“Regulating with purpose – outcomes-focused regulation and supervision, a practitioner’s perspective” – Remarks by Deputy Governor McMunn at Outcomes-focused Regulation in Financial Services conference, University College Dublin (UCD)
Executive Summary
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 frameworks, shifting supervision toward demonstrable outcomes i
Suggested Considerations
- Conduct gap analyses for revised CPC compliance, focusing on thresholds, customer experience, and fraud support (immediate if in-scope).
- Enhance resilience frameworks: Map operational/cyber risks, perform realistic scenario testing, document risk management for geopolitical/macro uncertainties.
- Strengthen financial crime controls: Improve fraud detection, victim support, scam awareness; update AML/CFT via enhanced questionnaires and transaction monitoring.
- Review technology/AI governance: Assess AI models, digital innovations (e.g., tokenisation); engage CBI supervisors pre-implementation; ensure data quality/reliability.
- Embed ESG/climate risks: Integrate into governance/business models; prepare for desktop/onsite reviews and greenwashing checks.
- Funds-specific: Validate Level 3 asset policies/models; monitor liquidity/leverage, product costs/disclosures, NAV calculations.
Key Dates
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 proact
Who is Affected
References
AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.
Summary
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...