Insurance & Pensions regulatory updates from Ireland.
We track 35 Insurance & Pensions updates from Ireland regulators, published by CBI. The archive covers 24 enforcement actions, 6 speeches and 3 warnings. Most recent update: September 2026. Coverage runs from 2018 to 2026.
Seána Cunningham delivers her opening remarks at the UNEP Global Sustainable Insurance Summit in Dublin.
Why this matters
This is a speech by the Central Bank of Ireland's Director of Insurance at an international summit. It articulates regulatory expectations around climate risk, insurance market resilience, and adaptation finance.
Central Bank of Ireland has today published its Supplemental Guidance on Prohibition Notices under the Fitness and Probity Regime , and a related Feedback Statement on Consultation Paper 166 . The Consultation , which closed on 25 March 2026, received eight submissions from representative bodies and individuals. The…
AI Analysis
The Central Bank of Ireland (CBI) has finalised and published **Supplemental Guidance on Prohibition Notices under the Fitness and Probity (F&P) Regime**, together with a Feedback Statement on Consultation Paper 166 (CP166). This guidance materially clarifies how CBI decision makers will determine the **nature, scope, duration, termination and publication** of Prohibition Notices, raising the bar for governance, investigation handling, and individual accountability across all Irish-regulated firms.
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...
Compliance impact
Non-compliance with the clarified prohibition framework, or failure to manage individuals subject to F&P concerns appropriately, exposes firms to significant enforcement risk, reputational damage, and potential constraints on business due to the removal of key CF/PCF staff. The refined guidance increases predictability but also raises expectations that firms will proactively manage F&P risks and cooperate effectively with the CBI in prohibition cases.
Central Bank of Ireland has commissioned an independent review of its enforcement activities. Enforcement is a core component of the Central Bank's regulatory framework. It supports credible deterrence and accountability, promotes high standards of conduct and, through transparent outcomes, supports trust and…
AI Analysis
The Central Bank of Ireland (CBI) has appointed Josephine Feehily as an external reviewer to conduct an independent review of the **effectiveness, efficiency and positioning of CBI’s enforcement activities within its supervisory framework**, with a report (including recommendations) to be published in due course. This signals a potential medium-term recalibration of enforcement strategy, case selection, timelines and transparency, and compliance teams should anticipate possible changes to how investigations are initiated, managed and resolved, including expectations around engagement and disclosure.
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...
Compliance impact
The immediate compliance impact is indirect but strategically significant: while no new rules are yet in force, firms should treat this as a precursor to a potentially more structured, faster and more transparent enforcement regime. Failure to adapt to any subsequent changes is likely to increase exposure to higher sanction risk, reputational damage and more intensive regulatory scrutiny.
Warning: Unauthorised Insurance Intermediary and Insurance/ Reinsurance Firm Unauthorised Firm Name Codeve Insurance Co DAC (CLONE) Website address https://www.codeveinsurance.com/ Email addresses used [email protected][email protected][email protected] Authorisation in Ireland This firm…
AI Analysis
The Central Bank of Ireland (CBI) has issued a warning under section 53 of the Central Bank (Supervision and Enforcement) Act 2013 against **Codeve Insurance Co DAC (CLONE)**, an unauthorised firm impersonating the authorised insurer **CODEVE Insurance Company dac** and offering insurance/reinsurance and intermediary services in Ireland without authorisation. This is a clone-firm financial crime risk event that requires immediate enhancements to onboarding, counterparty due diligence and fraud‑risk controls for insurance and distribution arrangements involving Ireland or Irish‑resident customers.
Key dates
17 July 2026
- CBI issues the public warning notice listing Codeve Insurance Co DAC (CLONE) as an unauthorised firm under section 53 of the Central Bank (Supervision and Enforcement) Act 2013
Suggested considerations
Update internal unauthorised/blacklist tables and watchlists to include “Codeve Insurance Co DAC (CLONE)”, the website `https://www.codeveinsurance.com`, and the email addresses `[email protected]`, `[email protected]`, and `[email protected]`.
Configure onboarding, third‑party due diligence and supplier management systems so that any counterparty or proposal referencing these identifiers or closely similar names triggers escalation and enhanced verification.
Conduct an immediate screening of existing distribution, outsourcing, binder, reinsurance and fronting arrangements to confirm that no current relationships involve the clone entity or its contact details.
Implement or reinforce a formal “clone‑firm check” in client and counterparty KYC/KYB procedures, requiring staff to verify authorisation status directly against the CBI’s registers and unauthorised firm list before entering into insurance or reinsurance arrangements linked to Ireland.
Issue an internal compliance and financial‑crime alert to underwriting, sales, distribution, treasury and investment teams highlighting the Codeve clone, the specific identifiers, and the need to report any contact or proposals linked to this entity.
What changed
- The CBI has formally listed “Codeve Insurance Co DAC (CLONE)” as an unauthorised insurance/reinsurance firm and insurance intermediary/distributor for Ireland.
The CBI confirms that this entity is not authorised in Ireland to provide insurance, reinsurance or insurance distribution/intermediary services.
The warning identifies specific contact points used by the clone: website `https://www.codeveinsurance.com` and email addresses `[email protected]`, `[email protected]` and...
The CBI confirms that the unauthorised firm has cloned the name and details of the authorised firm CODEVE Insurance Company dac to pass itself off as that legitimate entity and deceive consumers.
The CBI explicitly states there is no connection between the authorised CODEVE Insurance Company dac and the unauthorised clone, clarifying that the authorised firm is a victim of impersonation.
Compliance impact
Non‑compliance primarily exposes firms to financial crime, conduct and civil liability risks, including the risk of facilitating unlicensed insurance business, mis‑selling, and customer loss through fraud. Regulatory expectations around due diligence, distribution control and consumer protection mean that failure to identify and mitigate clone‑firm exposure could lead to supervisory scrutiny, remediation requirements and potential enforcement where governance or systems and controls are found deficient.
Warning: Unauthorised Insurance Intermediary Unauthorised Firm Name Inloovi Ireland Ltd. (Clone) Website address https://inloovi.com/ Email addresses used [email protected][email protected][email protected][email protected] Authorisation in Ireland This firm is not authorised to provide insurance…
AI Analysis
The Central Bank of Ireland (CBI) has issued a **Section 53 Central Bank (Supervision and Enforcement) Act 2013 warning notice** against **Inloovi Ireland Ltd. (Clone)**, an unauthorised entity falsely presenting itself as **A.R.B. Underwriting Limited t/a Buddy Travel Insurance** in order to provide insurance intermediation/distribution services in Ireland without authorisation. This reinforces CBI’s ongoing focus on **clone scams**, and has immediate implications for Irish‑authorised insurers, MGAs, and intermediaries around due‑diligence on counterparties, website/email abuse monitoring, and customer communications to prevent consumer detriment.
Key dates
10 July 2026
- CBI issues and publishes the Warning Notice identifying Inloovi Ireland Ltd. (Clone) as an unauthorised insurance intermediary and clone of A.R.B. Underwriting Limited t/a Buddy Travel Insurance, and lists the associated website and email addresses
Suggested considerations
Review and update internal sanctions/blacklist and fraud‑risk lists to include “Inloovi Ireland Ltd. (Clone)”, the domain inloovi.com, and the listed email addresses, ensuring screening across onboarding, claims, complaints, and payment processing.
Conduct an immediate counterparty and referral review to confirm that no current or proposed distribution, outsourcing, or referral arrangements involve Inloovi Ireland Ltd. (Clone) or entities using the inloovi.com domain.
Enhance KYC and intermediary due‑diligence procedures to include explicit checks against the CBI’s unauthorised firms list and Section 53 Warning Notices before entering into any new intermediary, coverholder, or introducer arrangement.
Update staff training (particularly for sales, claims, complaints, and contact‑centre teams) on recognising clone‑firm indicators (e.g., similar names, use of look‑alike domains, unofficial email addresses) and on escalation pathways to compliance and fraud teams.
Review and, where necessary, enhance website monitoring and brand‑abuse detection (including domain monitoring, phishing detection, and use of take‑down services) to identify and address fraudulent websites or email domains purporting to represent the firm.
What changed
- The CBI has formally identified “Inloovi Ireland Ltd. (Clone)” as an unauthorised insurance intermediary that is not authorised to provide insurance intermediary or insurance distribution services...
The CBI has publicly associated specific digital identifiers with this fraudulent entity, including the website inloovi.com and email addresses [email protected], [email protected],...
The CBI confirms that Inloovi Ireland Ltd. (Clone) has cloned details of a legitimate CBI‑authorised firm, A.R.B.
The CBI clarifies that there is no connection whatsoever between the legitimate authorised entity and the clone firm, and the warning is intended to protect both consumers and the legitimate firm’s...
The CBI reiterates that the name of the unauthorised firm is published under Section 53 of the Central Bank (Supervision and Enforcement) Act 2013, reinforcing its supervisory and enforcement stance...
Compliance impact
Failure to identify and respond to clone‑firm activity can expose regulated insurers and intermediaries to significant conduct, reputational, and potential supervisory risk, particularly where consumers mistakenly believe fraudulent activity is connected to an authorised firm. While the warning is formally directed at an unauthorised entity, CBI expectations on active detection, reporting, and customer communication are clear, and weak controls in these areas may attract supervisory scrutiny and, in serious cases, enforcement interest.
The Central Bank of Ireland has today launched a public consultation seeking views on its approach to Regulatory Impact Assessment (RIA) and on its approach to consultation with stakeholders. The consultation forms part of the Central Bank’s ongoing work to deliver a more effective and efficient regulatory framework…
AI Analysis
The Central Bank of Ireland (CBI) has launched a public consultation (closing 30 September 2026) on its **Regulatory Impact Assessment (RIA) framework** and on how it consults with stakeholders, as part of its wider programme to make Irish financial regulation more effective, efficient, and proportionate. For compliance teams, this is a key opportunity and a warning: the way the CBI designs, justifies, consults on, and reviews future rules will be formalised and made more evidence‑based, which will directly affect the cost, complexity, and predictability of future regulatory change across all sectors.
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...
Compliance impact
In the short term, the consultation does not impose new binding obligations but shapes the procedural framework for all future CBI rule‑making, making early engagement strategically important for managing long‑term compliance cost and regulatory uncertainty. Over the medium term, once the RIA and consultation frameworks are finalised, firms that fail to engage effectively in consultations may find themselves facing more onerous or misaligned requirements with limited scope for later challenge or adjustment.
Good morning and thank you to BIPAR for inviting me to speak at your event today, as we approach the start of the Irish Presidency of the Council of the European Union. As the financial sector continues to evolve, the contribution of intermediaries remains as important as ever. Around 2,500 of the 3,300 firms the…
Why this matters
Deputy Governor speech outlining CBI's supervisory priorities for retail intermediaries. Key focus areas include consumer vulnerability, commission arrangements, unregulated activities, and digital transformation. Informational in nature, setting regulatory expectations rather than announcing new rules.
Warning: Unauthorised Banker Unauthorised Firm Name HSBC Continental Europe (CLONE) Website https://campaign.eligibility-advisorscorporate.com/ Telephone Number (01) 6214 2195 (07) 4313 0963 Email address used [email protected] Authorisation in Ireland This scam entity cloned the name and details of a firm…
AI Analysis
The Central Bank of Ireland (CBI) has issued a warning notice (under section 53 of the Central Bank (Supervision and Enforcement) Act 2013) about a **clone “HSBC Continental Europe (CLONE)”** operating as an unauthorised banker and fraudulently using the CBI authorisation number of **Cowan Insurance Brokers Limited (CBI00001421)**. The case underscores heightened clone‑firm risk and obliges compliance, financial crime and customer‑facing teams to strengthen name‑screening, verification of authorisation numbers, and scam‑response procedures when dealing with references to HSBC, Cowan Insurance Brokers Limited, and similar high‑profile brands.
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...
Compliance impact
Failure to detect or appropriately respond to clone‑firm approaches could expose firms to customer loss, complaints, civil claims, and heightened CBI scrutiny regarding the adequacy of fraud, AML, and customer‑protection controls. For CBI‑authorised firms, weak controls around clone‑firm risk may be treated as a conduct and systems‑and‑controls deficiency with potential supervisory or enforcement consequences.
The Prohibition Notice (PDF) issued after Mr Buckley signed a Statement of Undisputed Facts, in which he accepted that between 1 February 2021 and 12 December 2023, while he was employed at two different retail intermediaries, he issued invoices to clients directing payment to his personal bank account in place of his…
AI Analysis
The Central Bank of Ireland (CBI) has issued an indefinite prohibition to Nicholas (Nick) Buckley from all controlled functions, effective 25 February 2026, following his admission of diverting client payments to his personal account and misrepresenting financial qualifications while at two retail intermediaries from 1 February 2021 to 12 December 2023. This enforcement action underscores the CBI's commitment to the Fitness and Probity Regime, emphasizing integrity in customer-facing roles to maintain public trust. Compliance professionals should note it as a precedent for severe sanctions on dishonesty, potentially influencing vetting and monitoring practices.
Key dates
1 February 2021
12 December 2023; Period of Buckley's admitted misconduct (diverting payments and misrepresenting qualifications)
25 February 2026
Effective date of the indefinite prohibition on Buckley performing any controlled functions
01 April 2026
Publication date of the CBI press release announcing the Prohibition Notice
Suggested considerations
Firms employing similar roles: Immediately review invoicing processes to ensure payments direct only to firm accounts, with segregation of duties and dual approvals for client billing.
Fitness and Probity assessments: Conduct enhanced due diligence on customer-facing staff, verifying qualifications via independent sources and monitoring for personal financial gain conflicts.
Incident reporting: Escalate any suspected integrity breaches (e.g., qualification misrepresentation or fund diversion) to CBI under fitness and probity notification obligations.
Training programs: Update mandatory training on Fitness and Probity Standards (available at https://www.centralbank.ie/regulation/fitness-and-probity), focusing on honesty in client interactions.
Prohibition checks: Screen all controlled function holders against CBI's public prohibitions list before approvals or role changes.
What changed
This is not a new regulation but an enforcement outcome under the existing Fitness and Probity Regime, established by the Central Bank Reform Act 2010, which mandates high standards of competence, integrity, and honesty for individuals in controlled functions. No regulatory changes are introduced; instead, it reinforces enforcement mechanisms, including investigations and prohibitions for breaches, particularly in customer-facing roles where honesty is paramount.
Compliance impact
Urgency: Medium – This is a specific enforcement precedent rather than a new rule, but it signals heightened CBI scrutiny on integrity breaches in retail intermediation, with indefinite bans as a tool to protect consumers. It matters because customer-facing misconduct erodes trust, prompting firms to strengthen controls proactively to avoid similar investigations, especially given CBI Director of Enforcement's warning on accountability. Non-compliance risks firm-level sanctions, reputational damage, and operational disruptions.
Good afternoon and welcome to this Central Bank of Ireland workshop on the Consumer Protection Code. Today I will focus on the outlook for consumers and investors. But first let me pause to talk a little about the broader context in which we find ourselves. We are living through a period marked by extraordinary…
AI Analysis
Deputy Governor Colm Kincaid's speech on 24 March 2026 emphasizes consumer protection as central to the Central Bank of Ireland's (CBI) mission amid geopolitical, technological, and economic changes, highlighting the revised **Consumer Protection Code 2025** (CPC 2025) as a key modernization effort. This matters for compliance professionals because the CPC 2025 introduces enhanced, digitally-focused protections effective **24 March 2026**, replacing the 2012 Code after a 12-month implementation period, with firms required to proactively secure customer interests.
Key dates
24 March 2025
- CBI publishes revised CPC 2025, Standards for Business Regulations, Consumer Protection Regulations, and guidance
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.
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.
Compliance impact
Urgency: High – With effectiveness today (24 March 2026), firms face immediate non-compliance risk as the 12-month window closes; CBI supervision will intensify on digital/fraud/vulnerability protections amid heightened risks (e.g., cyber, scams). Non-adherence risks enforcement under CBI's powers, reputational damage, and fines, especially as this "gold-plates" EU rules in a volatile environment.
The Central Bank of Ireland today (Tuesday 24 March 2026) marked the coming into force of the modernised Consumer Protection Code, giving consumers stronger protections when using banks, insurance companies, and other financial services. The modernised Code has been designed to better protect consumers in today’s…
Why this matters
This regulatory update from the Central Bank of Ireland introduces a modernized Consumer Protection Code that imposes new requirements on financial firms to better protect consumer interests.
Good morning everyone, I am delighted to be here for what looks set to be an interesting conference on a topic which is both very close to my heart and central to what we do at Central Bank of Ireland (“the Central Bank”) – as we work to deliver on our mission, and in particular ensuring the financial system is…
AI Analysis
This speech by Deputy Governor Mary Elizabeth McMunn outlines the Central Bank of Ireland's (CBI) shift toward **outcomes-focused regulation and supervision**, emphasizing five key priorities from the 2026 Regulatory and Supervisory Outlook (RSO) to address geopolitical risks, consumer protection, technology, and resilience in a volatile environment. It matters for compliance professionals as it signals intensified CBI scrutiny on firm behaviors and outcomes rather than mere rule compliance, with direct implications for supervisory engagements, thematic reviews, and enforcement across banking, funds, insurance, and payments sectors.
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).
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,...
Compliance impact
Urgency: High – The speech, delivered today (9 March 2026), underscores imminent RSO 2026 execution with CPC effective in 2 weeks (24 March 2026) and H1 2026 activities (e.g., DORA testing, AML questionnaires) starting soon. Non-compliance risks intensified supervision, thematic inspections, enforcement, and reputational damage in a high-geopolitical-risk environment; outcomes-focus demands proactive evidence of resilience and consumer safeguards over procedural box-ticking.
The Central Bank has today published its Regulatory & Supervisory Outlook 2026 , which sets out its latest assessment of the risk landscape facing the financial sector and the supervisory work it will undertake in response. This follows on from the Governor’s letter to the Tánaiste on the economic outlook and…
AI Analysis
The Central Bank of Ireland (CBI) has published its **Regulatory & Supervisory Outlook 2026**, outlining priorities shaped by geoeconomic fragmentation, technological acceleration, and elevated risks like operational resilience, cyber threats, data/AI, and consumer protection. This matters for compliance professionals as it signals intensified supervisory scrutiny, including desktop and onsite inspections, across Ireland's financial sector to ensure resilience and adaptability amid uncertainties.[https://www.centralbank.ie/news/article/press-release-central-bank-sets-out-its-regulatory-and-supervisory-priorities-26-february-2026][https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
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]
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.
Compliance impact
Urgency: High – This outlook directly previews intensified 2026 supervision, with operational/cyber resilience and consumer protection as "key concerns" likely triggering unannounced inspections and enforcement. Firms risk findings on outdated resilience testing or CPC gaps, especially amid elevated risks; proactive alignment now prevents remediation costs and sanctions, given CBI's efficiency roadmap and international...
I would like to welcome you all to the Central Bank of Ireland today 1 . We are delighted to host this gathering of EU Heads of Missions, representatives of our friends and partners from across the EU. A little over a year ago I had the pleasure to meet with you all. I spoke then of a geopolitical landscape facing…
AI Analysis
This speech by Central Bank of Ireland (CBI) Governor Gabriel Makhlouf outlines priorities for building economic and financial resilience amid geopolitical risks, climate change, technological shifts, and geoeconomic fragmentation, emphasizing domestic policy focus areas like infrastructure, indigenous business growth, and fiscal buffers. It matters for compliance professionals as it previews CBI's forthcoming 2026 regulatory and supervisory priorities, signaling heightened scrutiny on operational and financial resilience, consumer protection, and alignment with a transforming regulatory framework. https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026
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,...
Compliance impact
Urgency: Medium—This speech signals strategic direction rather than enforceable rules, but imminent priorities publication and 2026 consultations demand proactive preparation to avoid intensified supervision/enforcement. It matters because CBI emphasizes resilience in a high-risk environment (geopolitics, AI, climate), with non-compliance risking closer scrutiny under new integrated approach; firms ignoring this could face heightened operational reviews amid efficiency drive without standards reduction. https://www.centralbank.ie/regulation/transforming-regulation-and-supervision
Mr Philip Smith, former Chief Executive Officer (CEO) and Executive Director of RSA Insurance Ireland DAC disqualified for 13 years by the Central Bank of Ireland for his admitted participation in a breach of financial services law by RSAII On 1 December 2025 the Central Bank of Ireland reprimanded Mr Smith and…
AI Analysis
The Central Bank of Ireland (CBI) reprimanded and disqualified former RSA Insurance Ireland DAC (RSAII) CEO Philip Smith for 13 years from management roles in regulated financial service providers due to his admitted role in under-reserving large loss claims, breaching Article 13(1)(a) of the European Communities (Non-Life Insurance) Framework Regulations 1994 (S.I. No. 359/1994). This enforcement action underscores CBI's commitment to individual accountability for senior executives who circumvent controls, risking policyholder protection and firm solvency, as evidenced by RSAII's subsequent need for a major capital injection. It matters for compliance professionals as it demonstrates CBI's use of prolonged disqualifications and inquiries under the Administrative Sanctions Procedure (ASP) to deter governance failures in insurance firms.
Key dates
2014
- CBI enforcement investigation into Mr Smith and RSAII commences
December 2018
- CBI reprimands and fines RSAII €3.5m for related breaches, including reserve failures
November 2022
- CBI decides to hold an Inquiry into Mr Smith's participation under Part IIIC of the Central Bank Act 1942
1 December 2025
- Reprimand and 13-year disqualification imposed on Mr Smith, effective immediately under IAF Act transitional provisions (no High Court confirmation needed)
12 December 2025
- CBI publishes public statement on the enforcement action
Suggested considerations
Conduct internal audits of large loss claim reserving processes to verify compliance with Article 13(1)(a) of the 1994 Regulations, ensuring estimates are accurately recorded in databases without undocumented overrides.
Review senior management oversight of claims handling; document all approvals and prohibit informal (e.g., in-person or hard-copy only) processes that bypass controls.
Enhance governance training for executives on personal liability under ASP, including simulations of reserving decisions and policyholder risk scenarios.
Assess historical exposures for under-reserving; remediate if needed, and prepare for potential CBI inquiries (noting 10+ year investigation timelines).
Update conduct and culture frameworks to align with CBI expectations for CEOs to drive compliance, as per Deputy Governor Colm Kincaid's comments.
What changed
This is not a regulatory change or new requirement but an enforcement precedent reinforcing existing obligations under the 1994 Regulations for insurers to maintain adequate technical reserves reflecting true liabilities. It highlights CBI's focus on senior executive accountability for deliberate policy circumvention, such as undocumented processes overriding claims handlers' estimates, which inflated reported profits and understated liabilities.
Compliance impact
Urgency: High – This action signals intensified CBI scrutiny on individual accountability in insurance reserving, with 13-year bans possible for deliberate breaches risking policyholders, even without actual losses. It matters now (post-1 Dec 2025 effective date) as firms face elevated enforcement risk amid CBI's "full extent of powers" approach, potentially leading to parallel firm/individual sanctions and long inquiries; proactive reviews prevent similar outcomes, especially with statutory fine limits not mitigating non-financial penalties.
New report outlines the Central Bank’s approach to more effective and efficient regulatory and supervisory framework, reducing complexity and improving clarity while maintaining resilience and important protections in the system. This work builds on the Central Bank’s strategy to transform regulation and supervision…
AI Analysis
The Central Bank of Ireland published a comprehensive multi-year roadmap on December 10, 2025, aimed at streamlining its regulatory and supervisory framework across four pillars: supervision, regulation, gatekeeping, and reporting. This initiative represents a strategic shift toward more effective and efficient oversight while explicitly maintaining resilience standards and consumer protections, responding to EU calls for regulatory reform to enhance competitiveness.
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
Good morning everyone. 1 I am delighted to join you here today for this year’s Climate Finance week. “The scientific evidence that climate change is a serious and urgent issue is […] compelling.” “The benefits of strong, early action on climate change outweigh the costs.” And “the choices made in the next 10-20 years…
Why this matters
This speech discusses the macrofinancial effects of climate change in Ireland, including the progress and challenges in reducing greenhouse gas emissions, the relative costs of action versus inaction, the exposure to rising physical risks, and the management of climate-related risks by the financial sector.
The Central Bank of Ireland has today (Monday 14 October) published its Flood Protection Gap Report . Some homes and businesses in Ireland are unable to obtain flood cover. This means that when a flood occurs, there can be a shortfall between the actual cost of the flood and the portion of that cost that is covered by…
Why this matters
This regulatory update from the Central Bank of Ireland focuses on the flood protection gap, which has implications for the banking, insurance, and consumer credit sectors. It discusses prudential and capital requirements, ESG/sustainability, and reporting/disclosure, making it relevant for a range of financial firms.
I’d like to thank Insurance Ireland and Milliman for inviting me here today for this Chief Risk Officer (CRO) Forum. I’d like to use this opportunity to briefly reflect on the recent turmoil we’ve seen in the banking sector, what this might mean for (re)insurers, and to highlight some of our supervisory priorities…
“Review of the Consumer Protection Code: securing customers’ interests” - Remarks by Gerry Cross, Director of Financial Regulation – Policy & Risk, Central Bank of Ireland at Insurance Ireland - KPMG Briefing Session: CBI Review of the Consumer Protection Code
Why this matters
The speech discusses the Central Bank of Ireland's review of the Consumer Protection Code, which is a key regulatory framework governing the conduct of financial firms in their dealings with consumers.
Introduction Good morning everyone. Thank you for inviting me to speak here today. Before I begin, I’d like to acknowledge the important role played by Financial Services Ireland in advocating for its members, and in promoting the Irish financial services sector, both here and abroad. Whilst the respective missions we…
Ban on price walking in motor and home insurance comes into effect on 1 July 2022. New customer discounts not affected. For automatic renewals, better information and reminders to be provided to encourage switching. The Central Bank of Ireland has today published the Central Bank (Supervision and Enforcement) Act 2013…
AI Analysis
The Central Bank of Ireland (CBI) published the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Insurance Requirements) Regulations 2022 on 15 March 2022, banning price walking in motor and home insurance from 1 July 2022 to eliminate loyalty penalties for renewing customers while preserving new customer discounts and competition. This matters for compliance professionals as it imposes immediate prohibitions on differential pricing, mandatory annual reviews, enhanced renewal disclosures, and record-keeping, with CBI emphasizing ongoing oversight to ensure fair consumer outcomes.
Suggested considerations
Pricing Adjustments: Update systems/models to ensure renewal prices ≤ EQFRP; identify close-matched products for comparisons.
Conduct Reviews: Perform comprehensive annual review of pricing policies/processes, documenting compliance, controls, and rectifications; avoid "tick-box" approaches.
Enhance Communications: Revise renewal notices/documents to include mandated info (e.g., price, cancellation rights, switching options); handle pre-1 July notices pragmatically but comply in spirit.
Record Maintenance: Retain written records of reviews, pricing decisions, and compliance evidence for audit readiness.
Internal Governance: Assess/align with CPC General Principle 2.1; monitor for material changes requiring documented consistency checks.
What changed
- Ban on Price Walking: Insurance undertakings and intermediaries cannot charge renewing customers (defined as "relevant renewing customers") a premium higher than that charged to an equivalent...
Annual Pricing Reviews: Firms must conduct an annual review of motor and home insurance pricing policies and processes within two months of each year-end to ensure compliance, including controls to...
Automatic Renewal Disclosures: Firms must provide specific information to consumers before automatic renewals, including renewal price, right to cancel, and options to switch providers, to promote...
Record-Keeping: Written records must be retained for annual reviews, material pricing decisions, and compliance assessments.
Scope Exclusions: Applies prospectively from 1 July 2022; no retrospective application or transitional period.
Compliance impact
Urgency: Medium (as of 2026). The regulations have been effective since 1 July 2022 with no transitional period, requiring immediate system/process overhauls at implementation; non-compliance risks enforcement under Section 48 of the 2013 Act. Ongoing annual reviews and CBI's commitment to monitoring pricing practices sustain medium-term priority, especially amid CBI's consumer protection focus, but established firms likely adapted by now—late compliance or audit gaps remain risks.
Recent increase in cross-border financial assets is largely due to migration of assets from UK banks to subsidiaries in Ireland, to continue to serve EU clients after Brexit. Paper examining the strength of the connectedness of Irish insurance sector and investment funds finds insurers primarily hold shares in equity…
AI Analysis
The Central Bank of Ireland (CBI) published three "Behind the Data" papers on 20 January 2022 analyzing the international activities of Ireland's banking, insurance, investment funds, and non-bank financial intermediation (NBFI) sectors, highlighting post-Brexit asset migrations, insurer exposures via funds, and Ireland's fifth-largest global NBFI sector per FSB metrics. This matters for compliance professionals as it signals heightened CBI scrutiny on cross-border exposures, interconnectedness, and data granularity needs, potentially informing future supervisory expectations, macro-prudential policies, and reporting enhancements without imposing immediate rules.
Key dates
20 January 2022
Publication date of the three Behind the Data papers
Suggested considerations
Review and enhance internal reporting on cross-border assets, distinguishing Irish-parent vs. foreign-parent activities, in anticipation of potential narrower CBI statistics.
Map insurer fund exposures to underlying assets (e.g., equities, bonds) for geographic and asset-class transparency, addressing CBI-noted complexities in fund structures.
Assess NBFI activities against FSB economic functions for stability risks; prepare for possible granular data requests.
Monitor CBI's "Behind the Data" series for evolving trends, as it uses firm-submitted data and fulfills IMF recommendations (e.g., FSAP 2022 on fund exposures).
What changed
No direct regulatory changes, requirements, or new rules are introduced; these are analytical papers using existing locational banking, insurance, and fund data. Key insights include: (i) €180bn surge in cross-border bank assets (2018-Q3 2021) driven by UK-to-Ireland subsidiary migrations post-Brexit, concentrated in loans/deposits, derivatives, and three foreign-parent banks; (ii) Irish insurers' fund holdings primarily in equity (US-issued), bond (euro-area government/corporate), and mixed funds, with ~50% domiciled in Luxembourg but minimal local issuance; (iii) Recommendation for refined...
Compliance impact
Urgency: Low – This is informational analysis from 2022 with no binding rules, deadlines, or enforcement; it matters indirectly by flagging data gaps (e.g., parent distinction) that could shape future CBI supervision, macro-prudential tools, or reporting burdens, especially amid ongoing Brexit/NBFI focus. Firms with foreign parents or fund-heavy portfolios should note for risk monitoring, but no immediate compliance overhaul needed.
Differential Pricing and Business Interruption Insurance demonstrate Central Bank’s focus on conduct, culture and customer treatment Over €130 million paid in business interruption insurance claims to date Insurance sector needs to be prepared for the challenges ahead including digitisation and climate change Speaking…
Why this matters
This regulatory update from the Central Bank of Ireland focuses on the insurance sector, with a emphasis on conduct, culture, and customer treatment, particularly around business interruption insurance and differential pricing. It also discusses the sector's future challenges including digitization and climate change.
Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar Good morning everybody and thank you to Deloitte for the invitation to speak at this webinar. Some people think of insurance as a relatively modern financial concept. But of course, as the insurance experts in this…
Why this matters
I cannot provide the detailed compliance analysis you've requested because the specific regulatory publication you referenced—"Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar" (29 September 2021)—is not included in the search results provided.
The search...
Review finds that differential pricing practices can result in unfair outcomes for some consumers Proposal to ban the practice of ‘price walking’ to end the loyalty penalty for consumers who do not switch insurance provider regularly Proposals will ensure that new business discounts are still available to allow…
AI Analysis
The Central Bank of Ireland (CBI) proposes banning "price walking" in private car and home insurance to eliminate the loyalty penalty, where long-term customers pay significantly higher premiums (14% more for car, 32% more for home after 9 years) than new customers with similar risk profiles. This stems from a 2021 review finding differential pricing unfair to loyal or less mobile consumers, with regulations finalized and effective from 1 July 2022, confirmed effective in subsequent reviews. It matters as it enforces fair treatment under CBI's consumer protection mandate, requiring insurers to overhaul pricing models while preserving new customer discounts to maintain competition.
Key dates
22 October 2021
- Consultation period closes for proposals in the final report
Early 2022
- CBI intends to finalize measures post-consultation
15 March 2022
- Publication of final Insurance Requirements Regulations 2022
1 July 2022
- Regulations apply to insurance undertakings and intermediaries; ban on price walking effective
2023/2024
- CBI review confirms regulations working, no loyalty penalty observed, no further measures needed at that time
Suggested considerations
Pricing model adjustments: Revise systems to ensure renewal premiums ≤ year-one premiums for equivalent risks; test against historical data (e.g., 11 million policy records analyzed).
Disclosure updates: Amend new customer communications to explicitly state "new business discount" inclusion.
Governance and reviews: Implement annual pricing policy reviews with documented evidence of customer impact assessment and fair treatment compliance; integrate into board/CPC oversight.
Renewal processes: Obtain explicit consumer consent for auto-renewals; provide reminders and clear switching info pre-renewal.
Monitoring and reporting: Conduct internal audits; respond to CBI engagements; retain records for supervision.
What changed
- Ban on price walking: Insurers cannot charge second or subsequent renewal customers a higher premium than an equivalent year-one renewal customer with similar risk and service cost.
Disclosure of new business discounts: Firms must clearly disclose to new customers that lower prices include a new business discount.
Annual pricing policy reviews: Providers must review pricing policies yearly to ensure focus on customer impact, adherence to rules, and fair treatment.
Automatic renewals requirements: Introduce consumer consent for automatic renewals and enhanced information/reminders to support informed decisions and switching.
These were implemented via the...
Compliance impact
Urgency: low (as of 2026). Rules have been effective since July 2022, with CBI's 2023/2024 review confirming no loyalty penalties, no unintended consequences, and market stability—Ireland was first EU state with such a ban. Firms compliant since 2022 face ongoing low-risk monitoring; non-compliance risks enforcement under Section 48(1), but positive outcomes reduce immediate pressure. Matters for legacy audits or CPC reviews.
Introduction Good morning, and thank you for attending our Insurance Industry Event, the second of these which we’ve held virtually. Hopefully, as the vaccine rollout continues and restrictions are eased, there won’t have to be a third! The COVID 19 crisis has brought about a significant amount of change to all of our…
Speech delivered at Institute of Directors’ Briefing Webinar on 10 June 2021 Good morning everyone, I am delighted to speak to you on the importance of effective culture in firms, the contribution fitness and probity can make, and how we see the forthcoming Individual Accountability Framework further reinforcing…
AI Analysis
This 2021 speech by Derville Rowland, Director General of Financial Conduct at the Central Bank of Ireland (CBI), emphasizes the critical role of the Fitness & Probity (F&P) regime and the forthcoming Individual Accountability Framework (IAF) in fostering effective culture, governance, and individual responsibility in regulated firms. It matters because it signals CBI's supervisory priorities on senior role holders' competence, integrity, and accountability, which have since evolved into concrete regulatory updates, directly impacting board and compliance functions to mitigate conduct risks and ensure consumer protection. https://www.centralbank.ie/news/article/speech-importance-of-fitness-probity-and-ensuring-responsibility-derville-rowland-10-june-2021
Key dates
22 September 2021
- CBI notice of intention to amend PCFs under F&P regime (e.g., new Designated Persons roles)
20 November 2025
- Effective date for revised Guidance on Fitness and Probity Standards
24 November 2025
- CBI publishes Feedback Statement on CP160, Fitness and Probity Standards 2025, and revised Guidance
Post
amendment (TBD, after regulations effective); - 6-week window for in-situ PCF assessments and confirmations to CBI
Suggested considerations
Conduct thorough F&P due diligence on PCF/CF holders pre-appointment and ongoing (best-efforts for references, criminal/financial checks via public records; assess time commitments case-by-case).
Certify annually that PCF/CF individuals meet standards; no dual certification needed if PCF covers CF-1/2.
Review and update succession planning, handover policies, and conduct breach procedures in light of new PCFs and IAF/SEAR (Statements of Effectiveness and Accountability of Responsibilities).
Assess residency and capacity for non-resident PCF holders case-by-case, considering firm complexity.
Embed F&P into culture and governance frameworks, aligning with IAF Conduct Standards once enacted.[Speech]
What changed
The speech itself outlines no new statutory changes but highlights the F&P regime's role in ensuring "fit and proper" individuals in key roles and previews the IAF as a complementary framework to...
Consolidation of F&P Standards into the Fitness and Probity Standards 2025, applicable across all sectors, read alongside revised Guidance on the Fitness and Probity Standards (effective 20 November...
Amendments to Pre-Approval Controlled Functions (PCFs), adding roles like Designated Person for Investment Management (PCF-39D), Distribution (PCF-39E), and Regulatory Compliance (PCF-39F),...
Clarifications on due diligence (best-efforts basis for references, criminal checks, financial soundness via public records only—no bank statements required), time commitments (case-by-case), and...
Proportionality for fitness assessments but not probity; ongoing certification obligations for Controlled Functions (CFs) and PCFs.
These build on the speech's vision, addressing Enria Report...
Compliance impact
Urgency: High – While the 2021 speech is foundational, 2025 Standards and Guidance are now effective, mandating immediate due diligence enhancements and certifications amid IAF rollout. Non-compliance risks CBI investigations, prohibitions, or sanctions, especially with expanded PCFs tying into broader accountability (e.g., SEAR). This elevates board exposure, demanding proactive governance reviews to align culture with consumer protection mandates.
Opening remarks at the 2020 Insurance Industry Briefing Good morning everyone. I would like to thank you for attending today’s industry briefing. In my remarks this morning, I will take this opportunity to touch on: the role that insurance can play in society; some of the reasons why the industry in Ireland is…
Good afternoon Chairman, Committee members, I am joined by Ed Sibley, Deputy Governor, Prudential Regulation and Derville Rowland, Director General, Financial Conduct. We welcome the opportunity to appear before you today. The effects of the COVID-19 pandemic have been deep and distressing for our community. The…
Why this matters
I cannot provide the analysis you've requested because the document you've referenced is not available in the search results provided. The URL you cited (https://www.centralbank.ie/news/article/speech-introductory-statement-governor-makhlouf-21-oct-20) is from October 21, 2020—a historical speech addressing COVID-19...
I am joined today by Gráinne McEvoy, Director of Consumer Protection, and Domhnall Cullinan, Director of Insurance Supervision. Thank you for this opportunity to speak to you today about the Central Bank’s work in regulating and supervising the Irish insurance industry and specifically the practices of differential…
Insurance conference explores challenges facing the insurance industry Introduction of proposed judicial guidelines on personal injury claims would bring stability to the cost of insurance Solvency II review in 2020 to ensure continued protection of policyholders and beneficiaries The Central Bank hosted a conference…
Why this matters
This regulatory update discusses challenges facing the insurance industry, including the upcoming Solvency II review and the introduction of judicial guidelines on personal injury claims. It is relevant for insurance firms and covers prudential and consumer protection topics.
The Central Bank of Ireland imposes a fine of €3,500,000 on RSA Insurance Ireland DAC for regulatory breaches relating to large loss claims and accounting irregularities On the 18 December 2018, the Central Bank of Ireland (the “ Central Bank ”) reprimanded and fined RSA Insurance Ireland DAC (“ RSAII ” or the “ Firm…
AI Analysis
The Central Bank of Ireland (CBI) fined RSA Insurance Ireland DAC (RSAII) €3.5 million in December 2018 for serious breaches involving failure to maintain adequate technical reserves, inadequate internal controls and accounting procedures, and weak governance, stemming from deliberate under-reserving of large loss claims from 2009 to 2013, which understated reserves by €78.2 million as of 30 September 2013. This enforcement action underscores the CBI's zero-tolerance stance on reserving practices that risk policyholder protection and financial stability, highlighting how governance failures enabled manipulation and led to a significant capital injection for RSAII. It matters for compliance professionals as it demonstrates ongoing CBI scrutiny, with related actions against individuals like former CEO Philip Smith (13-year disqualification in 2025) and a former actuary (5-year prohibition).
Key dates
2009
October 2013; Period of under-reserving breaches and manipulation of large loss claims
30 September 2013
Date of €78.2 million technical reserves understatement
October 2013
CBI identifies issues during scheduled supervisory engagement
2014
CBI investigation into RSAII and individuals (e.g., Philip Smith) begins
December 2018
RSAII admits four breaches; enforcement against firm concludes
Suggested considerations
Conduct reserving process reviews: Ensure claims handlers' recommended estimates are recorded without delay or manipulation; implement independent validation for large loss claims.
Strengthen internal controls: Develop sound administrative/accounting procedures and mechanisms to detect irregularities (e.g., unearned premium adjustments, claims expenses).
Enhance governance: Robustify internal reporting structures per Corporate Governance Code 2010 (Section 6.3); promote ethical culture to prevent individual overrides.
Senior accountability: Boards and executives must oversee compliance; remediate via capital injections if needed, as RSAII did.
Supervisory engagement: Cooperate fully with CBI probes; apply lessons to Solvency II reserving under Article 101 (post-2016).
What changed
This is an enforcement action, not a new regulation, but it reinforces core pre-Solvency II requirements under the European Communities (Non-Life Insurance) Framework Regulations 1994, specifically Article 13(1)(a), mandating firms to establish and maintain technical reserves for all underwriting liabilities. It highlights breaches of the Corporate Governance Code for Credit Institutions and Insurance Undertakings 2010 (Section 6.3), requiring robust governance, internal reporting, and reliable information flows to decision-makers.
Compliance impact
Urgency: Medium – This 2018 action is historical but remains highly relevant due to 2025 individual enforcements, signaling CBI's long-term pursuit of accountability in insurance reserving and governance. It matters because under-reserving risks policyholder losses, financial instability, and capital adequacy (e.g., RSAII's injection), with CBI emphasizing deterrence via maximum fines and disqualifications; firms must self-assess controls to avoid similar scrutiny under Solvency II.
The Central Bank of Ireland has today published a consolidated view of publically available data for insurance and reinsurance firms. Under new Solvency II regulations, firms must provide public disclosures. The public disclosures take the form of a Solvency and Financial Condition Report (SFCR), which firms produce…
Why this matters
This regulatory update is related to the publication of Solvency and Financial Condition Reports (SFCRs) by insurance firms, which is a prudential and reporting requirement under Solvency II regulations. The update is informational in nature and does not indicate any immediate regulatory action.