K.Δ.Π. 245/2026 · In force since 29 May 2026
Can your EMI evidence its governance — today?
The Central Bank applied the full Payment Institutions governance regime to EMIs. It took effect on publication. No transition period.
Case CY-2026-0417 · Audit trail
live
09:14:02
Onboarding flagged — high-risk EDD
09:22:47
Escalated to MLRO
09:41:11
Four-eyes review — J. Andreou / M. Pavlou
10:03:29
Approved with conditions
—
— no record —
—
— no record —
The readiness check
Five questions. Answer honestly.
A supervisor will ask a version of each of these.
Question 1 of 5
0%
Can you produce the complete decision trail behind any high-risk onboarding — who decided, on what evidence, approved by whom, when — within one hour?
What changed
Six articles. One that matters.
Article 5 applies the Payment Institutions governance regime to EMIs by analogy — a far more demanding standard your institution was never scoped against.
Board oversight
Three lines of defence
Enterprise risk framework
ICT & outsourcing risk
Independent compliance & MLRO
Documented internal controls
Deep dive
EMI Governance Readiness — K.Δ.Π. 245/2026 | ComplianceSuite.ai
Read the full analysis of the new regulation, the five questions supervisors ask, and what good governance looks like in practice.
Scenario
The morning the supervisor calls.
Without an evidenced framework
- Compliance rebuilds the trail from four systems
- Four-eyes approvals exist in policy, not in logs
- Board reporting reconstructed from memory and email
- ICT and third-party risk documented in a spreadsheet
- The answer takes three weeks
With ComplianceSuite.ai
- Every decision timestamped, attributed, retrievable in minutes
- Four-eyes enforced in the workflow, logged automatically
- Board dashboard with a live, dated record
- RiskRecon monitoring ICT and third-party risk continuously
- The answer takes an afternoon
How we work
Half governance design. Half operational evidence.
Infocredit Advisory
Committee structures, MLRO independence, policy suite, board reporting.
Regulatory judgement, not software. Decades of Cyprus regulatory practice translating supervisory expectations into board-ready governance design.
ComplianceSuite.ai
17 integrated modules, configurable workflow engine, enforced four-eyes, adaptive risk scoring, board dashboards, Mastercard RiskRecon for ICT and third-party risk.
Replaces 4–6 fragmented tools. Up to 68% less manual workload.*
*Results vary by programme maturity and configuration.
Governance Gap Assessment
Get your gaps mapped.
A structured, no-obligation diagnostic against every obligation under 245/2026 — with a written read of where you stand and what to fix first.
Confidential. Reviewed by senior compliance practitioners at Infocredit Group.