A comprehensive review of the Central Bank of Ireland’s 2026 regulatory agenda

The Central Bank of Ireland's Regulatory and Supervisory Outlook 2026 was published to provide industry with detailed sector specific information on regulatory and supervisory priorities for this year.

Recently, the Investment Funds team in Dublin set out the Central Bank of Ireland's (CBI) views on the 2026 outlook and their regulatory priorities for 2026 as published in an open letter to the Tánaiste and Minister for Finance. You can read our recent publication on the CBI's letter to the Tánaiste here: The Central Bank of Ireland’s 2026 priorities explained | Ogier

This article focuses on the priorities for the Irish funds sector, highlighting areas of regulatory focus and practical tips for meeting supervisory expectations.

The Central Bank of Ireland's overarching priorities 

The CBI's overarching priorities for 2026 include:

• maintaining and building resilience to geopolitical and macro-financial uncertainties

• securing consumer and investor interests

• responding to technological-driven transformations

• addressing environmental and societal transitions

• enhancing regulation and supervision

The CBI's Regulatory and Supervisory Outlook 2026 holds invaluable information for all regulated industry sectors. It provides compliance, risk and legal teams across all regulated firms operating in Ireland with an opportunity to analyse the CBI's priorities and incorporate them into compliance programmes for the year ahead. You can read the full Regulatory and Supervisory Outlook here.

The CBI highlighted the importance and scale of the funds sector in Ireland, referencing that there are 9,100 authorised funds with NAV greater than €5.3 trillion managed by 136 regulated fund management companies and serviced by 65 fund service providers. The CBI will continue firm level supervision for those subject to close and continuous oversight and sectoral level supervision for the remainder of industry.

Central Bank of Ireland's seven focus areas for the Irish funds sector

Governance and risk management 

The CBI plans to conduct reviews across the funds sector to assess whether current governance practices are effective and to determine whether current risk management practices meet required standards. Concerns arise where boards lack sufficient local presence and oversight. Adequate oversight from board level is essential to ensure investor protection. The heart and mind of the organisation should be in Ireland.

Regulatory tip: review current board composition and input to ensure adequate and sufficient local knowledge and authority in decision-making. Regularly review governance frameworks to address gaps, focusing on oversight of outsourced services and delegated management. The CBI expect depositaries to have effective oversight of fund managers and they will be carrying out sectoral reviews focusing on this in 2026.

Operational and cyber resilience

The CBI highlighted that deficient cyber risk frameworks and weak operational resilience structures can increase the likelihood of service disruptions and cyberattacks, in addition to the current geopolitical environment. There should be a focus on enhancing operational risk management and effective scenario testing including business continuity planning. These measures can assist with mitigating the impact of adverse events.

While the CBI has acknowledged that outsourcing, delegation and the use of AI can deliver efficiencies, overreliance can dilute local management control of key activities.

Financial crime risk has been raised as a continued key priority for the CBI. It noted that funds can be exploited and due to the size of Ireland's sector, it is the subject of international scrutiny. For this reason, the CBI will be undertaking thematic reviews of suspicious transaction reporting across the sector and have linked weak IT systems and controls to vulnerabilities.

Regulatory tip: firms should stress test and update business continuity plans to ensure compliance with CBI expectations. A review of current practices and outsourced IT services should be examined to understand dependencies and identify weak points. Fund managers should ensure that third party money laundering reporting officers have sufficient legal knowledge and expertise to effectively analyse and report on suspicious transactions.

Asset valuation and market risks

The CBI's 2026 priority is to review the governance and controls around asset valuation, especially for real estate, private equity / credit and other complex or illiquid securities. Errors in the valuation of portfolio assets can lead to unfair pricing for investors and risks for market stability.

Regulatory tip: maintaining oversight is important for the valuation of assets. Firms should carry out periodic reviews and document findings to ensure unfair practices are avoided and funds are accurately valued, including hard to value assets.

Liquidity and leverage risks

Heightened scrutiny of liquidity and risk management tailored to specific fund's risk profiles will be a point of focus. The CBI intends to focus on how funds align redemption and settlement periods with asset liquidity, the use and operation of liquidity management tools and scenario-based stress testing. Targeted reviews will be conducted on high-leverage alternative funds and sectors facing significant liquidity risks, with an initial focus on Irish authorised bond funds and managers.

In parallel, under Article 25 of AIFMD, the CBI will analyse leverage related systemic risks across funds identifying the most leveraged AIFs to undertake targeted reviews on and their respective Irish AIFMs. This will also include those that manage non-Irish funds.

Regulatory tip: review and strengthen your fund’s liquidity and leverage frameworks, ensuring stress test outcomes drive real-world contingency planning and that liquidity management tools are actively maintained and understood by staff. The compliance teams within AIFMs managing Irish and non-Irish funds should prepare now for upcoming inspections.

Product costs and disclosures

The CBI is committed to investor protection by ensuring products are appropriate for their target market, particularly as complex instruments grow in prevalence. The CBI will scrutinise the transparency, justification and governance around all fees and product disclosures requiring adequate explanation. The CBI expects an investor-centric culture will be essential to protect consumer and investor interests.

Regulatory tip: conduct a comprehensive review of product disclosures and fee structures to ensure that all costs are justified, transparent, and communicated in simple language, backed by robust internal oversight over product design and distribution.

Data and artificial intelligence

Priorities include ensuring the accuracy, completeness, and reliability of data particularly where automation is being used. The CBI will target gaps in data quality, accessibility and AI governance, as observed in recent sectoral reviews.

Regulatory tip: map out and strengthen controls and validation processes across your data management and AI model governance framework, prioritising documentation, ongoing quality checks and risk assessments of all digital and analytics platforms.

Climate and ESG-related risks

The CBI’s focus is on the integration of climate and ESG risk management into authorisation and ongoing supervision, including stringent application of SFDR. The CBI will use advanced data techniques to monitor compliance and market conduct of ESG and climate disclosures to prepare for SFDR 2.0. The CBI highlighted that it is continuing to see regulatory divergence across ESG which can impact consistent application of sustainability standards and market conduct across markets.

Regulatory tip: firms should revisit ESG risk management and disclosure practices to ensure they are robust, up to date with both CBI and European guidance, with a review of upcoming changes being at the forefront of decisions.

The markets and MiFID investment firm sector in Ireland

As the markets and MiFID investment firm sectors are closely correlated to the funds sector, some key takeaways for clients operating these businesses are highlighted below.

Markets sector overview

The CBI has included crypto asset service providers (CASPs) into its market sector, highlighting that in 2026 the CBI will focus on reactive supervision for the newly authorised CASPs, providing them time to deploy their business models. During Q1 2026, the CBI will launch a new quarterly CASP regulatory return, providing them with a detailed view on each CASP's financial position and assist with the level of supervisory engagement required.

The CBI received 300 Title II whitepapers in 2025, exceeding predicted levels. Ogier advised several clients in respect of drafting Title II whitepapers and accompanying legal explanations during 2025. These are detailed documents that are submitted to the local competent authority and on to ESMA for publication. Considering the increasing numbers of whitepapers received by the CBI, they have noted they will fully engage in the ESMA work on MiCA regulation throughout 2026.

The CBI has flagged the high risk associated with inadequate custody and administration of clients' crypto assets and will be following up with recently authorised crypto custodians on their control environment during H2 2026.

Due to the cross-border nature of crypto flows, the CBI has highlighted the increased risk of money laundering and terrorist financing activities. They expect CASPs to maintain effective AML and fraud-prevention controls to mitigate financial crime risks. To supervise this, in H2 2026, trading firms and CASPs will be required to complete an enhanced Risk Evaluation Questionnaire (REQ) capturing quantitative and qualitative risk information on money laundering and terrorist financing controls. The CBI will be carrying out targeted assessments on CASPs during H1 and H2 2026 to ensure effective AML controls and processes.

Market abuse compliance remains a key priority for the CBI across traditional trading environments but also now across crypto trading environments. Targeted market abuse compliance inspections will be carried out on firms and persons discharging managerial responsibilities in H2 2026.

Irish MiFID investment firm sector overview

The CBI has highlighted that operational resilience across the MiFID investment firm sector is maturing but there are varying degrees of maturity with some forms playing reliance on a relatively small number of third part ICT providers. Firms should take the opportunity to review and assess their current operational resilience and enhance these where necessary. The CBI has planned to undertake inspections throughout 2026 and 2027 on SREP category 1 and 2 firms. In addition, all firms will face supervisory assessment of DORA incident reporting and registers.

Managing conflicts of interest particularly where firms have incentivised remuneration models in place is crucial.

The CBI highlighted the increased number of investor complaints and expects firms to demonstrate robust complaint handling processes.

Market abuse and AML compliance are of continued importance to the CBI and inspections in addition to REQs will be expected during 2026 and 2027.

How Ogier can help 

At Ogier, we can analyse your current practices and compliance with the Central Bank of Ireland's 2026 priorities to determine if there are areas for enhancement and to ensure your firm is meeting its obligations and regulatory expectations. Our team of leading lawyers and industry professionals offer practical advice and solutions to ensure your business is ahead of any regulatory scrutiny.