Search
Regulatory Round-up

Central Bank of Ireland Update and Supervisory Approach for 2026: Fund Service Providers

In 2026, the Central Bank of Ireland will streamline financial regulation, overhauling gatekeeping, supervision and regulatory reporting. Priorities include simpler rules on governance, outsourcing, AML and data. It will also review the fund service provider framework, align Irish rules with EU law, and implement the new Regulatory Impact Assessment supervision model replacing PRISM.

On 25 November 2025 at the Central Bank of Ireland’s Financial System Conference, Governor Gabriel Makhlouf discussed the Central Bank’s plans for the near future, including its simplification agenda and reviewing frameworks to ensure alignment between Irish rules and EU law, consistency across domestic regimes, and proportionality in how those requirements are applied.  The Central Bank will undertake work across all sectors including in relation to funds, governance, outsourcing, AML, and data reporting, guided by their aim to make regulation clearer, easier to navigate and more straightforward, without weakening the protections provided to consumers and investors or standards of prudence.

On 28 November 2025, the Central Bank announced Karen O’Leary as its new Director of Enforcement.

On 10 December, the Central Bank published “Regulating & Supervising Well – A More Effective and Efficient Framework” which builds on its plans published in February 2025 to introduce a more efficient and effective supervisory approach.  The new report outlines how the Central Bank will, in line with initiatives across Europe, enhance the effectiveness and efficiency of its supervision and domestic regulatory framework, improve gatekeeping processes, and deliver a more integrated and less burdensome reporting and data framework.  Governor Gabriel Makhlouf said “Our objective is straightforward.  We are making regulation and supervision more effective, easier to navigate, proportionate, and aligned with risk, while maintaining the resilience and safeguards that underpin people’s trust in the financial system”.

The Central Bank issued a consultation paper on its new Regulatory Impact Assessment (“RIA“) Framework in H1 2026.  The Central Bank has said that the most significant firms will be subject to close supervisory engagement and continuous assessment across a number of specific risk categories: Business Model & Strategy Risk; Culture, Governance & Risk Management; Operational Resilience Risk; Financial Resilience Risk and Financial Crime Risk. The Central Bank will have a set level of engagement with key individuals in these firms on an annual basis. Each of these firms will continue to have direct communication from their supervision team on supervisory activities for the period ahead.

The changes span four pillars: Supervision, Regulation, Gatekeeping, and Reporting and Data. The Central Bank will shortly undertake a comprehensive review of the fund service provider (“FSP“) framework to ensure that it remains robust and relevant in a post-AIFMD II environment, and is aligned with international expectations. The review will:

  • assess the rules governing management companies and service providers, ensuring they reflect the structures and risk profiles of today’s funds industry
  • update delegation and outsourcing provisions, where necessary, to reflect AIFMD II and EU guidance, balancing operational flexibility with effective oversight
  • streamline and consolidate domestic regulations, guidance, and Q&As, reducing duplication and improving consistency across the funds sector
  • consolidate Q&As and guidance into a structured framework

The Appendix sets out a Roadmap for Delivery of various other workstreams with timelines for each item.  Highlights include:

  • publishing their Regulatory and Supervisory Outlook 2026 to include overview of annual sectoral plans (H1 2026)
  • initial proposals from the FSP Framework Review (delegation, outsourcing, governance) (H1 2026)
  • drafting revised Corporate Governance Codes (H2 2026) with revised codes being published in H1 2027
  • review of potential changes to the PCF list (H2 2026)
  • introducing streamlined authorisation processes for funds, intermediaries and market participants (H2 2026)
  • updating the Cross Industry Guidance on Outsourcing (H2 2026)
  • implementing data discipline-by-design tests for new reporting requests (H2 2026)
  • identifying whether there are domestic regulatory reports which could be merged with others or retired completely (H2 2026)
  • completing a three-year review to assess the scope of application, proportionality, calibration, and operational impact in light of practical experience (H1 2027)

 

Menu