Senior Managers / Governance Regulations in Ireland

March 27th 2026

Central Bank Appointments

The Central Bank Commission has appointed Elizabeth Mahon as Secretary of the Central Bank, effective 30 March. Elizabeth has also been appointed to the role of Head of Governance in the Central Bank. Elizabeth has more than 20 years' experience in financial services, principally in the banking sector, where her career has focused on strategy and implementation, management consulting, organisational change, and stakeholder management. Since 2022 she has worked at the Central Bank as Head of S...

Sectors:

Topics:

Prudential / Capital Requirements Senior Managers / Governance Authorisation & Licensing

BankWealth Manager

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🇮🇪 CBI Enforcement medium

February 18th 2026

Institutions, Anchors, and Their Discontents: The Role of Central Banks - Speech by Governor Gabriel Makhlouf to Blavatnik School of Government

It is a pleasure to be here in Oxford 1 While I’m aware that this is a school of government and I’m a central banker, the two are inextricably linked. Societies and indeed economies are shaped by their institutions, specifically the legal, social, cultural, formal and informal norms that impact the way citizens interact with each other. Successful institutions are those that are trusted by the societies that created them and for which they ultimately serve. Today I am going to resist the oppo...

AI Analysis

Governor Gabriel Makhlouf's speech at the Blavatnik School of Government addresses central bank independence as a foundational institutional mechanism for delivering price stability and economic prosperity, rather than as a shield from accountability. The speech is not a regulatory enforcement action or new requirement, but rather a governance statement clarifying the Central Bank of Ireland's institutional philosophy on independence, credibility, and accountability—matters that directly affect how the CBI exercises supervisory discretion over regulated firms.

Sectors:

Banking & Credit Capital Markets & Trading Payments & E-Money

Topics:

Senior Managers / Governance Operational Resilience / Outsourcing Prudential / Capital Requirements

BankAsset ManagerPayment Provider

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🇮🇪 CBI Enforcement medium

February 11th 2026

Reinforcing Resilience, Responding to Change: Priorities for the Year Ahead - Speech by Governor Gabriel Makhlouf to Head of EU Missions

I would like to welcome you all to the Central Bank of Ireland today 1 . We are delighted to host this gathering of EU Heads of Missions, representatives of our friends and partners from across the EU. A little over a year ago I had the pleasure to meet with you all. I spoke then of a geopolitical landscape facing significant strain and complexity; of the rise of economic nationalism and trade disputes; as well as the shift from cooperation to competition, and its impact on our ability to mee...

AI Analysis

This speech by Central Bank of Ireland (CBI) Governor Gabriel Makhlouf outlines priorities for building economic and financial resilience amid geopolitical risks, climate change, technological shifts, and geoeconomic fragmentation, emphasizing domestic policy focus areas like infrastructure, indigenous business growth, and fiscal buffers. It matters for compliance professionals as it previews CBI's forthcoming 2026 regulatory and supervisory priorities, signaling heightened scrutiny on operational and financial resilience, consumer protection, and alignment with a transforming regulatory framework. https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026

What Changed

This is a forward-looking speech, not announcing immediate regulatory changes, but it references CBI's ongoing transformation agenda, including: Four overarching supervisory priorities for 2026: (1) Maintaining/building resilience to geopolitical/macro-financial risks (operational and financial resilience); (2) Securing consumer/investor interests; plus two others implied in related releases (e.g., governance, financial crime).

What You Need To Do

Review and prepare for priorities
Enhance resilience planning
Engage on consultations
Sector-specific
Proactive supervision prep

Key Dates

Next few weeks from 11 February 2026 - Publication of CBI's full 2026 Regulatory and Supervisory Priorities. https://www.centralbank.ie/news/article/speech-governor-makhlouf-head-eu-missions-10-February-2026

H1 2026 - Consultation on new Regulatory Impact Assessment (RIA) Framework. https://maples.com/regulatory-round-up/central-bank-of-ireland-update-and-supervisory-approach-for-2026-fund-service-providers https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf

Shortly (2026) - Launch of comprehensive Fund Service Provider (FSP) Framework review. https://www.centralbank.ie/docs/default-source/regulation/transforming-regulation-and-supervision/regulating-supervising-well-a-more-effective-and-efficient-framework.pdf

2025-2026 - Ongoing implementation of banking/payments supervisory activities and multi-year roadmap (supervision, regulation, gatekeeping, reporting). https://www.matheson.com/insights/fig-top-5-at-5-06-03-2025/ https://www.centralbank.ie/news/article/press-release-central-bank-of-ireland-publishes-roadmap-to-deliver-a-more-effective-and-efficient-regulatory-framework-10-december-2025

Compliance Impact

Urgency: Medium—This speech signals strategic direction rather than enforceable rules, but imminent priorities publication and 2026 consultations demand proactive preparation to avoid intensified supervision/enforcement. It matters because CBI emphasizes resilience in a high-risk environment (geopolitics, AI, climate), with non-compliance risking closer scrutiny under new integrated approach; firms ignoring this could face heightened operational reviews amid efficiency drive without standards reduction. https://www.centralbank.ie/regulation/transforming-regulation-and-supervision

References

Sectors:

Banking & Credit Investment Management Insurance & Pensions

Topics:

Operational Resilience / Outsourcing Prudential / Capital Requirements Senior Managers / Governance

BankAsset ManagerInsurance

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🇮🇪 CBI Enforcement medium

January 14th 2026

Speech by Gerry Cross, Director, Capital Markets and Funds, Central Bank of Ireland at Compliance Institute AGM - Supervising for success: some themes for a time of change

Introduction Good morning and thank you to Michael for inviting me to speak at the Compliance Institute’s Annual General Meeting. It is always a real pleasure to engage with compliance professionals. At the Central Bank, we recognise the essential role played by the compliance community in ensuring that financial firms are well-run and contributing to a financial system that is trusted and resilient. We also recognise the important role played by the compliance institute, equipping those work...

AI Analysis

This speech by Gerry Cross, Director of Capital Markets and Funds at the Central Bank of Ireland (CBI), outlines key supervisory priorities including securing customers' interests via the revised Consumer Protection Code, Individual Accountability Framework (IAF) implementation, regulatory simplification, resilience, technology leverage, and an evolving outcomes-focused supervision approach. It matters because it signals CBI's expectations for compliance professionals to drive these outcomes in firms, emphasizing proportionality and ongoing engagement amid regulatory evolution. Compliance teams must integrate these themes to align with CBI's shift toward less process-driven, more effective oversight.

What Changed

Revised Consumer Protection Code: Introduces new Standards for Business, building on the Code reviewed with industry input; focuses on delivering good outcomes for consumers and the economy. Individual Accountability Framework (IAF): Implemented 18 months prior (circa mid-2024); enhances clarity on responsibilities, supports governance, and aligns with outcomes-focused regulation rather than enforcement-heavy approaches. Supervisory Approach Evolution: Shifting in 2025-2026 to risk-based, outcomes-focused, less process-driven supervision integrated across financial stability, consumer...

What You Need To Do

Implement Revised Consumer Protection Code
Adopt Outcomes-Focused Practices
Engage with CBI
Leverage Technology

Key Dates

24 March 2026 - Revised Consumer Protection Code comes into force; firms must ensure full readiness and ongoing embedding of provisions, including new Standards for Business. DEADLINE

January 2026 speech).

Compliance Impact

Urgency: Medium. This speech reinforces imminent obligations like the 24 March 2026 Consumer Protection Code effective date (less than 2 months from speech/publication), requiring immediate readiness checks, but lacks new rules or critical enforcement threats. It matters for long-term alignment with CBI's outcomes-focused supervision, reducing future supervisory risks through proactive embedding of IAF and simplification; non-engagement could signal poor governance amid evolving oversight.

References

Sectors:

Investment Management Capital Markets & Trading Banking & Credit

Topics:

Consumer Protection / Conduct Senior Managers / Governance Operational Resilience / Outsourcing

Asset ManagerBankAll Firms

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🇮🇪 CBI Enforcement high

December 12th 2025

Public statement relating to Enforcement Action between Central Bank of Ireland and Philip Smith

Mr Philip Smith, former Chief Executive Officer (CEO) and Executive Director of RSA Insurance Ireland DAC disqualified for 13 years by the Central Bank of Ireland for his admitted participation in a breach of financial services law by RSAII On 1 December 2025 the Central Bank of Ireland reprimanded Mr Smith and disqualified him for 13 years from being a person concerned in the management of a regulated financial service provider for his participation in a breach by RSA Insurance Ireland DAC (...

AI Analysis

The Central Bank of Ireland (CBI) reprimanded and disqualified former RSA Insurance Ireland DAC (RSAII) CEO Philip Smith for 13 years from management roles in regulated financial service providers due to his admitted role in under-reserving large loss claims, breaching Article 13(1)(a) of the European Communities (Non-Life Insurance) Framework Regulations 1994 (S.I. No. 359/1994). This enforcement action underscores CBI's commitment to individual accountability for senior executives who circumvent controls, risking policyholder protection and firm solvency, as evidenced by RSAII's subsequent need for a major capital injection. It matters for compliance professionals as it demonstrates CBI's use of prolonged disqualifications and inquiries under the Administrative Sanctions Procedure (ASP) to deter governance failures in insurance firms.

What Changed

This is not a regulatory change or new requirement but an enforcement precedent reinforcing existing obligations under the 1994 Regulations for insurers to maintain adequate technical reserves reflecting true liabilities. It highlights CBI's focus on senior executive accountability for deliberate policy circumvention, such as undocumented processes overriding claims handlers' estimates, which inflated reported profits and understated liabilities.

What You Need To Do

Review senior management oversight of claims handling; document all approvals and prohibit informal (e
Enhance governance training for executives on personal liability under ASP, including simulations of reserving decisions and policyholder risk scenarios
Assess historical exposures for under-reserving; remediate if needed, and prepare for potential CBI inquiries (noting 10+ year investigation timelines)
Update conduct and culture frameworks to align with CBI expectations for CEOs to drive compliance, as per Deputy Governor Colm Kincaid's comments

Key Dates

2014 - CBI enforcement investigation into Mr Smith and RSAII commences.

December 2018 - CBI reprimands and fines RSAII €3.5m for related breaches, including reserve failures.

November 2022 - CBI decides to hold an Inquiry into Mr Smith's participation under Part IIIC of the Central Bank Act 1942.

1 December 2025 - Reprimand and 13-year disqualification imposed on Mr Smith, effective immediately under IAF Act transitional provisions (no High Court confirmation needed).

12 December 2025 - CBI publishes public statement on the enforcement action.

Compliance Impact

Urgency: High – This action signals intensified CBI scrutiny on individual accountability in insurance reserving, with 13-year bans possible for deliberate breaches risking policyholders, even without actual losses. It matters now (post-1 Dec 2025 effective date) as firms face elevated enforcement risk amid CBI's "full extent of powers" approach, potentially leading to parallel firm/individual sanctions and long inquiries; proactive reviews prevent similar outcomes, especially with statutory fine limits not mitigating non-financial penalties.

References

Sectors:

Insurance & Pensions

Topics:

Senior Managers / Governance Consumer Protection / Conduct

InsuranceAll Firms

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🇮🇪 CBI Enforcement medium

September 29th 2021

Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar

Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar Good morning everybody and thank you to Deloitte for the invitation to speak at this webinar. Some people think of insurance as a relatively modern financial concept. But of course, as the insurance experts in this audience know, its origins can be traced all the way back to certain kinds of shipping loans in Babylon, through Ancient Rome and Greece, and into Medieval Europe. In the 17 th ...

Sectors:

Insurance & Pensions

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Senior Managers / Governance

Insurance

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🇮🇪 CBI Enforcement medium

December 20th 2018

Enforcement Action: RSA Insurance Ireland DAC fined €3.5m

The Central Bank of Ireland imposes a fine of €3,500,000 on RSA Insurance Ireland DAC for regulatory breaches relating to large loss claims and accounting irregularities On the 18 December 2018, the Central Bank of Ireland (the “ Central Bank ”) reprimanded and fined RSA Insurance Ireland DAC (“ RSAII ” or the “ Firm ”) €3,500,000 in respect of serious breaches relating to the following: Failure to establish and maintain Technical Reserves in respect of all underwriting liabilities assumed by...

AI Analysis

The Central Bank of Ireland (CBI) fined RSA Insurance Ireland DAC (RSAII) €3.5 million in December 2018 for serious breaches involving failure to maintain adequate technical reserves, inadequate internal controls and accounting procedures, and weak governance, stemming from deliberate under-reserving of large loss claims from 2009 to 2013, which understated reserves by €78.2 million as of 30 September 2013. This enforcement action underscores the CBI's zero-tolerance stance on reserving practices that risk policyholder protection and financial stability, highlighting how governance failures enabled manipulation and led to a significant capital injection for RSAII. It matters for compliance professionals as it demonstrates ongoing CBI scrutiny, with related actions against individuals like former CEO Philip Smith (13-year disqualification in 2025) and a former actuary (5-year prohibition).

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.

What You Need To Do

Conduct reserving process reviews
Strengthen internal controls
Enhance governance
Senior accountability
Supervisory engagement

Key Dates

2009 - October 2013 Period of under-reserving breaches and manipulation of large loss claims.

October 2013 CBI identifies issues during scheduled supervisory engagement.

30 September 2013 Date of €78.2 million technical reserves understatement.

2014 CBI investigation into RSAII and individuals (e.g., Philip Smith) begins.

18 December 2018 CBI reprimands and fines RSAII €3.5 million (settled with 30% discount from €5 million max).

Compliance Impact

Urgency: Medium – This 2018 action is historical but remains highly relevant due to 2025 individual enforcements, signaling CBI's long-term pursuit of accountability in insurance reserving and governance. It matters because under-reserving risks policyholder losses, financial instability, and capital adequacy (e.g., RSAII's injection), with CBI emphasizing deterrence via maximum fines and disqualifications; firms must self-assess controls to avoid similar scrutiny under Solvency II.

References

Sectors:

Insurance & Pensions

Topics:

Prudential / Capital Requirements Senior Managers / Governance Reporting & Disclosure

Insurance

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