Regulatory outlook 2026: the Central Bank of Ireland’s priorities explained

The Central Bank of Ireland have released their regulatory priorities for 2026. How can you prepare for desktop or onsite inspections?

Governor Gabriel Makhlouf of the Central Bank of Ireland's (CBI) wrote to Tánaiste Simon Harris outlining his views on Ireland's macro-financial environment and the financial services industry, in addition to the Central Bank's regulatory and supervisory priorities for 2026. 

This article outlines the CBI's regulatory priorities and flags areas which clients may want to focus their attention on in preparation for desktop or onsite inspections.

The Central Bank of Ireland's economic outlook 

The Governor emphasised the need for both Ireland and Europe to strengthen economic resilience amid ongoing economic, geopolitical and societal changes, despite Ireland's current economic strength.

Read more on the CBI's economic outlook and focus for economic resilience.

The Central Bank of Ireland's supervisory and regulatory priorities for 2026

The CBI's supervisory and regulatory priorities are determined by their statutory mandate, domestic and international responsibilities, and Ireland's large and increasingly complex financial sector.

The four overarching priorities

Maintaining and building resilience to geopolitical and macro-financial uncertainties

The CBI wants to continue strengthening the financial sector's operational resilience to ensure an ability to respond to severe operational disruptions, providing continuity of services for customers. Maintaining this financial resilience can be achieved through assessing credit, market, liquidity and reserving / provisioning risk exposures and risk management practices.

Regulatory tip: Firms can prepare to meet this priority by ensuring a robust operational resilience environment within their respective businesses, mapping against risk management frameworks and carrying out appropriate and realistic scenario testing. This can also form part of the annual risk-based compliance monitoring programme.

You can read more about the Central Bank of Ireland's recent assessment on MiFID firms’ operational resilience in our recent article: Operational resilience - the Central Bank of Ireland’s review of MiFID firms

Securing consumer and investor interests

The CBI's revised Consumer Protection Code (CPC) is coming into effect on the 24 March 2026. This has had a 12-month lead-in period. There will be a focus on ensuring firms have implemented the CPC.

The CBI is also committed to fulfilling its obligations under the Access to Cash Legislation, including publishing regulations around ATM service standards (hours of availability, cash withdrawal limits) and new registration and oversight responsibilities.

Another focus element of consumer protection is the enhancement of the sector's financial crime safeguards including:

• how firms support fraud victims

• raising consumer and investor awareness of fraud and scams

• detection and punishment of unauthorised providers and those engaged in market abuse

Regulatory tip: Firms should assess whether the CPC is in scope, noting the threshold changes being brought in. If in scope, a review on the extent it will impact the business and steps to ensure compliance should be underway, if not near finalised at this point. Looking at financial crime compliance and market abuse, firms should focus on developments from the new Anti-Money Laundering Authority (AMLA) as it continues to publish regulation, implement technical standards and work towards the new single rulebook from the summer of 2027

Market abuse compliance and consumer protection around fraud and scams continues into 2026 as a key focus for the CBI. These should be a regular test on firms' compliance monitoring programmes.

Responding to technological-driven transformations

The CBI continues to focus on the use of AI in the financial sector including authorising and supervising innovative firms. As with other EU competent authorities and the UK FCA, the CBI has been engaging with industry through its Innovation Sandbox Programme, the most recent of which related to the payments sector.

Regulatory tip: Innovation through AI and technology is rapidly developing. Firms should carry out detailed analysis and due diligence on technological advancements that will aid their respective regulatory businesses. Before implementing any technology, it is important to determine whether prior engagement with your supervisory team in the CBI is needed, following internal engagement and analysis across all key stakeholders of your business. This may include legal, compliance, risk, operations, technology and c-suite stakeholders. Additionally, parallel environments are beneficial to run during the initial stages of any such technological developments.

Addressing environmental and societal transitions

The CBI will continue to review how industry has embedded climate and ESG into risk management, business models and governance. The intention is to assess firms' responses to climate-related weather events.

Regulatory tip: ESG should remain a key focus for firms with close attention on developments around SFDR 2.0. This has remained a key priority for the CBI for the last number of years and expectations are that desktop and onsite reviews will be carried out during 2026 and 2027.

A reflection on the Central Bank of Ireland's 2025 priorities

The Governor of the Central Bank included an insightful review of 2025 priorities, highlighting that strong progress had been made in the following areas:

• new integrated supervisory framework, enhancing the existing risk based, outcomes focused approach to supervision

• enhanced Consumer Protection Code

• enhanced Fitness and Probity Regime

• increasing capacity of credit unions to provide mortgages and business loans

• commencement of the Innovation Sandbox Programme

• implementation of the Markets in Crypto Assets Regulation (MiCAR)

• published roadmap for a more effective and efficient regulatory framework

• conducted research and analysis to understand emerging risks and market trends

What does the Central Bank of Ireland expect from firms in 2026?

The CBI is placing a strong emphasis on continuing to build economic resilience due to an increase in uncertainty both domestically and internationally. Firms can expect to see scrutiny of risk management practices and procedures as a result. Scenario testing should be effective, fit for purpose, carried out and documented.

With the approaching deadline for implementation of the revised CPC, in-scope firms should focus on carrying out a gap analysis to ensure they comply with the updated provisions.

Firms using AI across their infrastructure need to be AI literate and ensure that the business has carried out appropriate due diligence prior to implementing changes, linking in with all stakeholders and possibly the supervision team at the CBI.

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 offers practical advice and solutions to ensure your business is ahead of any regulatory scrutiny.

For more information, contact our team via the details provided below.

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice