Reporting & Disclosure in Ireland

Key dates

End of 2026

- The ECB Governing Council is expected to make the final decision on the new banknote design

23 July 2026

- The Central Bank of Ireland publishes the press release encouraging public participation in the ECB consultation

21 September 2026

- The public survey on the shortlisted euro banknote designs closes

Suggested considerations

• Review the ECB consultation materials and assess whether your firm has any direct operational exposure to future euro banknote changes.
• Monitor ECB and Central Bank of Ireland updates for the final design decision expected around the end of 2026.
• Prepare internal stakeholder briefings for cash operations, branch operations, payments, customer service, and communications teams on the expected euro banknote redesign timeline.
• If your firm accepts or processes cash, begin a preliminary review of any systems, controls, or vendor dependencies that could be affected by future note specifications, authentication features, or rollout timing.
• Update external messaging and FAQs only after the ECB publishes the final banknote design and implementation details.

What changed

• - The ECB has published ten shortlisted design proposals for the next series of euro banknotes, based on the themes “European culture” and “Rivers and birds.”
• The ECB has opened an online public survey to gather feedback on the proposed designs.
• The survey is open until 21 September 2026.
• The ECB Governing Council is expected to make the final design decision around the end of 2026.
• The current publication does not impose any immediate compliance obligation on firms; it is a consultation and design-selection step, not an enacted regulatory rule.

Key dates

20 July 2017

- The Prospectus Regulation entered into force at EU level

21 July 2019

- The Prospectus Regulation fully applied, and Ireland’s implementing regulations for the regime came into operation

31 March 2022

- New Irish Central Bank fee regulations for prospectus and related document approvals came into operation

7 March 2024

- The Central Bank’s revised Prospectus Regulatory Framework Q&A was published, updating operational guidance on approval, publication, and passporting matters

11 March 2024

- GEM rule amendments took effect for certain retail debt securities listings, providing related market infrastructure context

Suggested considerations

• Review all prospectus templates, disclosure checklists, and approval workflows against the amended Prospectus Regulation provisions that became fully applicable on 5 June 2026.
• Reassess transaction timetables to ensure the planned filing date allows for the 90 working day or 100 working day CBI review window, plus any needed extension request.
• Submit any request for a one-off 30 working day extension before the original approval period expires, and include the required reference details in the request.
• Confirm whether any current or planned issuance qualifies as an SME transaction, because the approval deadline differs from the standard timetable.
• Update internal sign-off procedures so legal, finance, and compliance teams can demonstrate that prospectus materials are prepared in line with the CBI’s statutory mandate and the amended EU framework.

What changed

• - Regulation (EU) 2024/2809 amends elements of the Prospectus Regulation, and those amendments fully took effect on 5 June 2026.
• The Prospectus Regulation continues to apply as the core EU framework for prospectuses, with the CBI acting as the competent authority in Ireland for approval matters.
• The CBI states that it must decide on a prospectus application within 90 working days of receipt of the initial application, or 100 working days for an SME.
• If the review exceeds the applicable working-day limit, the CBI will cease reviewing the prospectus without approving it and will notify the issuer, offeror, or person seeking admission to trading.
• A one-off extension of 30 working days may be requested before the original 90 working-day period lapses, including for SMEs.

Key dates

10 December 2025

– CBI publishes its roadmap “Regulating & Supervising Well – a more effective and efficient framework”, committing to a public consultation on a new Regulatory Impact Assessment (RIA) Framework in H1 2026 and outlining a multi‑year programme of regulatory and supervisory reforms from H1 2026 to H1 2028

22 June 2026

– CBI launches the public consultation on its approach to RIA and stakeholder consultation, alongside references to its new supervisory approach and roadmap of regulatory initiatives

H1 2026

– Target window identified in the roadmap for the public consultation on the new RIA Framework; this is now operationalised by the consultation launched on 22 June 2026

TBD (post‑30 September 2026)

– CBI will consider all submissions and publish a feedback statement setting out its finalised approach to RIA and consultation, which will then guide the design of future regulatory initiatives

H2 2026

– Roadmap foresees drafting of revised Corporate Governance Codes for consultation, which are likely to be shaped by, and potentially used to pilot, the new RIA framework and consultation approach once finalised

Suggested considerations

• Conduct an internal review of your firm’s experience with recent CBI consultations (e.g. Consumer Protection Code, governance, outsourcing, AML, reporting) and document challenges, costs, and data gaps that could be addressed through a more robust RIA and consultation framework.
• Prepare and submit a response to the CBI consultation by 30 September 2026, either directly or via relevant industry associations, setting out detailed expectations on how RIA should address compliance costs, operational impacts, proportionality for smaller firms, and implementation lead times.
• Update your regulatory affairs or public policy strategy to explicitly incorporate the emerging CBI RIA framework, including criteria for when to engage, escalation thresholds for high‑impact proposals, and internal approval processes for consultation submissions.
• For Irish‑authorised groups operating cross‑border, align your approach to CBI RIA engagement with EU‑level impact assessment practices (e.g. European Commission and ESAs) to ensure consistency in messaging and evidence on cumulative regulatory burden and competitiveness.
• Monitor subsequent CBI publications (including the forthcoming feedback statement, revised Corporate Governance Codes, and sectoral plans) to identify where the new RIA framework is being applied and to anticipate where the CBI may seek additional data or structured feedback from firms.

What changed

• - The CBI has opened a public consultation on its approach to Regulatory Impact Assessment (RIA), seeking views on how it should weigh evidence, assess costs and impacts, and structure its analysis...
• The consultation also covers the CBI’s approach to stakeholder consultation, including how it engages with industry, civil society, consumer representatives, the public, policymakers, and peer...
• The initiative sits within the CBI’s broader “more effective and efficient regulatory framework” programme, which includes a new supervisory approach and a roadmap of regulatory initiatives,...
• The CBI aims to make regulation clear, coherent and proportionate, explicitly linking rule‑making to protections for consumers, investors, and financial stability, and to the resilience of the...
• The CBI is moving towards a more structured, transparent, and evidence‑based policymaking process, where the rationale for regulatory interventions, the analysis of options, and the assessment of...

Key dates

January 2025

- New integrated supervisory model became effective

2025

- Strategic review of Industry Funding Levy approach (consultation expected during 2025)

2026

- Public consultation on new Regulatory Impact Assessment Framework

2026 to first half of 2028

- Multi-year programme implementation period for all roadmap initiatives

Suggested considerations

• *Immediate actions for compliance professionals:
• *Monitor consultation releases: Track the Central Bank's website for the 2026 RIA Framework consultation and respond with firm-specific impact assessments
• *Assess rulebook changes: Review how proposed updates to insurance regulations, banking rules, credit union handbook, and fund regulations affect your firm's compliance framework
• *Evaluate supervisory engagement: Understand how the new integrated supervisory model affects your firm's supervisory relationship and reporting lines
• *Prepare for gatekeeping changes: Anticipate enhanced consistency and transparency requirements in authorisation and Fitness & Probity processes

What changed

• The roadmap encompasses four major reform areas: Supervision: Implementation of a new integrated, risk-based supervisory approach introduced in January 2025, consolidating multidisciplinary teams...
• Insurance: Major compatibility review to eliminate duplication with Solvency II reforms and review of 2021 Recovery Planning Regulations
• Banking: Review of domestic banking rules predating CRD V/CRR to ensure consistency with updated EU standards
• Credit Unions: Updates to the Credit Union Handbook following simplification of the Lending Framework
• Funds: Changes to AIF rulebook and UCITS regulation with full review of the Fund Service Provider Framework

Key dates

30 June 2025

– Finance (Provision of Access to Cash Infrastructure) Act 2025 commenced

5 December 2025 – 4 March 2026

– Public consultation period for local deficiency guidelines and ATM service standards

Early 2026

– First publication of quarterly cash infrastructure data expected

2026

– Central Bank to publish final ATM service standards regulations

Q1 2026

– Direct engagement with consumers, people with disabilities, older people, and SMEs

Suggested considerations

• *For designated credit institutions:
• Monitor consultation developments and prepare for compliance with minimum cash infrastructure maintenance levels once regulations are finalized
• Prepare to provide quarterly data on ATM numbers, locations, and availability hours
• *For ATM operators:
• Engage with the consultation process to provide feedback on proposed service standards

What changed

• The consultation covers two primary regulatory components: 1. Local Deficiency Guidelines The Central Bank will establish procedures for identifying geographical areas where individuals and SMEs...
• Hours of ATM availability
• Cash withdrawal limits
• Banknote denomination stocking requirements
• Maximum ATM unavailability periods

Key dates

20 January 2022

Publication date of the three Behind the Data papers

Suggested considerations

• Review and enhance internal reporting on cross-border assets, distinguishing Irish-parent vs. foreign-parent activities, in anticipation of potential narrower CBI statistics.
• Map insurer fund exposures to underlying assets (e.g., equities, bonds) for geographic and asset-class transparency, addressing CBI-noted complexities in fund structures.
• Assess NBFI activities against FSB economic functions for stability risks; prepare for possible granular data requests.
• Monitor CBI's "Behind the Data" series for evolving trends, as it uses firm-submitted data and fulfills IMF recommendations (e.g., FSAP 2022 on fund exposures).

What changed

No direct regulatory changes, requirements, or new rules are introduced; these are analytical papers using existing locational banking, insurance, and fund data. Key insights include: (i) €180bn surge in cross-border bank assets (2018-Q3 2021) driven by UK-to-Ireland subsidiary migrations post-Brexit, concentrated in loans/deposits, derivatives, and three foreign-parent banks; (ii) Irish insurers' fund holdings primarily in equity (US-issued), bond (euro-area government/corporate), and mixed funds, with ~50% domiciled in Luxembourg but minimal local issuance; (iii) Recommendation for refined...

Key dates

2009

October 2013; Period of under-reserving breaches and manipulation of large loss claims

30 September 2013

Date of €78.2 million technical reserves understatement

October 2013

CBI identifies issues during scheduled supervisory engagement

2014

CBI investigation into RSAII and individuals (e.g., Philip Smith) begins

December 2018

RSAII admits four breaches; enforcement against firm concludes

Suggested considerations

• Conduct reserving process reviews: Ensure claims handlers' recommended estimates are recorded without delay or manipulation; implement independent validation for large loss claims.
• Strengthen internal controls: Develop sound administrative/accounting procedures and mechanisms to detect irregularities (e.g., unearned premium adjustments, claims expenses).
• Enhance governance: Robustify internal reporting structures per Corporate Governance Code 2010 (Section 6.3); promote ethical culture to prevent individual overrides.
• Senior accountability: Boards and executives must oversee compliance; remediate via capital injections if needed, as RSAII did.
• Supervisory engagement: Cooperate fully with CBI probes; apply lessons to Solvency II reserving under Article 101 (post-2016).

What changed

This is an enforcement action, not a new regulation, but it reinforces core pre-Solvency II requirements under the European Communities (Non-Life Insurance) Framework Regulations 1994, specifically Article 13(1)(a), mandating firms to establish and maintain technical reserves for all underwriting liabilities. It highlights breaches of the Corporate Governance Code for Credit Institutions and Insurance Undertakings 2010 (Section 6.3), requiring robust governance, internal reporting, and reliable information flows to decision-makers.