Semi-Transparent ETFs: Ireland’s New Approach to Portfolio Disclosure
On 17 April 2025, the Central Bank of Ireland (the “Central Bank”) published an updated UCITS Q&A which amends its position in relation to portfolio transparency. The UCITS ETF section in the Q&A, ID 1012, has been updated to set out the new requirements which now apply to portfolio transparency and disclosure of information on the portfolio of a UCITS ETF.
- Published
- in Industry Updates
The New Rules
Under the updated rules, ETFs authorised by the Central Bank can now disclose their portfolio holdings on a daily, or less frequent periodic basis, subject to certain conditions outlined below:
Daily Basis Disclosure:
- Prospectus Information: The prospectus of the ETF must disclose the type of information that will be provided in relation to the portfolio.
- Non-Discriminatory Access: The portfolio information must be made available on a non-discriminatory basis.
Periodic Basis Disclosure:
- Daily Information for Effective Arbitrage: Appropriate information must be disclosed daily to facilitate an effective arbitrage mechanism.
- Prospectus Information: The prospectus of the ETF must disclose the type of information provided to facilitate the effective arbitrage mechanism.
- Non-Discriminatory Access: This information must be made available on a non-discriminatory basis to Authorised Participants and Market Makers.
- Documented Procedures: Procedures must be in place to address circumstances where the arbitrage mechanism of the ETF is impaired and there is an inability to effectively price the ETF.
- Investor Requests: There must be a documented procedure for investors to request portfolio information.
- Quarterly Public Disclosure: The portfolio holdings as at the end of each calendar quarter must be disclosed publicly within 30 business days of the end of the quarter.
A Welcome Development
The Central Bank’s updated rules on ETF portfolio transparency represent a positive development for asset managers looking to launch active ETFs in Europe.
The flexibility in disclosure requirements is expected to enhance the protection of investment strategies and promote the growth of the active ETF market. This is another welcome development at a time when the Maples Group is seeing more active managers seeking to bring their strategies to the European market using the ETF wrapper.
This development follows on from the recent update to the Central Bank’s position regarding the naming convention for UCITS ETFs, permitting this to be at share class, rather than sub-fund level.
Further Information
For further information or assistance with launching an ETF under the new rules, please do not hesitate to contact the Maples ETF team.
