Good afternoon and welcome to this Central Bank of Ireland workshop on the Consumer Protection Code. Today I will focus on the outlook for consumers and investors. But first let me pause to talk a little about the broader context in which we find ourselves. We are living through a period marked by extraordinary change, geopolitical instability, rapid technological transformation and shifting economic conditions. Governor Makhlouf summarised this well when he said how 2026 has already seen ext...
AI Analysis
Deputy Governor Colm Kincaid's speech on 24 March 2026 emphasizes consumer protection as central to the Central Bank of Ireland's (CBI) mission amid geopolitical, technological, and economic changes, highlighting the revised **Consumer Protection Code 2025** (CPC 2025) as a key modernization effort. This matters for compliance professionals because the CPC 2025 introduces enhanced, digitally-focused protections effective **24 March 2026**, replacing the 2012 Code after a 12-month implementation period, with firms required to proactively secure customer interests.
What Changed
The CPC 2025 comprises Standards for Business Regulations (governance, resources, risk management, conduct standards) and Consumer Protection Regulations (cross-sectoral and sector-specific rules for consumers). Major updates include:
Core obligation: Firms must "secure customers’ interests," shifting to a proactive, customer-focused mindset.
Cross-sectoral requirements: Knowing the consumer/suitability; conflicts of interest/remuneration; vulnerable consumers (updated definition); digitalisation (customer-focused design); effective informing (beyond disclosure); charges/regulatory status...
What You Need To Do
Gap analysis
Policy/system updates
Governance/risk
Testing/monitoring
Stakeholder engagement
Key Dates
24 March 2025- CBI publishes revised CPC 2025, Standards for Business Regulations, Consumer Protection Regulations, and guidance.
24 March 2026- CPC 2025 takes effect; existing 2012 Code ceases (12-month implementation period ends).
Until 24 March 2026- 2012 Code (with addenda) remains in force.
Compliance Impact
Urgency: High – With effectiveness today (24 March 2026), firms face immediate non-compliance risk as the 12-month window closes; CBI supervision will intensify on digital/fraud/vulnerability protections amid heightened risks (e.g., cyber, scams). Non-adherence risks enforcement under CBI's powers, reputational damage, and fines, especially as this "gold-plates" EU rules in a volatile environment.
Good morning everyone, I am delighted to be here for what looks set to be an interesting conference on a topic which is both very close to my heart and central to what we do at Central Bank of Ireland (“the Central Bank”) – as we work to deliver on our mission, and in particular ensuring the financial system is operating in the best interests of consumers and the wider economy. 1 I am particularly delighted to be back in UCD – where I had the pleasure to study economics as an undergraduate, w...
AI Analysis
This speech by Deputy Governor Mary Elizabeth McMunn outlines the Central Bank of Ireland's (CBI) shift toward **outcomes-focused regulation and supervision**, emphasizing five key priorities from the 2026 Regulatory and Supervisory Outlook (RSO) to address geopolitical risks, consumer protection, technology, and resilience in a volatile environment. It matters for compliance professionals as it signals intensified CBI scrutiny on firm behaviors and outcomes rather than mere rule compliance, with direct implications for supervisory engagements, thematic reviews, and enforcement across banking, funds, insurance, and payments sectors.
What Changed
No new legislative changes are introduced in the speech itself, which serves as a practitioner's perspective on implementing the RSO 2026 priorities. It reinforces an outcomes-focused approach, prioritizing:
Resilience to geopolitical/macro risks (operational resilience, cyber security, financial resilience).
Consumer/investor protection (customer experience, digitalisation risks, financial crime/fraud).
Technology transformations (AI, digital money, tokenisation).
These build on prior developments like the revised Consumer Protection Code (CPC), DORA implementation, and enhanced AML/CFT...
What You Need To Do
Conduct gap analyses for revised CPC compliance, focusing on thresholds, customer experience, and fraud support (immediate if in-scope)
Enhance resilience frameworks
Strengthen financial crime controls
Review technology/AI governance
Embed ESG/climate risks
Key Dates
24 March 2026- Revised Consumer Protection Code (CPC) takes effect (12-month lead-in complete; firms must be compliant).DEADLINE
H1–H2 2026- DORA implementation including threat-led penetration testing (survey issued H1).
H1 2026–H2 2027- Thematic inspection of transaction monitoring and STR reporting.
H1–H2 2026- UCITS Value at Risk (VaR) model review and depositary oversight.
Compliance Impact
Urgency: High – The speech, delivered today (9 March 2026), underscores imminent RSO 2026 execution with CPC effective in 2 weeks (24 March 2026) and H1 2026 activities (e.g., DORA testing, AML questionnaires) starting soon. Non-compliance risks intensified supervision, thematic inspections, enforcement, and reputational damage in a high-geopolitical-risk environment; outcomes-focus demands proactive evidence of resilience and consumer safeguards over procedural box-ticking.
The Central Bank has today published its Regulatory & Supervisory Outlook 2026 , which sets out its latest assessment of the risk landscape facing the financial sector and the supervisory work it will undertake in response. This follows on from the Governor’s letter to the Tánaiste on the economic outlook and regulatory priorities in January . This is the third year of the report, which continues to be set against a backdrop of a changing, uncertain and increasingly complex external environme...
AI Analysis
The Central Bank of Ireland (CBI) has published its **Regulatory & Supervisory Outlook 2026**, outlining priorities shaped by geoeconomic fragmentation, technological acceleration, and elevated risks like operational resilience, cyber threats, data/AI, and consumer protection. This matters for compliance professionals as it signals intensified supervisory scrutiny, including desktop and onsite inspections, across Ireland's financial sector to ensure resilience and adaptability amid uncertainties.[https://www.centralbank.ie/news/article/press-release-central-bank-sets-out-its-regulatory-and-supervisory-priorities-26-february-2026][https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
What Changed
No new binding regulatory requirements are introduced in this publication, which serves as a strategic outlook rather than enforceable rules. Key shifts in risk assessment include elevated operational risks (due to geopolitics, digitalisation, complex models), increased asset valuation/market risks, and rising data/models/AI risks, while inflation/interest rate risks have decreased.
What You Need To Do
Conduct robust scenario testing and risk assessments for operational resilience, cyber threats, credit/market/liquidity risks, and document outcomes within compliance monitoring programs
Implement revised CPC by 24 March 2026, assessing scope changes and business impacts
Enhance financial crime controls, including fraud victim support, scam awareness, and market abuse detection; monitor AMLA developments
Embed ESG/climate risks into governance, risk management, and business models, preparing for SFDR 2
Review AI/data/models usage and operational frameworks for supervisory inspections; engage with CBI Innovation Sandbox if applicable
Key Dates
24 March 2026- Revised Consumer Protection Code (CPC) takes effect, following 12-month lead-in; firms must ensure full implementation.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]DEADLINE
H1 2026- CBI 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]
2026-2027- Ongoing desktop/onsite reviews on operational resilience, ESG/climate, and supervisory priorities across sectors.[https://www.ogier.com/news-and-insights/insights/regulatory-outlook-2026-the-central-bank-of-ireland-s-priorities-explained/]
Compliance Impact
Urgency: High – This outlook directly previews intensified 2026 supervision, with operational/cyber resilience and consumer protection as "key concerns" likely triggering unannounced inspections and enforcement. Firms risk findings on outdated resilience testing or CPC gaps, especially amid elevated risks; proactive alignment now prevents remediation costs and sanctions, given CBI's efficiency roadmap and international...
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.
What Changed
This is not a regulatory change document but a governance clarification with compliance implications:
Reframing of independence: Central bank independence is characterized as an "anchor" enabling long-term decision-making rather than isolation from society.
Credibility framework: Credibility depends on competence, engagement, coherence, and public trust—not institutional distance alone.
Accountability emphasis: Independence requires continuous dialogue with society and other economic governance institutions; it "does not mean isolation."
Historical validation: The speech references the...
What You Need To Do
*Understand CBI decision-making philosophy
*Engage constructively with supervisors
*Align governance with credibility principles
*Monitor 2026 supervisory priorities
Key Dates
10 February 2026- CBI published its 2026 Regulatory and Supervisory Priorities, which establish the operational framework within which this governance philosophy applies
18 February 2026- This speech delivered, reinforcing institutional independence principles
Second half 2026- Ireland assumes EU Council Presidency; CBI will support government during this period
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
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 2026speech).
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.
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.
New report outlines the Central Bank’s approach to more effective and efficient regulatory and supervisory framework, reducing complexity and improving clarity while maintaining resilience and important protections in the system. This work builds on the Central Bank’s strategy to transform regulation and supervision, including the introduction of our new integrated supervisory approach and the improvements made in our gatekeeping processes in recent years. The roadmap sets out a comprehensive...
AI Analysis
The Central Bank of Ireland published a comprehensive multi-year roadmap on December 10, 2025, aimed at streamlining its regulatory and supervisory framework across four pillars: supervision, regulation, gatekeeping, and reporting. This initiative represents a strategic shift toward more effective and efficient oversight while explicitly maintaining resilience standards and consumer protections, responding to EU calls for regulatory reform to enhance competitiveness.
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 and sharpening risk focus with clearer supervisory communications. This delivers more coherent firm engagement, stronger proportionality, and streamlined processes.
*Regulation: Comprehensive updates to the domestic rulebook, including:
Insurance: Major compatibility review to eliminate duplication with Solvency II reforms and review of 2021 Recovery Planning Regulations
Banking: Review of...
What You Need To Do
*Immediate actions for compliance professionals
*Monitor consultation releases
*Assess rulebook changes
*Evaluate supervisory engagement
*Prepare for gatekeeping changes
Key Dates
January 2025- New integrated supervisory model became effective
2026- Public consultation on new Regulatory Impact Assessment Framework
2026 to first half of 2028- Multi-year programme implementation period for all roadmap initiatives
2025- Strategic review of Industry Funding Levy approach (consultation expected during 2025)
The Central Bank of Ireland has fined Coinbase Europe Limited €21,464,734 for breaching its anti-money laundering and counter terrorist financing transaction monitoring obligations between 2021 and 2025. The Central Bank of Ireland (the Central Bank) has fined Coinbase Europe Limited (Coinbase Europe) €21,464,734 for breaching its anti-money laundering (AML) and combatting terrorist financing (CFT) obligations with respect to transaction monitoring as required by the Criminal Justice (Money L...
AI Analysis
The Central Bank of Ireland (CBI) fined Coinbase Europe Limited €21,464,734 for AML/CFT transaction monitoring failures under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010), involving over 30 million unmonitored transactions worth €176 billion from April 2021 to March 2025. This marks CBI's first enforcement against a crypto firm, highlighting regulators' focus on robust real-time monitoring and timely Suspicious Transaction Reporting (STR) for virtual asset service providers (VASPs). It matters as it sets a precedent for EU crypto compliance amid MiCA and AMLA implementation, signaling increased scrutiny and potential multimillion-euro penalties for similar lapses.
What Changed
This is an enforcement action, not new legislation, but it reinforces existing CJA 2010 requirements for VASPs: ongoing transaction monitoring, immediate STR filing to the Financial Intelligence Unit (FIU) and Revenue Commissioners upon suspicion of money laundering or terrorist financing, and adoption of internal policies/controls to prevent/detect financial crime.
What You Need To Do
Conduct Gap Analysis
Enhance Controls
Accelerate STR Processes
Board/Compliance Reporting
Third-Party Review
Key Dates
23 April 2021 - 19 March 2025Period of breaches, including 12-month window of unmonitored €176 billion transactions.
5 November 2025Settlement reached between CBI and Coinbase Europe.
6 November 2025CBI public announcement and Settlement Notice published.
12 January 2026High Court confirmed sanctions, making them final and effective.
CJA 2010obligations remain perpetual.
Compliance Impact
Urgency: High – This establishes a €21.5m benchmark for VASP monitoring failures in the EU, with risks amplified by MiCA (effective 2024) and AMLA (2025 onward), where national regulators like CBI will enforce harmonized rules. Firms risk similar fines (30% settlement discount possible), reputational damage, and operational restrictions if unmonitored volumes exceed 1-5%; immediate reviews are essential given CBI's precedent and cross-EU applicability.
Warning Unauthorised Investment Firm / Unauthorised Investment Business Firm Unauthorised Firm Name Monument Financial Group Website https://monumentfg.com/ Email addresses used admin@monumentfg.com [name].[surname]@monumentfg.com Phone number used +353 81 800 5284 Authorisation in Ireland This firm is not authorised to provide investment services in Ireland. Notes: Any person wishing to contact the Central Bank with information regarding such firms / persons may telephone (01) 224 5800 or re...
AI Analysis
The Central Bank of Ireland (CBI) has issued a warning notice under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, identifying **Monument Financial Group** as an unauthorised firm providing investment services in Ireland without authorisation. This matters for compliance professionals because it underscores the CBI's proactive enforcement against unauthorised activity, heightens scam awareness, and signals risks of consumer harm, regulatory referrals to An Garda Síochána, and potential enforcement against facilitating parties.[https://www.centralbank.ie/news/article/monument-financial-group---central-bank-of-ireland-issues-warning-on-unauthorised-firm]
What Changed
This is not a regulatory change or new requirement but an enforcement action via a warning notice published on 25 August 2025. It publicly names the firm, its website (https://monumentfg.com/), emails (admin@monumentfg.com, [name].[surname]@monumentfg.com), and phone (+353 81 800 5284), confirming it lacks authorisation for investment services in Ireland.
What You Need To Do
Immediate verification
Client communications
Internal compliance
Key Dates
25 August 2025- Warning notice published by CBI, adding Monument Financial Group to the unauthorised firms list.[https://www.centralbank.ie/news/article/monument-financial-group---central-bank-of-ireland-issues-warning-on-unauthorised-firm]
Compliance Impact
Urgency: Medium. This matters as part of a pattern of CBI warnings (e.g., Expert Limited on 19 June 2025, RCE Banque on 29 August 2025, DotBig on 01 December 2025), indicating rising unauthorised investment activity and scam risks in Ireland. Authorised firms face indirect liability for poor due diligence, reputational damage, or facilitation charges; consumers risk total fund loss without regulatory protections.
It has come to the attention of the Central Bank that a scam entity by the name SEI Investment (United States, Ireland), formerly operating the fraudulent clone website www.seiinvestment.com, has been claiming to be an investment firm / investment business firm in the absence of appropriate authorisations. In this instance, the scam entity cloned details and website content of the legitimate firm, SEI Investments (www.seic.com), in order to deceive consumers. The legitimate firm was proactive...
AI Analysis
The Central Bank of Ireland (CBI) issued a warning on 26 September 2022 about a fraudulent entity named "SEI Investment (United States, Ireland)" that cloned the legitimate authorised firm SEI Investments (www.seic.com) via the fake website www.seiinvestment.com to deceive consumers into unauthorised investment services. This matters because it highlights the rising threat of clone firm scams, which impersonate authorised entities using stolen details like names, addresses, and authorisation numbers, exposing firms to reputational risk and consumers to financial loss without Investor Compensation Scheme protection. Authorised firms must remain vigilant in monitoring for clones and reporting them promptly, as demonstrated by SEI Investments' proactive response that led to the site's deactivation in February 2022.
What Changed
This is not a regulatory change or new requirement but a public enforcement warning under Section 53 of the Central Bank (Supervision and Enforcement) Act 2013, emphasising ongoing enforcement against unauthorised firms providing regulated financial services, which is a criminal offence. It reinforces consumer protection guidance without introducing new rules, but signals CBI's heightened focus on clone firm frauds, as seen in similar warnings (e.g., The Capital Holdings clone, Bank of Ireland clones).
What You Need To Do
Monitor for clones
Client communications
Internal processes
Public reporting
Key Dates
26 September 2022- CBI issues warning notice on SEI Investment clone.
February 2022- Fraudulent clone website www.seiinvestment.com deactivated following legitimate firm's report.
Compliance Impact
Urgency: Medium – Not critical as the specific clone site was deactivated in 2022, but medium due to persistent clone fraud trend evidenced by ongoing CBI warnings into 2026 (e.g., BW Financial Services clone in August 2025, Stalwart Investments clone in March 2026). Matters for authorised firms as it underscores reputational, operational resilience, and consumer protection obligations under CBI's supervisory framework; unaddressed clones can lead to client complaints, enforcement scrutiny, or compensation claims if mis-sold products are linked back erroneously.
Ban on price walking in motor and home insurance comes into effect on 1 July 2022. New customer discounts not affected. For automatic renewals, better information and reminders to be provided to encourage switching. The Central Bank of Ireland has today published the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Insurance Requirements) Regulations 2022 which will apply to insurance undertakings and insurance intermediaries from 1 July 2022. The Central Bank identified d...
AI Analysis
The Central Bank of Ireland (CBI) published the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Insurance Requirements) Regulations 2022 on 15 March 2022, banning price walking in motor and home insurance from 1 July 2022 to eliminate loyalty penalties for renewing customers while preserving new customer discounts and competition. This matters for compliance professionals as it imposes immediate prohibitions on differential pricing, mandatory annual reviews, enhanced renewal disclosures, and record-keeping, with CBI emphasizing ongoing oversight to ensure fair consumer outcomes.
What Changed
Ban on Price Walking: Insurance undertakings and intermediaries cannot charge renewing customers (defined as "relevant renewing customers") a premium higher than that charged to an equivalent year-one renewal consumer (EQFRP) for motor and home insurance policies. New customer discounts remain permitted to support competition.
Annual Pricing Reviews: Firms must conduct an annual review of motor and home insurance pricing policies and processes within two months of each year-end to ensure compliance, including controls to prevent price walking and adherence to Consumer Protection Code (CPC)...
What You Need To Do
Pricing Adjustments
Conduct Reviews
Enhance Communications
Record Maintenance
Internal Governance
Compliance Impact
Urgency: Medium (as of 2026). The regulations have been effective since 1 July 2022 with no transitional period, requiring immediate system/process overhauls at implementation; non-compliance risks enforcement under Section 48 of the 2013 Act. Ongoing annual reviews and CBI's commitment to monitoring pricing practices sustain medium-term priority, especially amid CBI's consumer protection focus, but established firms likely adapted by now—late compliance or audit gaps remain risks.
Recent increase in cross-border financial assets is largely due to migration of assets from UK banks to subsidiaries in Ireland, to continue to serve EU clients after Brexit. Paper examining the strength of the connectedness of Irish insurance sector and investment funds finds insurers primarily hold shares in equity, bond, and mixed funds. The Irish non-bank financial intermediation sector – as measured using a Financial Stability Board framework - is the fifth largest in the world. The Cent...
AI Analysis
The Central Bank of Ireland (CBI) published three "Behind the Data" papers on 20 January 2022 analyzing the international activities of Ireland's banking, insurance, investment funds, and non-bank financial intermediation (NBFI) sectors, highlighting post-Brexit asset migrations, insurer exposures via funds, and Ireland's fifth-largest global NBFI sector per FSB metrics. This matters for compliance professionals as it signals heightened CBI scrutiny on cross-border exposures, interconnectedness, and data granularity needs, potentially informing future supervisory expectations, macro-prudential policies, and reporting enhancements without imposing immediate rules.
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...
What You Need To Do
Review and enhance internal reporting on cross-border assets, distinguishing Irish-parent vs
Map insurer fund exposures to underlying assets (e
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
Key Dates
20 January 2022 - Publication date of the three Behind the Data papers.
Compliance Impact
Urgency: Low – This is informational analysis from 2022 with no binding rules, deadlines, or enforcement; it matters indirectly by flagging data gaps (e.g., parent distinction) that could shape future CBI supervision, macro-prudential tools, or reporting burdens, especially amid ongoing Brexit/NBFI focus. Firms with foreign parents or fund-heavy portfolios should note for risk monitoring, but no immediate compliance overhaul needed.
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 ...
Review finds that differential pricing practices can result in unfair outcomes for some consumers Proposal to ban the practice of ‘price walking’ to end the loyalty penalty for consumers who do not switch insurance provider regularly Proposals will ensure that new business discounts are still available to allow consumers to seek the best prices, while ensuring that those who remain with the same insurance provider are not penalized The Central Bank is proposing to ban the practice of price wa...
AI Analysis
The Central Bank of Ireland (CBI) proposes banning "price walking" in private car and home insurance to eliminate the loyalty penalty, where long-term customers pay significantly higher premiums (14% more for car, 32% more for home after 9 years) than new customers with similar risk profiles. This stems from a 2021 review finding differential pricing unfair to loyal or less mobile consumers, with regulations finalized and effective from 1 July 2022, confirmed effective in subsequent reviews. It matters as it enforces fair treatment under CBI's consumer protection mandate, requiring insurers to overhaul pricing models while preserving new customer discounts to maintain competition.
What Changed
Ban on price walking: Insurers cannot charge second or subsequent renewal customers a higher premium than an equivalent year-one renewal customer with similar risk and service cost.
Disclosure of new business discounts: Firms must clearly disclose to new customers that lower prices include a new business discount.
Annual pricing policy reviews: Providers must review pricing policies yearly to ensure focus on customer impact, adherence to rules, and fair treatment.
Automatic renewals requirements: Introduce consumer consent for automatic renewals and enhanced information/reminders to support...
What You Need To Do
Pricing model adjustments
Disclosure updates
Governance and reviews
Renewal processes
Monitoring and reporting
Key Dates
22 October 2021- Consultation period closes for proposals in the final report.
Early 2022- CBI intends to finalize measures post-consultation.
15 March 2022- Publication of final Insurance Requirements Regulations 2022.
1 July 2022- Regulations apply to insurance undertakings and intermediaries; ban on price walking effective.
2023/2024- CBI review confirms regulations working, no loyalty penalty observed, no further measures needed at that time.
Compliance Impact
Urgency: low (as of 2026). Rules have been effective since July 2022, with CBI's 2023/2024 review confirming no loyalty penalties, no unintended consequences, and market stability—Ireland was first EU state with such a ban. Firms compliant since 2022 face ongoing low-risk monitoring; non-compliance risks enforcement under Section 48(1), but positive outcomes reduce immediate pressure. Matters for legacy audits or CPC reviews.
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 2013Period of under-reserving breaches and manipulation of large loss claims.
October 2013CBI identifies issues during scheduled supervisory engagement.
30 September 2013Date of €78.2 million technical reserves understatement.
2014CBI investigation into RSAII and individuals (e.g., Philip Smith) begins.
18 December 2018CBI 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.
Five Crises Ábhar mór bróid dom an léacht seo a thabhairt in onóir an Dochtúra T.K. Whitaker. Agus mar bharr ar sin, é bheith i láthair anocht. It is a great honour to be asked to deliver this lecture in honour of Dr. Ken Whitaker, all the more so in his presence. Go maire sé an céad! Or even better, as the Yiddish saying goes, ‘biz hundert un tsvantsik’. Economic crises often prompt us to look backwards and, perhaps, to seek solace in parallels and precedents in the past. Just as rising unem...
AI Analysis
This 2011 Whitaker Lecture by Professor Cormac O'Grada, hosted by the Central Bank of Ireland (CBI), is an academic speech analyzing five historical economic crises in Ireland, including the Economic War, WWII Emergency, 1950s downturn, and others, to contextualize the post-2008 financial crisis. It lacks any regulatory changes, enforcement actions, or compliance mandates, serving instead as reflective economic history rather than a binding publication. Compliance professionals need not action it directly, but it offers historical perspective on crisis resilience relevant to risk management and governance discussions.
What Changed
There are no regulatory changes, new requirements, or enforcement directives in this publication. The content is purely historical and analytical, discussing past Irish economic crises (e.g., net emigration peaks during 1934-38 Economic War and 1943 WWII Emergency) without proposing or announcing policy shifts.[User Provided Content]
Key Dates
29 June 2011.[User Provided Content]
Compliance Impact
Urgency: Low – This is a non-regulatory academic lecture with no immediate or ongoing compliance implications. It matters peripherally for firms emphasizing long-term economic history in prudential risk frameworks or governance training, but misclassification as "enforcement" (per query) overstates its relevance in 2026.