026; its revised 2013 Act is updated to 7 July 2026. They are administrative consolidations, not guarantees that every later change is captured. Relevant 2026 amendments elsewhere in Part V, including credit servicing, mean that an old copy of the 1997 Act is unsuitable for current classification. [C001; S001–S002] Law Reform+2

B. Actor-by-actor exceptions and adjacent businesses

B1. Complete section 28(1) excepted-person categories

An exception is not established merely by calling an organisation “nonprofit,” “professional,” “regulated,” “independent” or “free.” The following is the statutory list, with the specific evidence needed to test it.

The list is from the current revised section 28 text, read together with section 29(5)(b). The charitable-organisation criteria were checked against Charities Act 2009, s.2; the charity-registration rule was separately checked at s.39. [S005–S006, S009–S010] Law Reform+4

B2. Adjacent activities that must not be conflated

[C003–C004, C011–C015, C034–C035, C043; S005, S030, S035–S037] Law Reform+3

The key evidence is who the service is provided to, the actual task, why money or other benefits are received, and which legal person performs it. A third party paying the provider does not necessarily eliminate remuneration; conversely, receiving money solely from a creditor for genuinely creditor-side servicing does not by itself establish a debtor-side DMF relationship.

C. Authorisation and safeguards

C1. Permission decision

For a person within the statutory DMF definition, the relevant gateway is Central Bank of Ireland authorisation to carry on the business of a debt management firm under Part V of the 1997 Act. Sections 30–31 govern applying and grant/refusal. Section 32 makes the resulting permission subject to its conditions, and section 33 requires conditions to be set out in the authorisation or annexes. [C020–C023; S011–S015] Law Reform+3

The available text did not establish a general “appointed representative” substitute, automatic recognition of a foreign debt-management permission, or an ordinary professional-registration-only route for a non-excepted commercial DMF. These routes are therefore not established, rather than declared nonexistent.

A covered applicant must provide the Bank's specified form, information and documents. Section 30(2)(c) refers to an application fee if one is prescribed under section 33K of the Central Bank Act 1942. No current DMF-specific application-fee amount was established from a read operative fee instrument in this pass. [C020; S011]

Section 31 permits refusal on specified grounds, including relevant money-laundering/terrorism-law concerns, inability to fulfil the applicable obligations, and materially false or misleading information. The Bank must follow the statutory proposed-refusal notice and representation process. This is not an automatic entitlement to approval on merely submitting a form. [C021; S012]

C2. Ongoing qualification and protective requirements

[C022–C027, C029, C041, C046–C048; S013–S020, S023–S027, S038] Law Reform+6

The Bank's currently linked DMF standards specify professional indemnity cover of at least €1.25 million per claim and €1.85 million in aggregate for one policy period, plus insurer confirmation before commencing and annually thereafter. These are insurance coverage limits, not an application charge, bank deposit, customer-specific bond, guaranteed recovery fund or maximum consumer compensation. Coverage remains subject to policy terms and underlying liability. [C024; S016, S020] centralbank.ie

The standards require qualifying records to be retained for at least five years from the particular trigger appropriate to the record type. For relevant customer files, that is the later of cessation of service or last customer interaction. Other records have different triggers. The Bank's reporting page says the annual DMF return is due within six months after the firm's relevant financial year-end. No universal calendar filing date is inferred without the individual firm's year-end and requirements. [C026–C027; S019–S020, S027] centralbank.ie+1

C3. Unauthorised activity and adverse outcomes

A person carrying on a covered regulated business without authorisation contravenes section 29(1) and commits the offence in section 29(2). The enacted provision prints different summary and indictment consequences and further penalties for continuing after conviction; the Law Reform Commission notes that historic summary fine amounts are affected by the Fines Act 2010 classification. This report does not turn those provisions into a projected penalty for any hypothetical actor. [C028; S006] Law Reform+1

Authorisation can be revoked on enumerated statutory grounds, including certain sustained inactivity, false representations, serious breaches, fitness or supervisory problems, subject to statutory process. Section 35 separately addresses failure by an authorised person to observe Part V, conditions and regulations. An officer of a corporate offender has a distinct potential criminal-liability rule with statutory defences under s.36K. [C029; S017–S018, S039] Law Reform+2

Important consequence boundary: These are regulatory and criminal rules. Nothing read here establishes that a DMF violation automatically cancels the underlying creditor debt, releases collateral, voids a judgment, or creates a particular private damages remedy. Private and regulatory redress analysis is deferred.

C4. Two quantitative agency-levy examples

The Central Bank's August 2026 Funding Strategy and Guide, section 4.3, Table 6 (printed p.14; zero-based PDF page 13), places authorised DMFs in industry-funding Category C. It states:

• Minimum levy: €1,198.
• Variable formula: (A − B) × C, with B = €205,000 and C = 0.21%.
• A is income from fees plus commissions shown in the specified return for the year ended 31 December 2024, or the most recently received preceding return.
• Amounts are before deducting commissions payable to third parties.
• The guide describes the 2026 billing cycle recovering 2025 supervisory costs, not a charge for a consumer's debt-management contract.
• Newly authorised firms not yet required to file a return are assigned the stated minimum; failure to return may trigger a €4,500 default assessment that is subsequently replaced on filing.
• Partial-year authorisations may be subject to pro-rating, and multiple authorisations may produce multiple levies. [C036–C037, C040; S034] centralbank.ie+2

The following hypothetical firms are assumed to have held the relevant permission throughout 2025, with one Category C authorisation, a valid relevant return, no pro-rating, other-category levy, waiver or adjustment. Both values are above the threshold, avoiding any unsupported below-threshold treatment.

Example 1 — reported fees and commissions of €250,000

A = €250,000; B = €205,000; rate C = 0.0021

€250,000 − €205,000 = €45,000

€45,000 × 0.0021 = €94.50 variable levy

Illustrative Category C total

€1,292.50

€1,198 minimum + €94.50 variable = €1,292.50Example 2 — reported fees and commissions of €500,000

A = €500,000; B = €205,000; rate C = 0.0021

€500,000 − €205,000 = €295,000

€295,000 × 0.0021 = €619.50 variable levy

Illustrative Category C total

€1,817.50

€1,198 minimum + €619.50 variable = €1,817.50Legal-evidence limitation: The Bank's official calculation guide was read, but the actual text of S.I. 348/2026 could not be opened from the Irish Statute Book or the attempted official alternative. The examples therefore reproduce the regulator's published calculation, not an independently reconciled reading of every clause of the operative instrument. Actual invoices, assessment bases, pro-rating, waivers, appeals and other levies require that instrument and the firm's facts. No consumer fee, insurance premium, debt reduction or customer entitlement is inferred. [C040; S034, S040]

D. Public verification and documentary workflow

The Central Bank provides a public register portal and a register-download index. At the check date, the index advertised a Register of Debt Management Firms as at 22 October 2026. The index also separately listed credit-servicing, payment-institution and other sector registers. No individual entry or named company was searched. [C031; S028–S029] registers.centralbank.ie+1

A consumer's hypothetical, read-only verification sequence is:

1. Identify the contracting legal person. Record its exact corporate or personal legal name, trading name, address and registration identifiers from the proposed agreement or website.
2. Map promised activities. Mark separately: budgeting advice, debt strategy, negotiating, merely introducing, collecting for a creditor, paying creditors, and performing a statutory insolvency function.
3. Map benefits received. Ask what the provider, its affiliates and referring parties receive, from whom, and for which service—even if the first meeting is described as free.
4. Identify the debtor and debt. Determine individual versus business capacity, microenterprise facts, creditor identity, relevant obligation and any guarantor role.
5. Test an asserted exception. Request the charity constitution/registration information, professional-regulator details and proof of incidental work, institutional authorisation, Protocol participation/compliance, appointment, government funding or Insolvency Service authorisation as applicable.
6. If the ordinary DMF gateway applies, compare the precise legal person with the Central Bank's DMF category and ask to inspect the authorisation letter, current conditions, permitted activities, relevant trading names and insurer confirmation.
7. If another activity is claimed, verify that additional permission in its own category rather than treating a DMF entry as permission for payments, lending, servicing or every financial service.
8. Flag mismatches or missing facts for independent regulatory/legal clarification before relying on the claim. A register match alone cannot verify a private agreement or settlement promise.

A public listing establishes neither that a particular service is allowed under its conditions, nor that the website is genuinely operated by that firm, nor that an individual representative has an applicable statutory status. The Central Bank also warns that some EEA financial businesses operate under sector-specific passporting arrangements. That general observation is not proof of a DMF passport. [C018–C019, C031, C035, C038; S021, S028–S030]

No actual consumer agreement, authority letter, professional appointment or insurance policy was supplied or examined.

E. Statutory insolvency and geographic boundary

Ireland's statutory names include Debt Relief Notice (DRN), Debt Settlement Arrangement (DSA), Personal Insolvency Arrangement (PIA) and bankruptcy. They must not be relabelled with UK or US mechanisms. The current 2025 consumer-protection regulations themselves use those names in defining an “insolvency option.” [C032–C033; S032]

The Personal Insolvency Act 2012 separates:

• An approved intermediary, authorised by the Insolvency Service of Ireland under section 47 for the relevant statutory functions.
• An individually authorised personal insolvency practitioner, under section 164. That authorisation is personal, subject to statutory qualification requirements, and section 164(6) expressly says it does not authorise other Central Bank-regulated financial advisory services.

Section 28(1)(f) of the 1997 Act excepts the specified persons while acting in those capacities. A private voluntary settlement consultant cannot become a statutory insolvency practitioner by changing its marketing language. Conversely, a legitimate practitioner acting within the statutory role is not necessarily required to take a separate DMF authorisation for that role. [C014, C033; S005, S035–S036] Law Reform+2

The Central Bank's published DMF standards say authorised debt-management services are to be conducted within the State, and its application guidance states that DMF authorisation is granted to persons established in the State. These are important supervisory statements, but do not comprehensively decide whether every online contact, overseas customer, foreign negotiator or cross-border arrangement amounts to carrying on the regulated activity in Ireland. The legal nexus, other-state permission, particular services and contractual location remain unresolved without more operative material. [C018–C019, C044; S020–S022] centralbank.ie+1

The European credit-servicing framework is a different service and permission category. The Central Bank describes Irish implementation of Directive (EU) 2021/2167 through the 2023 credit-servicing regulations, with a corresponding service-specific passport. That does not create a general EU passport for Irish debt-management-firm work. [C034, C044; S037] Central Bank of Ireland

Worked bounded decisions

The scenarios are hypothetical classifications, not advice to a real provider or a prediction of settlement.

Scenario 1 — “Free” introductory advice followed by a paid service; claimed charity exception

Facts: An Ireland-based organisation offers free first meetings, prepares household-debt discharge plans and negotiates with creditors. A related membership programme charges for continuing assistance. It describes itself as a nonprofit.

Application:

• Advice and negotiation satisfy the activity types. A connected membership charge may satisfy indirect remuneration. [C003–C004]
• The household debtor potentially satisfies the consumer limb. [C005]
• The organisation's nonprofit description does not prove the statutory charity exception. Inspect its legal constitution, charitable purpose, property-distribution restrictions and excluded-body status; test the exact legal person providing the service. [C009, C045]

Conditional result: If statutory charity status is established, the DMF excepted-person branch may apply. If not, and all other elements hold, ordinary Central Bank authorisation is the adverse branch. If no direct or indirect remuneration exists, the DMF remuneration element may fail, but that does not certify every other rule as inapplicable.

Missing: Contracts, beneficial payment flows, charity constitution/registration and full activity records.

Scenario 2 — Collection agency versus debtor-appointed negotiator

Facts: Company A buys an account and uses Company B to seek payments on A's behalf. Company C separately markets debt-discharge negotiations to that same debtor, charging the debtor's employer a service fee.

Application:

• B's genuine creditor-side collection function is not automatically debtor-side DM advice. The credit-servicing gateway needs separate testing. [C034]
• C is negotiating with the debtor's creditors for the debtor, and its employer-funded compensation can still constitute remuneration. [C003–C004]
• The employer's payment does not alone prove C is excepted. [C016]

Conditional result: C may need DMF authorisation; B may need a different servicing authorisation, or fall outside that separate category depending on the precise credit/debt and structure. Neither conclusion determines whether the debt is collectible.

Missing: Ownership and servicing agreements, customer mandate, compensation contracts, loan type and creditor/client identities.

Scenario 3 — Foreign remote adviser targeting an Irish resident

Facts: An adviser established outside Ireland advertises to Irish residents, holds video consultations abroad, sends suggested repayment terms and negotiates by email. It displays a foreign licence.

Application:

• The described activity and potential remuneration satisfy the substantive DMF-type activity test if the recipient is a qualifying consumer. [C003–C005]
• The Bank's standards and guidance impose Irish-place/establishment expectations on its authorised DMFs. [C018–C019]
• A foreign authorisation is not automatically proof that this activity may be provided into Ireland. Nor do the sources read establish a conclusive jurisdictional test for every online interaction. [C044]

Conditional result: Unresolved territorial nexus and permission. Hold any statement that the foreign licence is sufficient or that the arrangement is categorically outside Irish law.

Missing: Country of establishment, actual work locations, targeted market, contracting entity, domestic representation, activity performed in Ireland and the foreign permission's statutory scope.

Scenario 4 — Sole trader, company debt and personal guarantee

Facts: An individual runs a sole-trader business and seeks to renegotiate trade debts. They also guaranteed a separate company loan.

Application:

• Their solely commercial activity does not automatically meet the individual otherwise-than-business limb. [C005]
• Their enterprise could nonetheless be a microenterprise, depending on current headcount, turnover/balance sheet, linked enterprises and calculation period. [C006]
• The guarantee must be analysed as a distinct obligation: whose legally enforceable debt, in what capacity, and whether the service is provided to a statutory consumer. [C042]

Conditional result: Potential coverage if the microenterprise criteria and other DMF elements hold; potentially outside this DMF definition if neither consumer limb applies. No finding is made on the enforceability or amount of the guarantee.

Missing: Accounts, staff and linked-entity data, guarantee deed, demand history, entity identities and actual service mandate.

Scenario 5 — A private “insolvency specialist” versus an authorised statutory practitioner

Facts: A company offers a voluntary settlement plan and says one employee is a personal insolvency practitioner. It also offers to initiate a statutory PIA.

Application:

• Private paid negotiation by the company is tested against the DMF definition and company-level exception, not simply an employee's title. [C003, C014]
• A genuine personally authorised PIP acting as such falls within the narrower statutory exception for that function. [C033]
• The PIP's individual authorisation does not automatically license the company to carry on all private financial advice. [C033]

Conditional result: Separate the statutory mandate from the commercial company's nonstatutory services; test each legal person and permission independently.

Missing: ISI authorisation/appointment documentation, exact engagement parties, scope of work and service agreements.

Scenario 6 — Payment routing with no advice, then service expansion

Facts: A technical platform only sends consumer-instructed payments to creditors. It later adds personalised repayment plans and creditor negotiation.

Application: Pure payment routing does not itself demonstrate the s.28 advice or negotiation elements. The added service may. Payment permission remains a separate inquiry in either state. [C003, C035, C043]

Conditional result: A possible initial non-DMF branch becomes a possible covered DMF branch upon expansion. The platform cannot rely on a DMF authorisation as blanket authority to receive or safeguard money.

Missing: Funds flow, client ownership of funds, payment execution contracts, financial-service permissions, employee scripts and change-of-service date.

Source register — C_IE-P01-S001–S043

Reading convention: Body means relevant operative body text was actually opened and read. Guidance is the regulator's own published interpretation or standard, not an enacted Act merely because it is official. Failed/discovery cannot independently support a material legal proposition. For PDFs, printed page and zero-based PDF index are separated. For HTML, both are N/A.

All open/read dates below are 26 October 2026. A source's publication or consolidation date is distinct from its legal effective date.

Additional bounded discovery gap: an exact-title official search for the 2 August 2012 Protocol found statutory and regulatory references but no fully read operative Protocol with amendments. It is therefore not represented as an opened source or as proof of a particular party's exception. No general judicial case or enforcement decision was necessary to establish the basic statutory test; none was searched, and this makes no claim about the existence or absence of precedents.

Atomic claim register — C_IE-P01-C001–C050

Each claim is limited to Ireland, the actor/capacity and legal period stated or incorporated in its source. “If covered, authorisation required” means only when every statutory DMF element is satisfied and no excepted-person provision applies. It is not a judgment about a real person.

Additional pinpoint for C029: the read Law Reform Commission text of 1997 Act s.36K(1)–(3) is at https://revisedacts.lawreform.ie/eli/1997/act/8/section/36K/revised/en/html, access 26 October 2026, revised status governed by S001, HTML/no PDF page. It provides the corporate-officer offence rule and its knowledge/reasonable-precautions branches. This direct URL is an extension to source S018 for C029, not a separate unregistered unseen authority. Law Reform

Granular coverage register — A–F and geographical boundaries

Here, answered means this focused classification point has a substantive source-backed conclusion at the recorded source currency—not that every live case or later amendment is resolved. Partial means the principal branch is determined but a material predicate or operative authority remains unread. Unresolved is a genuine evidence gap. Excluded_with_reason is intentionally deferred to a separate pass.

A. Operative perimeter and currency

B. Actors and exemptions

C. Authorisation and safeguards

D. Public checks and documentation

E. Insolvency, EU and geography

F. Explicit later passes — not silently answered here

Researcher self-check and evidentiary holds

Material new questions for the next owner

1. Does the full S.I. 348/2026 operative text reproduce the Bank's Category C formula, and what are its exact pro-rata, adjustment, waiver and appeal clauses?
2. Is there a current DMF-specific application charge under section 33K, and is a separate FSPO levy payable with distinct bases?
3. What exact document and amendments comprise the 2 August 2012 mortgage-forbearance Protocol, and how is valid party status determined?
4. How do the original Commission Recommendation's partner/linked-enterprise accounting rules resolve borderline microenterprise applicants?
5. What is the authoritative Irish legal test for a foreign remotely delivered debtor-side advisory service, as distinct from an Irish-authorised firm conducting services outside Ireland?
6. Where a regulated creditor, servicer or PIP also operates a separately branded commercial negotiation business, which legal person and capacity bears each authorisation requirement?
7. Does a provider offering only creditor payments, introductions or software actually remain outside the similar-activity limb once customer scripts and remuneration flows are examined?
8. What later-than-1-August-2026 changes, if any, affect the operative Part V text or delegated requirements?

Evidence-grounded opportunities for SettleADebt

Publication and operational holds

• Hold the annual-levy formula as a final unqualified statement of enacted law until S.I. 348/2026 is directly reopened; publish any interim example only as the Bank guide's illustrative calculation.
• Hold affirmative reliance on the Protocol exception, foreign authorisation, unreviewed microenterprise edge cases, business guarantor classification and every claimed payment-services permission.
• Hold fee, contract, client-money, remedies, debt-product and insolvency-process articles for their specifically enumerated next passes.
• Do not create a named-provider badge, recommend a particular firm, validate its licence or claim that regulated status guarantees creditor cooperation.
• Do not state a personal consumer deadline based on a generic regulatory timeline, or treat a 90-working-day service standard as guaranteed authorisation.
• Do not infer that unauthorised debt-management activity extinguishes the customer's debt or automatically supplies a private remedy.
• Do not import conclusions from Northern Ireland, the rest of the UK, the US, Canada, Australia or any other jurisdiction.

This is a researcher self-check, not independent legal or coordinator review. The coordinator must reopen consequential source provisions, resolve the inaccessible instruments, independently recompute the arithmetic and reconcile every partial/unresolved coverage row before acceptance. It would be inaccurate to call this a completed Ireland country dossier.

Disposition: The focused Irish debt-management perimeter and authorisation component has substantive source-backed findings, with explicit currency, cross-border, professional-exception and levy-instrument gaps. A097/A098 acceptance remains held.

END C_IE PASS-01