Agenda Articles

Following a consultation process on amendments to the Fitness and Probity (“F&P”) regime (“CP160”) which concluded in July 2025, the Central Bank of Ireland (the “CBI”) has published three further key documents in relation to the F&P review: • a Feedback Statement on CP160 (the “Feedback Statement”) (here); • revised Guidance on the Standards of Fitness and Probity (the “F&P Standards”) (here) (effective from 20 November 2025) (the “Finalised Guidance”); and • consolidated Fitness and Probity Standards - Code issued under Section 50 of the Central Bank Reform Act 2010 (here).

Don’t panic if you are called for interview by the Central Bank of Ireland (the “CBI”) as part of your application for approval for a pre-approval controlled function role (a “PCF role”). The CBI has clarified that “an interview by the Central Bank should not be viewed as a negative indicator.”

Directors of regulated financial services providers face an ever-increasing array of obligations, including under the Central Bank (Individual Accountability Framework) Act 2023 (the “IAF Act”). Given the potentially serious consequences for directors if they fail to comply with their duties (e.g. fines, disqualification, imprisonment), it is vital that directors understand and can document compliance with their legal and regulatory obligations.

The Government Legislation Programme for the Spring 2025 session has been published. The Cabinet has approved 21 bills for priority publication and 29 bills for priority drafting. Priority legislation includes the EU Data Regulation Bill, the Media Regulation Bill and the Protection of Employees (Employers’ Insolvency) (Amendment) Bill.

On 30 August 2024, the Department of the Environment, Climate and Communications published the General Scheme for the National Cyber Security Bill 2024 (CSB).

In M.H. v Child and Family Agency, a 2023 ex tempore judgment, the Circuit Court (Court) awarded the plaintiff €7,500 for non-material damages under the General Data Protection Regulation (GDPR).

On 28 January 2026, the Central Bank of Ireland (Central Bank) opened a public consultation (CP166) on draft supplemental guidance (Draft Guidance) relating to prohibition notices issued under the fitness and probity regime (Consultation).

The Irish Screening of Third Country Transactions Act 2023 (the Act) entered into force on 6 January 2025, introducing mandatory notification and pre-clearance for in scope transactions.

In its last quarterly Insurance Newsletter of 2024, the Central Bank of Ireland (Central Bank) provided an update that it has revised its Notification Guidance for (Re)insurance Undertakings when Outsourcing Critical or Important Functions or Activities (CIFA) under Solvency II (Guidance).