CBI Consultations

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

5 June 2026 Deadline

- Deadline for stakeholder submissions responding to the 16 questions in DP12

Post

5 June 2026; - CBI to publish a feedback statement assessing responses and existing policy fit. (Source: https://www.centralbank.ie/news/article/press-release-discussion-paper-tokenisation-and-distributed-ledger-technology-in-financial-services-5-march-26 [publication]; https://www.arthurcox.com/insights/central-bank-issues-discussion-paper-on-dlt-tokenisation-in-financial-services/ )

Suggested considerations

• Review DP12 (PDF available via CBI site) and prepare/ submit responses to the 16 questions by 5 June 2026, focusing on legal clarity, risks, funds tokenisation, and enablers like interoperability.
• Engage in CBI's structured stakeholder dialogues to influence future frameworks.
• Assess internal DLT/tokenisation pilots or plans against discussed risks (e.g., operational resilience, scalability) and opportunities (e.g., fractional ownership, 24/7 liquidity).

What changed

This is a non-binding discussion paper, not a regulatory change or new requirement; it poses 16 questions on topics including legal recognition of tokenised instruments, governance, infrastructure, funds (e.g., tokenised MMFs and ETFs), payments, and risks like operational resilience and interoperability. It highlights needs for policy intervention to avoid fragmented "walled gardens," ensure central bank money's role, and address challenges in fractionalisation, transparency, and settlement finality, but no mandates are imposed yet.

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

18 January 2024 Deadline

- Consultation deadline for CP157 on macroprudential measures for GBP LDI funds

29 April 2024

- Announcement and start of three-month implementation period for GBP LDI yield buffer measures

23 July 2024

- Publication of Feedback Statement to DP11 on macroprudential policy for investment funds

29 July 2024 Deadline

- Effective date for GBP LDI funds' minimum 300bps yield buffer compliance (three months post-announcement)

22 November 2024

- CBI response to European Commission consultation on macroprudential policies for NBFI

Suggested considerations

• For property funds: Continue adhering to pre-existing leverage/liquidity mismatch limits.
• All relevant managers: Monitor CBI updates on measure evaluations, conduct ongoing vulnerability analysis, and prepare for potential toolkit expansions (e.g., stress testing, data sharing). Engage in international coordination via FSB/IOSCO and EU consultations.
• General: Review fund strategies for systemic risks, update governance for macroprudential oversight, and align with CBI's DP11 principles.

What changed

• This Feedback Statement introduces no new regulatory changes or requirements; it is a summary of feedback on DP11 and CBI's perspectives on macroprudential considerations for funds.
• Restrictions on leverage and liquidity mismatch for Irish-authorised property funds (introduced prior to 2024).
• A codified minimum 300bps yield buffer for Irish-authorised GBP-denominated Liability Driven Investment (LDI) funds, requiring resilience to UK interest rate shocks, with liquid assets in the buffer...

Key dates

29 April 2024

- CBI announces finalised macroprudential framework

29 July 2024 Deadline

- Compliance deadline for existing Irish GBP-denominated LDI funds authorised before 29 April 2024 (3-month implementation period)

Immediate Deadline

- Compliance requirement for newly authorised LDI funds after 29 April 2024

Ongoing Deadline

- New funds seeking authorisation must notify CBI of framework scope applicability

Suggested considerations

• *For Existing Fund Managers (by 29 July 2024):
• *Audit & Classification: Determine whether each fund falls within the regulatory scope by assessing whether the investment strategy matches asset sensitivity to UK interest rates/inflation against pre-defined investor liabilities
• *Yield Buffer Assessment: Calculate current yield buffer position and identify any shortfalls against the 300 bps minimum threshold
• *Portfolio Restructuring: If necessary, rebalance portfolios to achieve and maintain the 300 bps yield buffer, ensuring:
• Removal of external/third-party assets from buffer calculations

What changed

• The framework establishes the following core requirements for in-scope GBP-denominated LDI funds: Yield Buffer Requirement
• Minimum resilience threshold of 300 basis points increase in UK yields
• CBI clarifies this is a minimum floor, not a target; funds may prudently maintain higher buffers
• Assets must be sufficiently liquid under both normal and stressed market conditions Yield Buffer Composition Rules
• "External assets" or "third-party assets" cannot be included in the yield buffer