Banking & Credit in Ireland

Key dates

TBD (est. late 2026–2027)

- CBI will integrate the Supplemental Guidance with the Main Guidance on Fitness and Probity Investigations, Suspensions and Prohibitions as part of its wider implementation of a recent High Court judgment relating to F&P enforcement procedures

28 January 2026

- CBI launches Consultation Paper 166 on Supplemental Guidance relating to Prohibition Notices under the Fitness and Probity regime

11 March 2026

- CBI hosts an industry webinar on the Supplemental Guidance on Prohibition Notices under the Fitness and Probity regime

25 March 2026

- CP166 consultation period closes; CBI receives eight submissions from representative bodies and individuals

30 July 2026

- CBI publishes the final Supplemental Guidance on Prohibition Notices under the Fitness and Probity Regime and the Feedback Statement on CP166

Suggested considerations

• Update Fitness and Probity policies, procedures, and governance frameworks to explicitly address the possibility of Prohibition Notices, including criteria for escalation, internal investigation standards, record‑keeping, and engagement protocols with the CBI during prohibition-related processes.
• Ensure Board and senior management, including PCF role holders and HR/legal/compliance leads, are briefed on the new prohibition guidance, the publication policy, and the enhanced transparency of outcomes so that they understand the personal and organisational consequences of F&P failings.
• Strengthen documentation and retention of supervisory, disciplinary, compliance and performance records for CF and PCF holders to ensure that, if a prohibition is contemplated, the firm can provide a coherent, contemporaneous factual record to the CBI and the individual.
• Review and, where necessary, amend individual accountability frameworks (including Statements of Responsibilities and role profiles) to clearly delineate responsibilities, seniority and CF scope, given that these factors now explicitly influence the nature, scope and duration of any prohibition.
• Embed procedures to manage individuals who become subject to proposed or actual Prohibition Notices, including immediate role restrictions, notification workflows, communication protocols to boards and key stakeholders, and contingency planning for business continuity.

What changed

• - The Supplemental Guidance formally sets out the circumstances and general principles the CBI’s Prohibition Decision Maker will consider when deciding whether to impose a Prohibition Notice,...
• The guidance clarifies the decision-making framework for the nature, scope and duration of a prohibition, including whether it applies to specific controlled functions (CFs), parts of CFs, or any...
• The guidance codifies how a Prohibition Notice becomes effective, establishing that effectiveness arises either through a written agreement between the CBI and the individual concerned (prohibition...
• The guidance explains the three mechanisms by which a Prohibition Notice may be terminated or cease to have effect: (1) termination of a prohibition agreement by the CBI, (2) revocation of a...
• The Supplemental Guidance sets out CBI’s approach to requests by prohibited persons to terminate a prohibition agreement, including the factors CBI will assess when considering whether to lift or...

Key dates

End of 2026

- The ECB Governing Council is expected to make the final decision on the new banknote design

23 July 2026

- The Central Bank of Ireland publishes the press release encouraging public participation in the ECB consultation

21 September 2026

- The public survey on the shortlisted euro banknote designs closes

Suggested considerations

• Review the ECB consultation materials and assess whether your firm has any direct operational exposure to future euro banknote changes.
• Monitor ECB and Central Bank of Ireland updates for the final design decision expected around the end of 2026.
• Prepare internal stakeholder briefings for cash operations, branch operations, payments, customer service, and communications teams on the expected euro banknote redesign timeline.
• If your firm accepts or processes cash, begin a preliminary review of any systems, controls, or vendor dependencies that could be affected by future note specifications, authentication features, or rollout timing.
• Update external messaging and FAQs only after the ECB publishes the final banknote design and implementation details.

What changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the themes “European culture” and “Rivers and birds.”
• The ECB has opened an online public survey to gather feedback on the proposed designs.
• The survey is open until 21 September 2026.
• The ECB Governing Council is expected to make the final design decision around the end of 2026.
• The current publication does not impose any immediate compliance obligation on firms; it is a consultation and design-selection step, not an enacted regulatory rule.

Key dates

Late 2026

- Expected Governing Council decision on the final design proposal for the new euro banknote series

Subsequent years (post‑2026)

- Progressive introduction of new‑series euro banknotes into circulation, co‑circulating with existing series which retain value

21 September 2026

- Closure of the ECB public online survey on the ten shortlisted euro banknote design proposals

Suggested considerations

• Establish an internal project workstream to monitor ECB communications on the banknote redesign and plan for operational impacts on cash handling, ATM networks and merchant devices.
• Conduct a preliminary impact assessment of how new banknote security and design features may affect existing banknote sorting, authentication and recycling equipment, and identify likely upgrade or replacement needs.
• Engage with ATM and cash‑handling hardware vendors to understand expected firmware, sensor and software changes required to support the new banknote series and to secure upgrade slots ahead of issuance.
• Review and update internal cash‑handling and banknote authentication procedures, including staff training materials, to incorporate new design and security features once technical specifications are published.
• Plan customer communications strategies to explain the coexistence of old and new series banknotes, reaffirm the continued validity of previous series, and address any fraud or counterfeiting concerns.

What changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the two themes “European culture” and “Rivers and birds”.
• An EU‑wide online public survey has been launched to collect feedback on the shortlisted designs, forming part of the ECB’s inclusive approach to banknote design.
• The ECB’s Governing Council will select a single design proposal around the end of 2026, informed by the Design Contest Jury conclusions, technical assessments and survey results.
• The chosen design will undergo further development and testing before production, including integration of new and improved security features.
• The new series of euro banknotes will be introduced into circulation in subsequent years, alongside existing series, which will retain their legal value and continue to circulate.

Key dates

23 July 2026

- Central Bank of Ireland publishes the warning notice identifying Bates Finance Limited (CLONE) as an unauthorised investment firm and stating its lack of authorisation and cloning behaviour

Suggested considerations

• Monitor the Central Bank of Ireland’s unauthorised firms and warning notices on an ongoing basis and promptly update internal watchlists, sanctions‑style lists, and fraud‑monitoring tools to include Bates Finance Limited (CLONE).
• Update customer‑facing communications, scam warnings, and investor education materials to reference clone firms and instruct clients to verify authorisation using the Central Bank’s Registers before engaging with any investment firm.
• Review and strengthen controls for detecting and responding to clone firm activity, including monitoring for misuse of the firm’s name, logo, Companies Registration Office number, or website domain in Ireland and other jurisdictions.
• Implement procedures to immediately escalate to the Central Bank and law enforcement (e.g. An Garda Síochána) if the firm becomes aware that its identity is being cloned or if clients are approached by Bates Finance Limited (CLONE) or similar unauthorised entities.
• Enhance due‑diligence and onboarding checks to validate counterparties and intermediaries offering investment products into Ireland, ensuring they hold appropriate authorisation from the Central Bank or relevant EU/EEA regulators.

What changed

• - The Central Bank of Ireland has formally identified “Bates Finance Limited (CLONE)” as an unauthorised investment firm / investment business firm and published its details (name, website, email,...
• The warning explicitly states that Bates Finance Limited (CLONE) is not authorised to provide investment services in Ireland and is cloning an authorised firm’s details to pass itself off as...
• The Central Bank confirms that there is no connection between the legitimate authorised firm and the cloned entity using its name.
• The firm’s name is published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reaffirming the Central Bank’s enforcement power to publicly name unauthorised providers.
• The warning reiterates channels for reporting suspected unauthorised firms to the Central Bank (telephone and online reporting), reinforcing expectations that firms and individuals will escalate...

Key dates

22 July 2026 Deadline

– CBI announces the appointment of Josephine Feehily and the commissioning of an independent review of enforcement activities, with a commitment that a report including recommendations will be provided to the Governor and published in due course

TBD (post‑review publication date)

– CBI publication of the external reviewer’s report and recommendations, which will likely act as the starting point for any formal changes to the enforcement framework, processes or guidance

TBD (following CBI response to the report)

– Expected phased implementation of any accepted recommendations through updated policies, procedures, public statements, or, where necessary, legislative or regulatory amendments

Suggested considerations

• Review and document your enforcement‑facing governance, including Board and senior management oversight of investigations, decision‑making on settlement, and escalation paths, to ensure these are robust and can withstand a more structured or time‑bound enforcement approach.
• Assess whether your record‑keeping, data, and management information relating to regulatory breaches, incidents, and CBI interactions are sufficiently complete and organised to support faster and more transparent enforcement processes.
• Conduct a gap analysis of investigation procedures and response playbooks (e.g. dawn raid readiness, information requests, interviews, internal investigations) to ensure they can meet potentially tighter CBI timeliness and information‑quality expectations.
• Update Board and senior management on the launch of the enforcement review and agree a watching brief, including designation of a responsible function (e.g. Compliance or Legal) to monitor the review, its terms of reference, stakeholder engagements and eventual recommendations.
• Engage external counsel or industry associations, as appropriate, to prepare for possible consultation or stakeholder engagement opportunities during the review, including developing key messages on proportionality, timeliness, transparency and coordination with supervision.

What changed

• - The CBI has formally commissioned an independent review of its enforcement activities, covering both how enforcement is structured and how it operates in practice, rather than a narrow thematic or...
• The review mandate expressly covers the performance of enforcement activities and the role of enforcement within the wider supervisory framework, indicating that enforcement may be repositioned...
• The review will examine enforcement structures and processes, including decision‑making governance, which may result in new approval routes, escalation paths, or committee structures for opening,...
• The review will look at case‑selection criteria and processes, suggesting potential future changes to how and why firms or individuals are selected for enforcement action, and possibly the...
• Timeliness of enforcement actions is in scope, which may lead to explicit timelines or service standards for case progression, investigation milestones, and resolution, with potential knock‑on...

Key dates

20 July 2017

- The Prospectus Regulation entered into force at EU level

21 July 2019

- The Prospectus Regulation fully applied, and Ireland’s implementing regulations for the regime came into operation

31 March 2022

- New Irish Central Bank fee regulations for prospectus and related document approvals came into operation

7 March 2024

- The Central Bank’s revised Prospectus Regulatory Framework Q&A was published, updating operational guidance on approval, publication, and passporting matters

11 March 2024

- GEM rule amendments took effect for certain retail debt securities listings, providing related market infrastructure context

Suggested considerations

• Review all prospectus templates, disclosure checklists, and approval workflows against the amended Prospectus Regulation provisions that became fully applicable on 5 June 2026.
• Reassess transaction timetables to ensure the planned filing date allows for the 90 working day or 100 working day CBI review window, plus any needed extension request.
• Submit any request for a one-off 30 working day extension before the original approval period expires, and include the required reference details in the request.
• Confirm whether any current or planned issuance qualifies as an SME transaction, because the approval deadline differs from the standard timetable.
• Update internal sign-off procedures so legal, finance, and compliance teams can demonstrate that prospectus materials are prepared in line with the CBI’s statutory mandate and the amended EU framework.

What changed

• - Regulation (EU) 2024/2809 amends elements of the Prospectus Regulation, and those amendments fully took effect on 5 June 2026.
• The Prospectus Regulation continues to apply as the core EU framework for prospectuses, with the CBI acting as the competent authority in Ireland for approval matters.
• The CBI states that it must decide on a prospectus application within 90 working days of receipt of the initial application, or 100 working days for an SME.
• If the review exceeds the applicable working-day limit, the CBI will cease reviewing the prospectus without approving it and will notify the issuer, offeror, or person seeking admission to trading.
• A one-off extension of 30 working days may be requested before the original 90 working-day period lapses, including for SMEs.

Key dates

10 July 2026

- CBI publishes the warning notice on AGF International Advisors Company Limited (CLONE) and/or Iron-Cap / IRONCAP as an unauthorised investment firm / investment business firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Review and update client‑onboarding procedures to include specific screening for the websites www.iron-cap.com and https://www.iron-cap.io and the email domains associated with Iron-Cap / IRONCAP, flagging and escalating any matches as suspected clone‑firm exposure.
• Update sanctions, fraud, and financial crime screening tools and internal watchlists to include the unauthorised firm identifiers associated with AGF International Advisors Company Limited (CLONE) and Iron-Cap / IRONCAP, ensuring alerts are generated for relevant customer or transaction hits.
• Strengthen fraud‑awareness communications to clients and staff by referencing the CBI’s financial scam materials, emphasising the risks of dealing with unauthorised firms and clone entities, and advising clients to verify firm authorisation before investing.
• Establish or update an internal escalation protocol for suspected clone‑firm activity, ensuring that all such cases are reported promptly to the CBI via the dedicated unauthorised firms reporting channels and, where applicable, to other relevant regulators.

What changed

• - The CBI has formally designated AGF International Advisors Company Limited (CLONE) and/or Iron-Cap / IRONCAP as an unauthorised investment firm / investment business firm and has published its...
• The specific websites www.iron-cap.com and https://www.iron-cap.io (including the French-language path https://www.iron-cap.io/fr/forgot-password/) have been identified as associated with this...
• The email addresses [email protected] and [email protected] have been flagged as being used by the unauthorised entity in connection with the Iron-Cap / IRONCAP investment offering.
• The CBI has reiterated that the clone is not authorised to provide investment services or investment business services in Ireland and has explicitly clarified that there is no connection whatsoever...
• The warning reinforces existing CBI expectations that Irish‑authorised firms and gatekeepers must monitor and respond to clone‑firm activity, including by reporting suspected unauthorised firms...

Key dates

28 April 2023

– CBI previously issued a warning notice regarding a fraudulent entity cloning LGIM Managers (Europe) Limited and offering fake “Legal & General” bond investments, establishing a history of cloning activity around this authorised firm

10 July 2026

– CBI publishes the current warning notice “LGIM Managers (Europe) Limited (CLONE) – Central Bank of Ireland Issues Warning on Unauthorised Firm”, formally identifying the clone, its contact details, and its unauthorised status under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Update customer‑facing fraud warnings, website scam information pages, and client communications to include reference to the CBI warning on the LGIM clone and to explain how clients can verify whether a firm is authorised in Ireland.
• Enhance onboarding and periodic KYC / KYB procedures to include independent verification of counterparties’ authorisation status on the CBI register and cross‑check any claimed partnership with LGIM Managers (Europe) Limited, bunq Bank, or similar institutions.
• Implement or update internal guidance requiring staff to escalate immediately any client queries, introductions, or marketing materials referencing “LGIM Managers (Europe) Limited (CLONE)” or using the listed contact details to the compliance and financial crime teams.
• Conduct a targeted review of recent and ongoing distribution, referral, and introducer arrangements to identify any potential exposure to unauthorised clone entities or intermediaries misusing the LGIM brand or falsely claiming CBI authorisation.
• Train frontline staff, relationship managers, and call‑centre agents on the specific red flags associated with clones of authorised firms, including copied registration details, foreign addresses, and use of generic email domains, and on the process for verifying authorisation with the CBI.

What changed

• - The CBI has formally designated “LGIM Managers (Europe) Limited (CLONE)” as an unauthorised investment firm / investment business firm and published its details on the CBI unauthorised firms list...
• The CBI has explicitly stated that the clone entity is not authorised to operate as an investment firm or investment business firm in Ireland, thereby clarifying that any investment services offered...
• The warning identifies specific contact details associated with the scam, including email addresses [email protected] (now inactive) and [email protected], a purported address at...
• The CBI has confirmed that the clone has copied the name and registration details of the legitimate CBI‑authorised firm LGIM Managers (Europe) Limited (C173733), while emphasising that there is no...
• By publishing the firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, the CBI has activated its statutory regime for public warning notices on unauthorised firms,...

Key dates

26 June 2026

- CBI publishes the warning notice against Loan Empower Solution as an unauthorised retail credit firm and lists the firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Review and update internal unauthorised-firm and scam monitoring procedures to ensure Loan Empower Solution and its identifiers (name, website, address, email, telephone number) are captured in watchlists, fraud rules, and staff guidance.
• Screen recent and ongoing customer transactions and communications for any references to Loan Empower Solution or similar lending scams requesting upfront “loan fees”, and escalate any matches to fraud and compliance teams.
• Update customer-facing communications and website scam warnings to highlight the risk of advance fee fraud in retail credit, referencing the need to check the CBI registers and unauthorised-firms list before engaging with lenders.
• Ensure call centre, branch, and digital support staff are trained to identify and respond to customers approached by unauthorised lenders, including how to advise customers to verify authorisation status on the CBI website and to report suspected scams.
• Incorporate checks against the CBI unauthorised firms search into onboarding, due diligence, and third-party risk management processes for any lending-related partnerships, introducers, or lead generators.

What changed

• - The CBI has added Loan Empower Solution (website: lesolution.eu) to its public list of unauthorised firms and explicitly categorised it as an unauthorised retail credit firm operating without the...
• The CBI has publicly stated that Loan Empower Solution appears to be operating an advance fee fraud model, where upfront payments are requested for credit services that are never provided.
• The CBI has confirmed that the firm is using a purported Irish business address (The Merrion Buildings, 18–20 Merrion Street, Dublin 2, D02 XH98), a non-Irish telephone number, and a specified...
• The firm’s name has been published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reaffirming the CBI’s use of its statutory power to publicly identify entities...
• The CBI has directed the public to its unauthorised firms search and financial scams information pages, implicitly reinforcing expectations that firms promote use of these tools in their consumer...

Key dates

10 December 2025

– CBI publishes its roadmap “Regulating & Supervising Well – a more effective and efficient framework”, committing to a public consultation on a new Regulatory Impact Assessment (RIA) Framework in H1 2026 and outlining a multi‑year programme of regulatory and supervisory reforms from H1 2026 to H1 2028

22 June 2026

– CBI launches the public consultation on its approach to RIA and stakeholder consultation, alongside references to its new supervisory approach and roadmap of regulatory initiatives

H1 2026

– Target window identified in the roadmap for the public consultation on the new RIA Framework; this is now operationalised by the consultation launched on 22 June 2026

TBD (post‑30 September 2026)

– CBI will consider all submissions and publish a feedback statement setting out its finalised approach to RIA and consultation, which will then guide the design of future regulatory initiatives

H2 2026

– Roadmap foresees drafting of revised Corporate Governance Codes for consultation, which are likely to be shaped by, and potentially used to pilot, the new RIA framework and consultation approach once finalised

Suggested considerations

• Conduct an internal review of your firm’s experience with recent CBI consultations (e.g. Consumer Protection Code, governance, outsourcing, AML, reporting) and document challenges, costs, and data gaps that could be addressed through a more robust RIA and consultation framework.
• Prepare and submit a response to the CBI consultation by 30 September 2026, either directly or via relevant industry associations, setting out detailed expectations on how RIA should address compliance costs, operational impacts, proportionality for smaller firms, and implementation lead times.
• Update your regulatory affairs or public policy strategy to explicitly incorporate the emerging CBI RIA framework, including criteria for when to engage, escalation thresholds for high‑impact proposals, and internal approval processes for consultation submissions.
• For Irish‑authorised groups operating cross‑border, align your approach to CBI RIA engagement with EU‑level impact assessment practices (e.g. European Commission and ESAs) to ensure consistency in messaging and evidence on cumulative regulatory burden and competitiveness.
• Monitor subsequent CBI publications (including the forthcoming feedback statement, revised Corporate Governance Codes, and sectoral plans) to identify where the new RIA framework is being applied and to anticipate where the CBI may seek additional data or structured feedback from firms.

What changed

• - The CBI has opened a public consultation on its approach to Regulatory Impact Assessment (RIA), seeking views on how it should weigh evidence, assess costs and impacts, and structure its analysis...
• The consultation also covers the CBI’s approach to stakeholder consultation, including how it engages with industry, civil society, consumer representatives, the public, policymakers, and peer...
• The initiative sits within the CBI’s broader “more effective and efficient regulatory framework” programme, which includes a new supervisory approach and a roadmap of regulatory initiatives,...
• The CBI aims to make regulation clear, coherent and proportionate, explicitly linking rule‑making to protections for consumers, investors, and financial stability, and to the resilience of the...
• The CBI is moving towards a more structured, transparent, and evidence‑based policymaking process, where the rationale for regulatory interventions, the analysis of options, and the assessment of...

Key dates

01 January 2025

– CBI established a dedicated team to investigate and prosecute offences under financial services legislation

2025 (effective date – specific day not stated)

– The modernised Consumer Protection Code came into effect for Irish‑regulated firms

2025 (throughout the year)

– CBI implemented its new supervisory approach centred on four safeguarding outcomes and reorganised into multi‑disciplinary supervisory teams

2025 (theme year)

– CBI’s Innovation Sandbox focused on combatting financial crime, with seven projects selected on information sharing, identity verification and fraud prevention

December 2025

– CBI published “Regulating & Supervising well – a more effective and efficient framework,” detailing its simplified and outcomes‑focused regulatory framework

Suggested considerations

• Map the modernised Consumer Protection Code requirements against existing policies, procedures and customer journeys to identify and remediate gaps, particularly in digital channels, disclosure, sales practices and complaints handling.
• Update vulnerable customer policies, customer‑facing procedures, training materials and systems flags to ensure systematic identification, recording and tailored treatment of consumers in vulnerable circumstances.
• Review mortgage switching processes and documentation to ensure customers receive clear, comparative information on switching options, are not subject to unreasonable barriers or retention tactics, and that conflicts of interest are controlled and documented.
• Conduct a comprehensive review of insurance auto‑renewal practices (including communications, timing, consent mechanisms and pricing) and implement changes to align with the strengthened consumer protection expectations.
• Strengthen fraud and scam prevention frameworks by enhancing customer education, warnings, authentication, monitoring, incident response and redress processes, with particular focus on online and mobile channels.

What changed

• - The modernised Consumer Protection Code entered into effect in 2025, updating the existing Irish conduct framework to reflect digital delivery of financial services and strengthen protections in...
• Requirements on informing consumers effectively were tightened, implying higher expectations on clear, fair, not misleading disclosures across digital and traditional channels, and more robust...
• New or enhanced obligations concerning consumers in vulnerable circumstances now apply, requiring firms to identify, record and respond to vulnerability and to embed vulnerability considerations into...
• Mortgage switching processes are subject to strengthened conduct standards, increasing expectations on how options are presented, how customers are supported to switch, and how potential conflicts or...
• Insurance auto‑renewal practices are now more tightly controlled, requiring clearer pre‑renewal information, active consent and controls to mitigate consumer detriment from inertia or unsuitable...

Key dates

05 June 2026

- CBI publishes the warning notice on FTI Finance Limited (CLONE) as an unauthorised investment firm / investment business firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Screen existing and new customers against the details in the CBI warning and immediately block or enhance review of any relationships, communications, or transactions involving the listed websites or email domains linked to FTI Finance Limited (CLONE).
• Update internal fraud and financial crime watchlists to include the name “FTI Finance Limited (CLONE)” as well as the specific domains and email addresses identified in the CBI notice.
• Enhance customer‑facing verification processes to require staff to confirm the regulatory status of any firm claiming to be FTI Finance Limited against the CBI public register before onboarding, referral, or execution of transactions.
• Review and update client communications, investor education materials, and website FAQs to highlight the risks of clone firms, directing clients to verify authorisation using the CBI register and to consult CBI’s financial scams information.
• Train front‑office, call‑centre, compliance, and fraud‑operations staff on the characteristics of clone investment scams, including this specific case, and embed clear escalation procedures for suspected clone activity.

What changed

• - CBI has formally designated “FTI Finance Limited (CLONE)” as an unauthorised investment firm / investment business firm and published its details on the Central Bank’s unauthorised firms warning...
• The CBI explicitly clarifies that FTI Finance Limited (CLONE) is not authorised to operate as an investment firm or investment business firm in Ireland and therefore cannot legally provide MiFID‑type...
• The warning identifies specific websites associated with the clone entity that must be treated as high‑risk indicators in client and transaction screening: -...
• The warning identifies specific email addresses used by the clone, which should be added to firms’ fraud and sanctions‑style screening lists: - [email protected] -...
• CBI confirms that the scam entity has cloned the details of a CBI‑authorised firm of the same name, underscoring a continuing supervisory focus on clone firm scams and the expectation that regulated...

Key dates

03 June 2026

- CBI publishes the warning notice “HSBC Continental Europe (CLONE) – Central Bank of Ireland Issues Warning on Unauthorised Firm” under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Update internal sanctions / fraud / negative‑news / watchlists to include “HSBC Continental Europe (CLONE)” together with the published website, phone numbers, and email address, and ensure these are blocked or escalated on detection.
• Implement or reinforce procedures to independently verify CBI authorisation numbers and firm details directly against the CBI registers, and ensure staff understand that cloned use of an otherwise valid authorisation number is a red‑flag indicator of fraud.
• Conduct an immediate targeted review of recent and pending client interactions, payments, and investment instructions to identify any exposure to the scam entity or its contact details, and escalate any hits to financial crime and legal teams.
• Deliver targeted staff training and reminders (particularly for front‑office, call‑centre, onboarding, and complaints teams) on clone‑firm typologies, including the use of legitimate authorisation numbers (e.g., CBI00001421) by fraudulent entities.
• Enhance customer‑facing communications, website warnings, and FAQs to highlight current CBI warnings about HSBC‑branded clones and to instruct customers always to verify firm details via the official CBI registers and not via links sent in emails or on unknown websites.

What changed

• - The CBI has formally designated “HSBC Continental Europe (CLONE)” as an unauthorised banker / unauthorised firm and added it to its public unauthorised firms list.
• The CBI has identified and published the specific contact details associated with the scam entity, including the website `https://campaign.eligibility-advisorscorporate.com/`, Irish phone numbers...
• The publication confirms that the fraudulent entity has cloned both the name and details of HSBC Continental Europe and separately cloned the authorisation number CBI00001421, which belongs...
• The CBI expressly states there is no connection between Cowan Insurance Brokers Limited and the fraudulent entity, thereby clarifying that any use of that authorisation number in combination with the...
• The warning reiterates that any unauthorised provision of financial services that requires CBI authorisation is a criminal offence, reinforcing the enforcement stance seen across prior clone‑HSBC...

Key dates

03 June 2026

- CBI issues and publishes the warning notice identifying Insight Investment Solutions ICAV (CLONE) as an unauthorised ICAV and clarifying the absence of any connection with the legitimate authorised fund

Suggested considerations

• Update internal sanctions, fraud, and negative‑news screening lists and any “unauthorised firms” watchlists to include Insight Investment Solutions ICAV (CLONE) and its associated website, phone number, and email address.
• Instruct onboarding, KYC, and product‑approval teams to verify any reference to “Insight Investment Solutions ICAV” directly against the CBI registers, ensuring the Central Bank registration number and contact details match the legitimate authorised ICAV, not the clone.
• Implement or reinforce clone‑firm detection controls, including validation of firm names, registration numbers, URLs, emails, and phone numbers against official CBI (and other relevant NCA) registers before onboarding a fund, manager, or distributor.
• Circulate a targeted internal fraud/scam alert to front‑office, distribution, advisory, call‑centre, and client‑facing staff highlighting the existence of this specific clone, its identifiers, and the escalation process if approached.
• Review and, where necessary, update financial promotions and distribution due‑diligence procedures to require confirmation that any Irish ICAV referenced in marketing materials is directly verified on the CBI register and not accessed via unverified third‑party domains.

What changed

• - The CBI has formally designated *Insight Investment Solutions ICAV (CLONE)* as an unauthorised ICAV and publicly listed it as an unauthorised firm under section 53 of the Central Bank (Supervision...
• The CBI confirms the clone firm is not authorised to provide financial services in Ireland and is unlawfully using the name and Central Bank registration number of the legitimate ICAV to deceive...
• The warning explicitly clarifies that there is no connection whatsoever between the legitimate Central Bank authorised Insight Investment Solutions ICAV and the clone entity, which must now be...
• Contact details (website, telephone number, email) used by the clone are now identified by the CBI as fraudulent identifiers that should be incorporated into internal fraud and financial‑crime...
• The publication reinforces the CBI’s expectation that firms and the public report suspected unauthorised firms to the CBI and consult CBI public registers and scam guidance when verifying...

Key dates

29 August 2025

– CBI issues a prior warning notice on an analogous unauthorised comparison website, Rates Finder, highlighting the “comparison website scam” model

19 March 2026

– CBI issues a warning on EU Bonds, another unauthorised investment firm, further signalling its focus on online bond and rate “finder” scams

03 June 2026

– CBI publishes the Warning Notice on Euro Bonds Finder/Irish Rates Finder as an unauthorised investment firm/investment business firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Screen all clients, counterparties, introducers, and third-party platforms against the CBI “Search Unauthorised Firms” list and ensure Euro Bonds Finder/Irish Rates Finder is included in internal watchlists and negative lists.
• Update internal fraud, scam, and financial crime typology libraries to include Euro Bonds Finder/Irish Rates Finder and similar bond/rate “finder” or comparison-website investment scams, including indicators such as online forms capturing investor details and subsequent unsolicited calls or emails.
• Instruct relationship managers, advisory staff, and customer service teams not to refer clients to, or accept referrals from, Euro Bonds Finder/Irish Rates Finder and to escalate any client reports of contact with this firm via internal suspicious activity or fraud reporting channels.
• Enhance transaction monitoring and payment screening rules to flag and review attempted transfers to payment accounts or beneficiaries linked to Euro Bonds Finder/Irish Rates Finder or similar unauthorised online investment schemes.
• Review marketing, distribution, and partnerships to ensure no white-labelling, lead-sharing, affiliate, or referral arrangements exist, directly or indirectly, with Euro Bonds Finder/Irish Rates Finder or comparable unauthorised comparison/investment platforms.

What changed

• - The CBI has formally designated Euro Bonds Finder/Irish Rates Finder as an unauthorised investment firm/unauthorised investment business firm and added it to its public unauthorised firms list...
• The CBI has explicitly confirmed that Euro Bonds Finder/Irish Rates Finder is not authorised as an investment business firm in Ireland and therefore cannot legally provide investment services or...
• The warning clarifies that any dealings with Euro Bonds Finder/Irish Rates Finder fall outside the regulatory perimeter, meaning investors do not benefit from protections such as CBI conduct of...
• The publication reiterates CBI’s standing process for reporting suspected scams, including use of the dedicated phone line and the CBI’s online resources on financial scams, strengthening...
• By treating this firm in the same way as other comparison or “finder” style websites previously flagged by CBI (for example Rates Finder, EU Bonds and similar sites), the warning underscores an...

Key dates

01 December 2025

– CBI previously issued a warning regarding Bond Rate Compare / Compare Bonds Ltd as an unauthorised investment firm / investment business firm

03 June 2026

– CBI publishes the current warning notice confirming Compare Bonds Ltd is an unauthorised firm and disclosing associated website and contact details

Suggested considerations

• Screen all existing and prospective introducers, lead generators, comparison sites and affiliates against the CBI’s unauthorised firms list, and immediately block or off‑board any relationship linked to Compare Bonds Ltd, Bond Rate Compare or the domains and websites identified.
• Update internal fraud‑risk, KYC and onboarding procedures to include explicit checks for CBI unauthorised‑firm warnings for any third party that sources or routes investment or deposit business, especially where “comparison”, “bond”, “EU rates” or similar branding is used.
• Instruct front‑office, sales and relationship‑management staff not to accept introductions, leads or client referrals from Compare Bonds Ltd or any entity using the websites or email domains cited in the CBI warning.
• Enhance transaction‑monitoring and case‑management workflows to flag and investigate payments, transfers or instructions referencing Compare Bonds Ltd, comparebondrates.eu, bondratecompare.com, or similarly branded entities previously named in CBI warnings.
• Review and, where necessary, update customer‑facing scam warnings and disclosures (websites, apps, terms, and client communications) to highlight the risk of “comparison website” investment scams and to direct customers to the CBI’s unauthorised firm register.

What changed

• - The CBI has added Compare Bonds Ltd to its public list of unauthorised firms under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, confirming it is not authorised to operate...
• The warning identifies specific digital identifiers associated with the unauthorised firm, including the website `http://www.comparebondrates.eu/` and the email domain `bondratecompare.com`, which...
• The publication continues the CBI’s recent thematic focus on “comparison website” style investment scams, following earlier warnings on entities such as Bond Rate Compare / Compare Bonds Ltd, EU...
• The notice reiterates that the CBI operates a central reporting channel for unauthorised firms, including a dedicated telephone line and online reporting facility, underscoring expectations that...
• The warning is an enforcement‑related action aimed at investor protection and market integrity, signalling that regulated firms must not treat introductions, leads or referrals from Compare Bonds Ltd...

Key dates

29 May 2026

- CBI issues and publishes the warning notice identifying Fire Financial Services Limited (CLONE) as an unauthorised firm and clone of the legitimate Fire Financial Services Limited (C58301), and lists it under section 53 of the Central Bank (Supervision and Enforcement) Act 2013

Suggested considerations

• Review and update internal fraud‑risk and financial crime risk assessments to explicitly cover clone‑firm risks, including inheritance scams and impersonation of authorised entities.
• Integrate the specific domains, email addresses, and phone numbers listed in the CBI notice into fraud‑monitoring tools, allow‑/block‑lists, and case‑management systems, and ensure they are treated as high‑risk indicators.
• Ensure front‑line, call‑centre, and relationship‑management staff receive targeted training and briefing on this specific clone case and on common clone‑firm red flags, including requests related to inheritance payments and use of unofficial domains.
• Enhance onboarding and counterparty due diligence procedures to include systematic checks against the CBI “unauthorised firms” list and the CBI public registers, especially where firms claim Irish regulation or use names similar to existing authorised firms.
• Update third‑party and introducer due diligence controls to verify that any firm referring business or presenting as an intermediary is properly authorised and not listed as unauthorised under section 53 of the Central Bank (Supervision and Enforcement) Act 2013.

What changed

• - CBI has formally identified Fire Financial Services Limited (CLONE) as an unauthorised entity that is not authorised to provide banking business or payment services in Ireland and is misusing the...
• CBI has published specific fraud indicators associated with this clone, including website domains (e.g.
• The warning explicitly states that the clone firm appears to be running an inheritance scam, including the use of fake documentation allegedly from third parties, which should be treated as a red...
• CBI reiterates that there is no connection between the legitimate authorised Fire Financial Services Limited (C58301) and this fraudulent entity, thereby clarifying the status of the genuine firm and...
• The firm’s name is formally published on CBI’s list of unauthorised firms under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, increasing regulatory expectation that firms...

Key dates

05 March 2026

- CBI publishes its Discussion Paper on tokenisation and distributed ledger technology in financial services, initiating a structured consultation on tokenised markets, funds, money and payments

26 May 2026

- Deputy Governor speech sets out the CBI’s strategic approach to tokenised finance, confirming that consultation feedback will inform subsequent policy, supervisory expectations and potential rule changes

05 June 2026

- Closing date for submissions to the CBI Discussion Paper on tokenisation and DLT, after which CBI will prepare a feedback statement and refine its policy stance

TBD (post‑June 2026)

- CBI feedback statement on the tokenisation Discussion Paper expected, likely followed by more granular guidance and potential adjustments to supervisory and authorisation processes for tokenised activities

Suggested considerations

• Map all current and planned tokenisation and DLT initiatives (including pilots and proofs of concept) across the group and identify which EU and Irish regulatory regimes they fall under (MiFID II, UCITS, AIFMD, CRR/CRD, PSD2/PSR, Solvency II, MiCA, DORA, etc.).
• Perform a regulatory gap analysis to confirm that tokenised products and services are fully captured within existing licensing permissions and assess whether any variation of permission, new authorisation, or recognition as a market infrastructure is required.
• Review and update governance arrangements so that boards and senior management explicitly oversee tokenisation strategies, risk appetite, and the use of DLT, including ensuring clear allocation of responsibilities under the firm’s senior manager or fitness and probity framework.
• Integrate tokenisation‑specific risks into the firm’s risk management framework, covering legal enforceability of tokens, smart‑contract risk, cyber and operational resilience, data integrity, interoperability, concentration risk in technology providers, and settlement and counterparty risk.
• Review outsourcing and third‑party risk management frameworks to ensure that DLT platform providers, smart‑contract developers, node operators and custodians are treated as critical or important outsourced service providers where appropriate, with robust contractual, oversight and exit provisions.

What changed

• - The CBI formally recognises tokenisation and shared, programmable ledgers as a likely core infrastructure of the future financial system and signals that regulation will evolve to treat tokenised...
• The speech confirms that CBI’s regulatory approach will be “technology‑neutral but not technology‑blind”, indicating that existing EU and Irish rules (e.g.
• The CBI emphasises the need to keep central bank money at the core of tokenised finance, aligning its stance with Eurosystem work on wholesale and retail central bank digital currency (CBDC) and...
• The speech reinforces that tokenised instruments representing traditional financial assets (securities, deposits, fund units) will generally be treated as regulated financial instruments, triggering...
• The CBI highlights operational resilience, cyber risk, interoperability and smart‑contract governance as critical supervisory focus areas for tokenised finance infrastructure and platforms.

Key dates

14 April 2026

Publication date of warning notice; Immediate public alert on unauthorised status of Finance Advice Help.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

Suggested considerations

• Verify firm status: Use CBI's unauthorised firms search tool before engaging with any retail credit provider (https://www.centralbank.ie/regulation/how-we-regulate/authorisation/unauthorised-firms/search-unauthorised-firms).
• Report suspicions: Contact CBI at (01) 224 5800 or via direct reporting portal for any dealings with Finance Advice Help or similar entities.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
• Educate clients/staff: Disseminate scam protection guidance from www.centralbank.ie/financialscams; implement "SAFE test" for verification.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
• Monitor clones: Screen for impersonation risks, as seen in related warnings (e.g., Shamrock Lend clone).

What changed

This is not a regulatory change but an enforcement action via a public warning notice. It reinforces existing requirements under the Central Bank (Supervision and Enforcement) Act 2013 (section 53), which empowers CBI to publish names of unauthorised firms offering regulated services like retail credit. No new rules are introduced; it signals ongoing vigilance against unauthorised retail credit providers.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

Key dates

08 April 2026

Announcement and effective date; CBI press release details the amendment, with immediate application implied for qualifying bridging loans (no explicit phase-in mentioned)

Suggested considerations

• Update lending policies: Identify and classify principal home bridging loans (max 18 months, repayment from property sale, no capital repayments required during term) to apply LTI exemption but enforce 90% LTV.
• Enhance underwriting: Conduct individual suitability and affordability assessments beyond macroprudential limits; do not rely solely on exemption.
• Strengthen consumer protections: Fully inform borrowers of risks (e.g., sale delays, interest costs); ensure products suit circumstances per consumer protection rules.
• Internal monitoring and reporting: Track bridging loan volumes within flexibility allowances; prepare for CBI inquiries as part of ongoing assessments.
• Staff training and systems updates: Revise origination, disclosure, and compliance systems promptly to operationalize changes.

What changed

• - Exemption from LTI limit: Principal home bridging loans—defined as short-term loans (maximum 18 months) enabling homeowners to buy a new principal home before selling their current property, repaid...
• LTV limit retained: Maximum 90% LTV continues to apply to these loans, alongside the 15% flexibility allowance for first-time/second/subsequent buyer lending.
• No other changes: All remaining mortgage measures, including consumer protection rules and lenders' prudent underwriting obligations, stay intact.
• Monitoring commitment: CBI will track the exemption's operation within its regular mortgage measures assessments for unintended risks.

Key dates

24 March 2025

- CBI publishes revised CPC 2025, Standards for Business Regulations, Consumer Protection Regulations, and guidance

24 March 2026

- CPC 2025 takes effect; existing 2012 Code ceases (12-month implementation period ends)

Until 24 March 2026

- 2012 Code (with addenda) remains in force

Suggested considerations

• Gap analysis: Map current policies/processes against CPC 2025 using CBI's mapping tool; update for new obligations like digital service design, vulnerability screening, fraud measures.
• Policy/system updates: Implement "secure customers’ interests" framework; enhance disclosures (e.g., mortgages, charges, unregulated activities); train staff on conduct standards/vulnerable consumers.
• Governance/risk: Strengthen board oversight, risk management for cyber/fraud/digital risks; distinguish regulated/unregulated activities.
• Testing/monitoring: Develop records/compliance systems; test advertising/bundling; integrate sustainability claims checks.
• Stakeholder engagement: Review CBI guidance/FAQs; prepare for supervision during implementation.

What changed

• The CPC 2025 comprises Standards for Business Regulations (governance, resources, risk management, conduct standards) and Consumer Protection Regulations (cross-sectoral and sector-specific rules for...
• Core obligation: Firms must "secure customers’ interests," shifting to a proactive, customer-focused mindset.
• Cross-sectoral requirements: Knowing the consumer/suitability; conflicts of interest/remuneration; vulnerable consumers (updated definition); digitalisation (customer-focused design); effective...
• Specific enhancements: Fraud/scam protections; mortgage switching disclosures; greenwashing prevention via clear sustainability claims; expanded consumer definition (e.g., SMEs up to €5m turnover...
• Supporting materials: Guidance on securing interests/vulnerable consumers, mapping tool for legacy codes, redline amendments.

Key dates

24 March 2026 Deadline

- Revised Consumer Protection Code (CPC) takes effect (12-month lead-in complete; firms must be compliant)

H1–H2 2026

- DORA implementation including threat-led penetration testing (survey issued H1)

H1–H2 2026

- Enhanced AML/CFT Risk Evaluation Questionnaire

H1 2026–H2 2027

- Thematic inspection of transaction monitoring and STR reporting

H1–H2 2026

- UCITS Value at Risk (VaR) model review and depositary oversight

Suggested considerations

• Conduct gap analyses for revised CPC compliance, focusing on thresholds, customer experience, and fraud support (immediate if in-scope).
• Enhance resilience frameworks: Map operational/cyber risks, perform realistic scenario testing, document risk management for geopolitical/macro uncertainties.
• Strengthen financial crime controls: Improve fraud detection, victim support, scam awareness; update AML/CFT via enhanced questionnaires and transaction monitoring.
• Review technology/AI governance: Assess AI models, digital innovations (e.g., tokenisation); engage CBI supervisors pre-implementation; ensure data quality/reliability.
• Embed ESG/climate risks: Integrate into governance/business models; prepare for desktop/onsite reviews and greenwashing checks.

What changed

• No new legislative changes are introduced in the speech itself, which serves as a practitioner's perspective on implementing the RSO 2026 priorities.
• Resilience to geopolitical/macro risks (operational resilience, cyber security, financial resilience).
• Consumer/investor protection (customer experience, digitalisation risks, financial crime/fraud).
• Technology transformations (AI, digital money, tokenisation). These build on prior developments like the revised Consumer Protection Code (CPC), DORA implementation, and enhanced AML/CFT frameworks,...

Key dates

2026

2027; - Ongoing desktop/onsite reviews on operational resilience, ESG/climate, and supervisory priorities across sectors.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]

24 March 2026 Deadline

- Revised Consumer Protection Code (CPC) takes effect, following 12-month lead-in; firms must ensure full implementation.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]

H1 2026

- CBI consultation on new Regulatory Impact Assessment (RIA) Framework.[https://maples.com/regulatory-round-up/central-bank-of-ireland-update-and-supervisory-approach-for-2026-fund-service-providers][https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf]

Summer 2027

- Anti-Money Laundering Authority (AMLA) single rulebook implementation, influencing financial crime priorities.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]

Suggested considerations

• Implement revised CPC by 24 March 2026, assessing scope changes and business impacts.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
• Enhance financial crime controls, including fraud victim support, scam awareness, and market abuse detection; monitor AMLA developments.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
• Embed ESG/climate risks into governance, risk management, and business models, preparing for SFDR 2.0 and event response reviews.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
• Prepare for integrated supervision via gatekeeping enhancements and streamlined reporting.[https://maples.com/regulatory-round-up/central-bank-of-ireland-update-and-supervisory-approach-for-2026-fund-service-providers]

What changed

No new binding regulatory requirements are introduced in this publication, which serves as a strategic outlook rather than enforceable rules. Key shifts in risk assessment include elevated operational risks (due to geopolitics, digitalisation, complex models), increased asset valuation/market risks, and rising data/models/AI risks, while inflation/interest rate risks have decreased.

Key dates

Second half 2026

- Ireland assumes EU Council Presidency; CBI will support government during this period

10 February 2026

- CBI published its 2026 Regulatory and Supervisory Priorities, which establish the operational framework within which this governance philosophy applies

18 February 2026

- This speech delivered, reinforcing institutional independence principles

Suggested considerations

• *Understand CBI decision-making philosophy: Recognize that CBI supervisory decisions are grounded in long-term economic stability objectives, not short-term political cycles.
• *Align governance with credibility principles: The speech identifies four credibility pillars—competence, engagement, coherence, and public trust. Regulated firms should ensure their governance frameworks reflect these principles in their own operations.
• *Monitor 2026 supervisory priorities: The speech references CBI's published 2026 Regulatory and Supervisory Priorities, which include maintaining resilience to geopolitical risks, securing consumer and investor interests, and delivering new responsibilities under Access to Cash legislation.

What changed

• This is not a regulatory change document but a governance clarification with compliance implications:
• Reframing of independence: Central bank independence is characterized as an "anchor" enabling long-term decision-making rather than isolation from society.
• Credibility framework: Credibility depends on competence, engagement, coherence, and public trust—not institutional distance alone.
• Accountability emphasis: Independence requires continuous dialogue with society and other economic governance institutions; it "does not mean isolation."
• Historical validation: The speech references the 1960s-1970s macroeconomic instability under political pressure versus post-pandemic effectiveness of credible central banks in controlling inflation.

Key dates

2025

2026; - Ongoing implementation of banking/payments supervisory activities and multi-year roadmap (supervision, regulation, gatekeeping, reporting). https://www.matheson.com/insights/fig-top-5-at-5-06-03-2025/ https://www.centralbank.ie/news/article/press-release-central-bank-of-ireland-publishes-roadmap-to-deliver-a-more-effective-and-efficient-regulatory-framework-10-december-2025

Next few weeks from 11 February 2026

- Publication of CBI's full 2026 Regulatory and Supervisory Priorities. https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026

H1 2026

- Consultation on new Regulatory Impact Assessment (RIA) Framework. https://maples.com/regulatory-round-up/central-bank-of-ireland-update-and-supervisory-approach-for-2026-fund-service-providers https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf

Shortly (2026)

- Launch of comprehensive Fund Service Provider (FSP) Framework review. https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf

Suggested considerations

• Review and prepare for priorities: Monitor for 2026 priorities release (imminent); assess firm alignment with resilience themes (geopolitical/macro-financial risks, operational resilience, consumer protection).
• Enhance resilience planning: Strengthen operational/financial resilience frameworks, including stress testing for geopolitical shocks, infrastructure dependencies, and climate risks; update outsourcing/governance per cross-sectoral guidance.
• Engage on consultations: Participate in H1 2026 RIA Framework consultation and upcoming FSP review; review internal reporting/data processes for proportionality.
• Sector-specific: Funds/asset managers—prepare for AIF/UCITS updates and FSP review; banks/insurers—align with CRD V/Solvency II compatibility reviews; all firms—ensure business models address narrow economic vulnerabilities.

What changed

• This is a forward-looking speech, not announcing immediate regulatory changes, but it references CBI's ongoing transformation agenda, including:
• Four overarching supervisory priorities for 2026: (1) Maintaining/building resilience to geopolitical/macro-financial risks (operational and financial resilience); (2) Securing consumer/investor...
• Upcoming publication of full 2026 Regulatory and Supervisory Priorities "in the next few weeks." https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026
• Broader roadmap initiatives: Integrated risk-based supervision; rulebook updates (e.g., AIF/UCITS, Fund Service Provider framework review post-AIFMD II, insurance compatibility with Solvency II,...

Key dates

24 March 2026 Deadline

- Revised Consumer Protection Code comes into force; firms must ensure full readiness and ongoing embedding of provisions, including new Standards for Business

Suggested considerations

• Implement Revised Consumer Protection Code: Complete readiness by 24 March 2026; apply new Standards for Business in operations, leveraging CBI workshops for guidance.
• Embed IAF: Maintain enhanced responsibility mapping, support decision-making, and engage with CBI on implementation feedback to mature governance.
• Adopt Outcomes-Focused Practices: Shift from process-driven to outcomes-based compliance (e.g., customer interests, resilience); review internal frameworks for simplification opportunities.
• Engage with CBI: Participate in ongoing consultations, workshops, and stakeholder feedback on supervision evolution, IAF, and Consumer Protection Code.
• Leverage Technology: Integrate tech for resilience and compliance efficiency, aligning with CBI's supervisory priorities.

What changed

• - Revised Consumer Protection Code: Introduces new Standards for Business, building on the Code reviewed with industry input; focuses on delivering good outcomes for consumers and the economy.
• Individual Accountability Framework (IAF): Implemented 18 months prior (circa mid-2024); enhances clarity on responsibilities, supports governance, and aligns with outcomes-focused regulation rather...
• Supervisory Approach Evolution: Shifting in 2025-2026 to risk-based, outcomes-focused, less process-driven supervision integrated across financial stability, consumer protection, safety/soundness,...
• Regulatory Simplification: Openness to reviewing frameworks (e.g., fitness and probity) for simpler, outcomes-based alternatives without compromising effectiveness; supports broader simplification...
• Resilience and Technology: Ongoing focus on financial resilience post-reforms, leveraging technology for supervision; no specific new rules but emphasis on embedding these in operations. No new...

Key dates

January 2025

- New integrated supervisory model became effective

2025

- Strategic review of Industry Funding Levy approach (consultation expected during 2025)

2026

- Public consultation on new Regulatory Impact Assessment Framework

2026 to first half of 2028

- Multi-year programme implementation period for all roadmap initiatives

Suggested considerations

• *Immediate actions for compliance professionals:
• *Monitor consultation releases: Track the Central Bank's website for the 2026 RIA Framework consultation and respond with firm-specific impact assessments
• *Assess rulebook changes: Review how proposed updates to insurance regulations, banking rules, credit union handbook, and fund regulations affect your firm's compliance framework
• *Evaluate supervisory engagement: Understand how the new integrated supervisory model affects your firm's supervisory relationship and reporting lines
• *Prepare for gatekeeping changes: Anticipate enhanced consistency and transparency requirements in authorisation and Fitness & Probity processes

What changed

• The roadmap encompasses four major reform areas: Supervision: Implementation of a new integrated, risk-based supervisory approach introduced in January 2025, consolidating multidisciplinary teams...
• Insurance: Major compatibility review to eliminate duplication with Solvency II reforms and review of 2021 Recovery Planning Regulations
• Banking: Review of domestic banking rules predating CRD V/CRR to ensure consistency with updated EU standards
• Credit Unions: Updates to the Credit Union Handbook following simplification of the Lending Framework
• Funds: Changes to AIF rulebook and UCITS regulation with full review of the Fund Service Provider Framework