Senior Managers / Governance regulatory updates from Ireland.
We track 36 Senior Managers / Governance updates from Ireland regulators, published by CBI. The archive covers 19 speeches, 6 enforcement actions and 6 news items. Most recent update: November 2026. Coverage runs from 2017 to 2026.
Central Bank of Ireland today (Monday 2 November) hosts its annual Financial System Conference at Croke Park in Dublin. It brings together c. 500 delegates including international and domestic policy experts, senior figures from the financial services industry, and stakeholders from across the financial ecosystem. Key…
Why this matters
The press release centres on the Governor's opening remarks and announcements at the conference, so it is classified as a speech. It addresses AI governance and accountability expectations for regulated firms, which supports the Technology & Cyber and Senior Managers / Governance topics.
The Central Bank of Ireland published its CP168 Feedback Statement and final Guidance on Money Market Fund Weekly Liquid Asset levels on 30 October 2026. The Guidance confirms supervisory expectations that Irish-authorised money market funds maintain higher market-resilience WLA levels than the statutory minima under Regulation (EU) 2017/1131, with enhanced vigilance and supervisory engagement where those levels are approached or breached.
Key dates
2026-06-08
The Central Bank published Consultation Paper CP168 on Guidance on Money Market Fund Weekly Liquid Asset levels.
2026-08-03 Deadline
The consultation period for CP168 closed.
2026-10-30
The Central Bank published the CP168 Feedback Statement and final Guidance on Money Market Fund Weekly Liquid Asset levels.
Suggested considerations
Firms should assess each affected fund's current and projected WLA against the 40% resilience level for Public Debt CNAV and LVNAV funds and the 20% level for VNAV funds.
MMF managers may wish to update liquidity-risk frameworks, liquidity monitoring, stress-testing assumptions, escalation triggers and board or risk-committee reporting to reflect the resilience levels.
Compliance and risk teams should document how temporary movements below a resilience level will be assessed in the context of the fund's overall liquidity position, redemption profile, asset liquidity and market conditions.
Managers should establish or validate procedures for prompt escalation and notification to the Central Bank where WLA remains below the applicable resilience level for more than 10 business days or where a prolonged or substantial deviation is anticipated.
Firms should retain evidence supporting WLA calculations, stress-test outputs, escalation decisions, explanations for deviations and communications with the Central Bank.
Fund managers may wish to review liquidity-related disclosures and prospectus language, although independent commentary indicates that the Guidance is primarily expected to require internal liquidity-management changes rather than prospectus amendments.
Irish MMF managers should monitor related developments from the European Commission, ESMA, the French AMF and Luxembourg CSSF because the Guidance forms part of a coordinated European supervisory approach.
What changed
The Guidance expects Public Debt Constant Net Asset Value (CNAV) and Low Volatility Net Asset Value (LVNAV) money market funds to maintain weekly liquid assets (WLA) at a market-resilience level of 40%, and Variable Net Asset Value (VNAV) money market funds to maintain WLA at 20%. These levels exceed the minimum WLA requirements in Article 24 of Regulation (EU) 2017/1131, which are generally 30% for Public Debt CNAV and LVNAV funds and 15% for VNAV funds.
Compliance impact
The impact is material for MMF managers because the supervisory resilience levels are 10 percentage points above the statutory WLA minimum for Public Debt CNAV and LVNAV funds and 5 percentage points above it for VNAV funds. Although the Guidance does not itself amend Regulation (EU) 2017/1131, failure to manage, escalate or explain deviations may result in increased Central Bank supervisory scrutiny and engagement.
Today, the Irish Financial Services Appeals Tribunal (IFSAT) has published its decision in the appeal by Mr David Guinane of the Central Bank Inquiry Decision dated 23 April 2025 concerning permanent tsb plc (PTSB) and Mr David Guinane. The decision of IFSAT was to uphold Mr Guinane’s appeal and overturn the Inquiry…
AI Analysis
The Irish Financial Services Appeals Tribunal upheld David Guinane’s appeal and overturned the Central Bank inquiry decision that he had participated in permanent tsb plc’s breach of the Consumer Protection Code 2006. The Tribunal reportedly identified fundamental errors of law, ultra vires and unreasonable decision-making, inadequate fair notice and insufficient reasons; the Central Bank will not appeal, although it must apply to the High Court for confirmation. The outcome removes the €80,000 fine and reprimand against Mr Guinane and may affect how the Central Bank structures future individual enforcement cases arising from historic conduct.
Key dates
2019-05-30
The Central Bank’s ASP investigation into PTSB concluded; PTSB had admitted 42 regulatory breaches and received a €21 million fine and reprimand.
2023-12-01
The Central Bank published ASP Guidelines providing further detail on its inquiry process; the exact publication day is not specified in the source, so this date denotes December 2023 only.
2025-04-23
The Central Bank Inquiry Decision concerning PTSB and David Guinane was issued.
2026-10-22
IFSAT published its decision, upheld Mr Guinane’s appeal and overturned the Inquiry Decision; the Central Bank stated that it does not propose to appeal.
Suggested considerations
Compliance teams may wish to record the IFSAT outcome in enforcement-risk assessments and monitor the High Court confirmation process.
Banks and mortgage lenders may wish to review open or potential individual-enforcement matters involving historic conduct to confirm that the alleged contraventions, issues for determination, evidential basis and proposed sanctions have been clearly particularised and communicated.
Firms may wish to preserve governance records showing how customer-impact risks, escalation decisions, approvals and follow-up controls were assessed, particularly for tracker mortgage, conduct and legacy remediation matters.
Legal and compliance teams may wish to assess whether the reasoning reported in the decision has implications for ongoing Central Bank inquiries, including fair-notice, statutory-authority, procedural-fairness and reasons requirements.
Firms may wish to distinguish this case from the separate PTSB entity enforcement outcome: PTSB admitted 42 regulatory breaches and received a €21 million fine and reprimand in 2019, which this publication does not overturn.
Firms may wish to track the Central Bank’s external review of wider enforcement activities and any revisions to inquiry procedures, ASP guidance or Individual Accountability Framework implementation.
What changed
No new regulatory obligation or rule has been introduced for firms. The specific inquiry decision against Mr Guinane has been overturned, and the Central Bank does not propose to appeal the IFSAT findings. Independent reporting indicates that IFSAT found the inquiry process and reasoning legally defective, including failures to give fair notice of certain issues and to provide adequate reasons. The Central Bank will apply to the High Court for confirmation of the IFSAT decision under the Central Bank Act 1942.
Compliance impact
The immediate impact is case-specific: the individual sanction against Mr Guinane is overturned, while the separate 2019 PTSB entity sanction remains unaffected by this publication. The decision is nevertheless significant for Central Bank enforcement risk because independent reporting describes findings of fundamental legal and procedural defects, potentially increasing scrutiny of fair notice, statutory authority, evidence, reasoning and proportionality in individual accountability cases.
Remarks by Governor Gabriel Makhlouf on the launch of The Evolution of Bank Governance in the EU
Why this matters
The document is remarks by the Central Bank of Ireland Governor at a book launch, so it is a speech. It discusses board effectiveness, challenge culture, individual accountability, and fitness and probity reforms following the Enria review, which fall under Senior Managers / Governance.
Central Bank of Ireland Governor Gabriel Makhlouf today (Thursday 1 October) spoke at the Irish Funds Annual Global Funds Conference , where he set out why deeper, more integrated European capital markets matter for Irish households and the wider economy. Delivering this requires the financial services sector to take…
Why this matters
This is a speech by the Central Bank of Ireland Governor delivered at an industry conference. While not a binding rule or consultation, it provides noteworthy regulatory signals on three specific resilience priorities: shock resilience, operational resilience (with emphasis on third-party concentration risk and exit...
Good morning. Thank you for the invitation to speak here today. The success of Ireland’s funds sector is well known. Europe’s second-largest fund domicile and a top-three global player, Ireland now hosts €5.6 trillion in investment fund assets and serves investors around the world. This success is a credit to the…
Why this matters
This is a speech by CBI Governor Makhlouf to the Irish funds sector. While informational in nature (urgency: null), it carries significant regulatory signals: (1) explicit supervisory focus on operational resilience culture and third-party service provider concentration risk; (2) acknowledgment of uneven compliance...
The Central Bank today (15 September 2026) announced the appointment of Simon Sloan as Director of Strategy and Governance. Simon brings a wealth of experience from both inside and outside of the Central Bank. Since joining the Central Bank in 2011, he has held a number of leadership roles across Asset Management…
Why this matters
The content is purely administrative—announcing the appointment of Simon Sloan as Director of Strategy and Governance at the Central Bank. It contains no new rules, guidance, enforcement actions, or regulatory requirements affecting financial firms.
Good morning everyone. Thank you for the opportunity to speak to you here today in Croke Park – a place that embodies what can be achieved in Ireland. As the children return to school and the rain settles in, Ireland’s extraordinary summer has finally begun to turn. And it really was extraordinary – the driest on…
Why this matters
This is a speech by Deputy Governor Colm Kincaid to a public sector management conference. It is informational and forward-looking rather than prescriptive, but contains significant strategic guidance on four workplace dimensions (digitalisation, longer careers, lifelong learning/AI, hybrid work) that reflect emerging...
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.
People across Ireland are invited to give their feedback on the shortlisted design proposals for the next series of euro banknotes, unveiled today by the European Central Bank (ECB). These design proposals are based on two different themes – “European culture” and “Rivers and birds” – and on the associated motifs…
AI Analysis
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.
Compliance impact
The immediate compliance impact is low, because this is a consultation and not a binding regulatory requirement. The practical impact may become medium later if the ECB’s final decision triggers operational changes for cash-handling, customer communications, ATM calibration, or banknote lifecycle controls.
Good morning, I am delighted to be here and many thanks to Andrea for the invitation. 1 I very much look forward to the discussion and to hearing from you, but first of all I would like to set the scene with some perspectives on the environment we are operating in. Last month I set out my views on some of the key…
Why this matters
Deputy Governor McMunn's speech addresses governance and delegation practices in Irish fund management companies, with focus on operational resilience, AI governance, and supervisory expectations.
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.
Cathaoirleach and Committee members, thank you for the invitation to be here today. I am joined by my colleagues Deputy Governor for Monetary and Financial Stability, Vasileios Madouros, and Colm Kincaid, Deputy Governor for Consumer and Investor Protection. The Economic Outlook Let me begin with the economic outlook…
AI Analysis
The Central Bank of Ireland (CBI) Governor used this Oireachtas hearing to restate that the CBI will act only within its statutory mandate on prospectus approval, while also signalling that the EU Prospectus Regulation framework has changed materially since 5 June 2026 because of Regulation (EU) 2024/2809. For compliance teams, the key point is that prospectus-related processes, disclosures, and approval planning should now be reviewed against the amended EU regime and the CBI’s existing approval timetable requirements, including the 90 working day decision rule for non-SME prospectuses and 100 working day rule for SMEs.
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.
Compliance impact
Non-compliance risk is high because a failed or delayed prospectus approval can block issuance, delay admission to trading, and disrupt capital raising. Firms also face execution and disclosure risk if they do not align their documentation and timetables to the amended EU regime and the CBI’s approval mechanics.
Central Bank of Ireland has appointed Gavin Curran as Director of Capital Markets and Funds and Max Patanella as Chief Information Officer. Director – Capital Markets and Funds Gavin joined the Central Bank in September 2022 and has been Head of Funds Supervision Division since January 2025. Gavin has over 20 years’…
Why this matters
Press release announcing leadership appointments at Central Bank of Ireland. Director of Capital Markets and Funds will oversee capital markets supervision and funds regulation. Chief Information Officer will manage IT security and technology strategy.
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.
Introduction Good morning, I am delighted to be here and many thanks to Patricia at FSI for the invitation. 1 You have a busy agenda today, discussing some of the key issues currently facing the financial sector and financial regulators. As the title of this conference suggests, we are living through a time of…
Why this matters
Deputy Governor speech outlining CBI's regulatory philosophy on international financial services, gatekeeping processes, and simplification agenda. Addresses authorisation standards, subsidiary governance expectations, and supervisory approach across banking, asset management, and payments sectors.
The Central Bank has today (15 May 2025) announced the appointment of Glenn Calverley to the role of Director of Finance and Business Performance. Mr Calverley will take up his role with effect from 1 September 2026. Glenn brings a wealth of experience to this role, most recently as Director of Strategy & Governance…
Safeguarding Financial Integrity – Central Bank of Ireland’s Approach to Financial Crime Prevention Thank you for the invitation to speak at today’s event. This is an important opportunity for us to engage and share our experiences and approaches to deal with the global challenges and issues we are facing in financial…
Good morning. Brendan, thank you for the warm introduction. It is a pleasure to join you at the ILCU Internal Audit Services Conference. I also want to thank Barry Harrington for the invitation to address you here today. 1 When I addressed the ILCU Annual Conference last April, I spoke about a time of transformative…
Today, the High Court published its written judgment in the matter of the Central Bank’s application under the Fitness & Probity Regime to confirm the one-year prohibition issued to a senior executive on 02 February 2022 concerning his role in a regulated firm in the investment fund and asset management sector. The…
AI Analysis
The Central Bank of Ireland (CBI) issued a statement on 17 April 2026 acknowledging a High Court judgment refusing to confirm a one-year prohibition on a senior executive in the investment fund and asset management sector due to inadequate fair procedures during the CBI's Fitness & Probity (F&P) investigation. This matters for compliance professionals as it underscores the critical need for robust fair procedures in F&P processes and highlights recent legislative and guidance enhancements under the Individual Accountability Framework (IAF) Act 2023 to address such shortcomings. Firms must prioritize these updates to mitigate enforcement risks.
Suggested considerations
Review and implement April 2023 updated F&P Regulations and Guidance to ensure investigations and prohibitions incorporate IAF Act fair procedure safeguards (https://www.centralbank.ie/news/article/press-release-central-bank-statement-on-high-court-judgment-17-april-2026).
Conduct internal audits of F&P processes, focusing on fair procedures (e.g., notice, representation rights) for senior executives in CF/PCF roles.
Monitor and prepare for summer 2026 final guidance from CP-166 on prohibitions; submit any late feedback if applicable.
Train compliance and HR teams on heightened procedural standards, referencing High Court emphasis on fair procedures.
For firms in investment funds/asset management: Assess PCF suitability assessments against consolidated F&P Standards from CP-150.
What changed
- Legislative enhancements via IAF Act 2023: Introduced changes to strengthen CBI's investigation and prohibition powers under the F&P Regime, including additional safeguards for fair procedures in...
Updated Regulations and Guidance (April 2023): CBI published revisions reflecting IAF Act changes, focusing on improved investigation and decision-making processes...
CP-150 Consultation (2025): Led to updated Guidance on consolidated Fitness and Probity Standards, separate from F&P investigations...
CP-166 Consultation on Supplemental Guidance: Public consultation on prohibitions closed 25 March 2026; final guidance expected summer 2026...
Compliance impact
Urgency: High – The High Court ruling directly critiques CBI's past F&P procedures, signaling elevated scrutiny on fair process compliance; failure risks court refusals of prohibitions, reputational damage, and escalated enforcement. With final CP-166 guidance imminent (summer 2026), firms face immediate pressure to align processes, especially post-IAF Act, to avoid similar outcomes in ongoing or future investigations.
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.
The Central Bank Commission has appointed Elizabeth Mahon as Secretary of the Central Bank, effective 30 March. Elizabeth has also been appointed to the role of Head of Governance in the Central Bank. Elizabeth has more than 20 years' experience in financial services, principally in the banking sector, where her…
Why this matters
This regulatory update announces the appointment of new leadership roles at the Central Bank of Ireland, including a new Secretary and Head of Governance. This is a routine organizational change announcement that is likely of low urgency for most financial firms.
It is a pleasure to be here in Oxford 1 While I’m aware that this is a school of government and I’m a central banker, the two are inextricably linked. Societies and indeed economies are shaped by their institutions, specifically the legal, social, cultural, formal and informal norms that impact the way citizens…
AI Analysis
Governor Gabriel Makhlouf's speech at the Blavatnik School of Government addresses central bank independence as a foundational institutional mechanism for delivering price stability and economic prosperity, rather than as a shield from accountability. The speech is not a regulatory enforcement action or new requirement, but rather a governance statement clarifying the Central Bank of Ireland's institutional philosophy on independence, credibility, and accountability—matters that directly affect how the CBI exercises supervisory discretion over regulated firms.
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.
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
Introduction Good morning and thank you to Michael for inviting me to speak at the Compliance Institute’s Annual General Meeting. It is always a real pleasure to engage with compliance professionals. At the Central Bank, we recognise the essential role played by the compliance community in ensuring that financial…
AI Analysis
This speech by Gerry Cross, Director of Capital Markets and Funds at the Central Bank of Ireland (CBI), outlines key supervisory priorities including securing customers' interests via the revised Consumer Protection Code, Individual Accountability Framework (IAF) implementation, regulatory simplification, resilience, technology leverage, and an evolving outcomes-focused supervision approach. It matters because it signals CBI's expectations for compliance professionals to drive these outcomes in firms, emphasizing proportionality and ongoing engagement amid regulatory evolution. Compliance teams must integrate these themes to align with CBI's shift toward less process-driven, more effective oversight.
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...
Compliance impact
Urgency: Medium. This speech reinforces imminent obligations like the 24 March 2026 Consumer Protection Code effective date (less than 2 months from speech/publication), requiring immediate readiness checks, but lacks new rules or critical enforcement threats. It matters for long-term alignment with CBI's outcomes-focused supervision, reducing future supervisory risks through proactive embedding of IAF and simplification; non-engagement could signal poor governance amid evolving oversight.
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.
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…
Gender diversity at senior levels in the regulated financial services sector is increasing but remains insufficient, according to the latest Central Bank of Ireland Demographic Analysis Report . The annual publication analyses applications to hold certain senior roles within regulated firms that require the Central…
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...
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…
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…
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.
Report breaks down applications for regulatory approval by age, gender and country of origin. The Central Bank remains concerned by the continued evidence of a lack of diversity at senior level in regulated firms. Some small improvements in banking, asset management and credit union sectors, but overall percentage of…
Why this matters
This is a press release and data publication from the Central Bank of Ireland announcing demographic analysis of 3,600+ applications for senior role approvals under the Fitness and Probity regime.
Settlement Agreement between the Central Bank of Ireland and Merrion Stockbrokers Limited Merrion Stockbrokers Limited fined €200,000 by the Central Bank of Ireland in respect of failings pursuant to the Fitness and Probity regime. On 12 December 2017, the Central Bank of Ireland (the ‘Central Bank’) fined Merrion…
AI Analysis
The Central Bank of Ireland (CBI) fined Merrion Stockbrokers Limited €200,000 on 12 December 2017 for breaching section 21 of the Central Bank Reform Act 2010 by failing to implement adequate systems and controls under the Fitness and Probity (F&P) regime from 1 December 2011 to at least April 2015. This first-ever enforcement action against a firm for section 21 violations underscores firms' primary responsibility for ongoing due diligence on Controlled Functions (CFs) and Pre-Approval Controlled Functions (PCFs), signaling heightened CBI scrutiny on governance and accountability post-financial crisis.
Key dates
1 December 2011
- Fitness and Probity regime effective; Merrion's breach period begins
Late 2014 Deadline
- Management buy-out and new Board appointed; initial compliance improvements start
24 April 2015
- Merrion implements first written F&P policies and procedures
2016
- CBI inspection identifies breaches
12 December 2017
- CBI imposes €200,000 fine and reprimand via settlement agreement; investigation closed
Suggested considerations
Develop/improve written policies and procedures for initial and ongoing due diligence on CFs/PCFs, including centralized records per individual.
Conduct thorough due diligence at appointment and continuously monitor compliance with F&P Standards; maintain demonstrable records.
Ensure accurate CF/PCF classification for all relevant roles (e.g., executive directors, finance heads, client advisors).
Implement monitoring systems to detect changes in fitness/probity and report to CBI if Standards are breached.
Board-level oversight: Review and remediate gaps, as post-2016 Merrion Board did.
What changed
This 2017 enforcement does not introduce new regulatory changes but enforces existing requirements under the F&P regime, established via the Central Bank Reform Act 2010 and effective from 1 December...
Firms must maintain adequate systems and procedures for initial and ongoing due diligence to ensure CFs/PCFs meet F&P Standards (fitness: competence, integrity; probity: honesty).
Ongoing monitoring beyond initial checks, with written records and centralized documentation for each individual.
Accurate classification of roles as CFs/PCFs; failure here constituted a breach. No subsequent statutory changes are noted in the publication, but it reinforces that firms bear ultimate...
Compliance impact
Urgency: Medium - While from 2017, this foundational enforcement remains highly relevant for ongoing F&P obligations, with risks of fines/reprimands during CBI inspections (as in Merrion's 2016 review). It matters because firms hold primary accountability for a regime designed post-crisis to prevent unfit individuals in key roles; non-compliance exposes entities to significant reputational, financial (€200k precedent), and operational risks, especially amid evolving governance scrutiny.