The Central Bank’s 2026 Regulatory & Supervisory Outlook: What Irish Fund Managers Need to Know

The Central Bank of Ireland (“CBI“) has published its Regulatory & Supervisory Outlook Report 2026 (the “Report“), setting out its strategic priorities and planned supervisory activities for the year ahead.

The CBI has identified five overarching priorities for 2026: maintaining resilience to geopolitical risks and macro-financial uncertainties; securing consumer and investor interests; responding to technology-driven transformations, including AI and tokenisation; addressing environmental and societal transitions; and enhancing how the CBI itself regulates and supervises.

For the funds sector specifically, the CBI’s supervisory focus is organised around seven key areas:

• Governance and Risk Management: remains a central concern, with the CBI highlighting risks arising from insufficient board substance or inadequate decision-making capacity. The sectoral assessment of delegation in fund management companies will continue, with the first industry communication expected in the first half of 2026;
• Operational and Cyber Resilience and AML/CFT: compliance continues to attract heightened supervisory attention, including continued focus on implementation of the Digital Operational Resilience Act (“DORA“) and a thematic review of AML transaction monitoring in the funds sector;
• Asset Valuation and Market Risk: the CBI has expressed ongoing concerns about asset valuation, particularly in private assets, and plans a thematic review focusing on hard-to-value assets and level 3 asset controls;
• Liquidity and Leverage Risks: remain a focus, with reviews planned for liquidity risk management in bond funds and leverage reduction in property funds;
• Product Costs and Disclosures: are under scrutiny as funds increasingly engage in complex and alternative investment strategies, including crypto-assets and novel ETF constructions;
• Data and Artificial Intelligence: present emerging risks, and the CBI expects firms utilising third-party AI service providers to maintain appropriate governance and controls frameworks; and
• Climate and ESG-Related Risks: remain a priority, with ongoing work to assess compliance with the Sustainable Finance Disclosure Regulation and the Fund Naming Guidelines.

Robust governance, effective risk management and operational resilience remain consistent supervisory priorities where the CBI will continue to focus over the next year. Firms should proactively review their frameworks across these areas in anticipation of the CBI’s planned thematic reviews and supervisory engagements throughout 2026.