CBI Fitness & Probity Thematic Assessment 2026: Key Findings and Actions for MiFID Investment Firms

What you need to know

The Central Bank of Ireland (the “Central Bank”) has published a thematic assessment report (the “Report”) following a review of the implementation of key aspects of the Fitness and Probity regime (the “F&P Regime”) in the MiFID investment firm sector.

While the Report focussed on MiFID investment firms, the findings from the review are equally relevant to other regulated firms subject to the F&P Regime, the Individual Accountability Framework (“IAF”) and, where relevant, the Senior Executive Accountability Regime (“SEAR”).

The Report found that while many firms had sufficiently detailed F&P policies and procedures in place, and a number of firms demonstrated effective implementation in practice, a cohort of firms displayed deficiencies, particularly in relation to the due diligence undertaken at the onboarding stage and as part of the annual certification process for Pre-Approved Controlled Function (“PCF”) role holders.

The Report also assessed the steps taken by firms to embed IAF and SEAR into their governance frameworks, noting that while the majority of firms have taken effective steps, further work is required by some firms to reach the expected level of maturity.

Supervisory Expectations and Findings

The Report identifies both good practices observed and areas requiring enhancement across the following areas:

Policies and Procedures

The Central Bank expects firms to maintain F&P policies and procedures that are up-to-date and sufficiently detailed and implemented in practice. Many firms had such policies in place. However, a cohort of firms did not effectively apply the requirements in practice, with policies lacking sufficient detail on how the firm would meet its obligation to ensure Controlled Function (“CF”) and PCF role holders meet the Fitness and Probity Standards (the “F&P Standards”). In relation to the IAF, some firms’ policy documents lacked specific details on how the firm had tailored its approach to IAF or the actions taken to embed the framework.

Due Diligence and Annual Certification

Some firms were unable to provide sufficient evidence of due diligence completed at the onboarding stage for PCF role holders and/or for the annual certification process. Common gaps included missing signed agreements to comply with the F&P Standards and insufficient documentation of the firm’s assessment of an individual’s competence and capability.

Individual Accountability Framework and SEAR

The majority of firms had taken effective steps to embed the IAF by updating policies and procedures and providing staff training. However, the Central Bank found that certain firms’ policies did not adequately reflect the IAF or document how the firm had tailored its approach in practice. Also, in a SEAR context, some management responsibility maps fell short of the prescribed standards.

Key Actions

The Central Bank expects all MiFID investment firms to review their arrangements, practices, policies and procedures against the findings and feedback outlined in the report.

Although not specifically directed to do so by the Central Bank, for other regulated firms, it would also be prudent to undertake a review and assessment of F&P and IAF policies and procedures against the findings and feedback outlined in the report.

How the Maples Group Can Help

Our Financial Services Regulatory team is available to assist with:

• board briefings on the Report’s findings and implications for your firm;
• gap analysis of your firm’s F&P policies, procedures and practices against the supervisory expectations and findings set out in the Report;
• review and enhancement of due diligence and annual certification processes;
• review of IAF and, where relevant, SEAR frameworks; and
• engagement with the Central Bank in the context of supervisory follow-up.

Further Information

For further information, please liaise with your usual Maples Group contact or any of the persons listed on this page.