Issue 18 2026
AI Analysis
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. MMF managers are expected to incorporate the resilience levels into liquidity-risk frameworks, stress-testing scenarios, escalation procedures and internal decision-making. Where WLA approaches or falls below the applicable resilience level, managers are expected to exercise enhanced vigilance; where the fund remains below the level for m
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 scrut
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.
What the CBI said
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