Asset Management Essentials: Ireland - Q3 2026

Central Bank delegation review

The Central Bank published its findings of its thematic review of delegation practices among fund management companies authorised in Ireland (the Delegation Review).

The Delegation Review found that fund management companies generally have good governance frameworks, controls, oversight processes and data capabilities in place. However, it also identified several areas requiring enhancement, including board independence, over-reliance on group-level committees, resourcing concerns, insufficient contingency planning and limitations with data access.

The Central Bank’s findings are organised across five themes: governance, portfolio management, risk management, delegate oversight and data capabilities. For each theme, the Delegation Review sets out supervisory expectations together with examples of good practice and areas requiring improvement. You can read more in our article: Central Bank of Ireland delegation Review – key considerations for Irish fund management companies

Key actions to take: All fund management companies should review the Delegation Review’s findings with input from their board and conduct a gap analysis against the supervisory expectations and observations it sets out. Fund management companies should put in place a time-bound plan by the end of 2026 to address any gaps identified in their operational, resourcing and governance arrangements in respect of delegation, ensuring alignment with all relevant rules and guidance.

Thematic assessment – depositaries' risk assessment obligations

On 11 May 2026, the Central Bank issued a letter to all CEOs and branch managers of depositaries setting out the findings of its thematic review of how depositaries apply the relevant UCITS and AIFMD requirements when assessing the risks associated with a fund’s investment objective and strategy and the organisation of a fund management company (FMC), both at onboarding and on an ongoing basis. The review found deficiencies in the controls established by some depositaries to undertake risk assessments effectively and to identify conflicts of interest and includes a non-exhaustive list of good practices observed.

Key actions to take: All depositaries should undertake a review of their risk assessment frameworks against the Central Bank’s findings to ensure alignment between regulatory expectations and processes in place.

UCITS Regulations 2026 – EMIR counterparty risk-spreading rules

European Union (Undertakings for Collective Investment in Transferable Securities) (Amendment) (No. 2) Regulations 2026 (S.I. No. 289 of 2026): these Regulations came into operation on 25 June 2026 and transpose the revised UCITS counterparty risk-spreading rules introduced under the EMIR 3.0 Directive. Non-centrally cleared derivatives entered into by an Irish UCITS must now be taken into account when calculating counterparty risk exposure for the purposes of the UCITS counterparty risk limits.

Key actions to take: UCITS managers should review related prospectus disclosures and depositary agreement provisions an align with new rules, where required.

Ireland's Presidency of the Council of the EU

Ireland assumed the Presidency of the Council of the EU on 1 July 2026 for a term running to 31 December 2026. The Irish Government has confirmed that its funds-relevant priorities include advancing the Savings and Investments Union (SIU) and seeking to conclude negotiations on the EU’s Market Integration and Supervision Package during its term. The Taoiseach has indicated that consensus on the SIU may be achievable before the end of 2026.

Key actions to take: Firms should monitor the Irish Presidency’s agenda, as progress on the SIU and the market integration files could materially affect cross-border fund operations.

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Central Bank consultation on guidance on money market fund weekly liquid assets and the EU Money Market Funds Regulation review

On 8 June 2026, the Central Bank published Consultation Paper 168 (CP168) proposing guidance on the minimum weekly liquid asset (WLA) levels that money market funds (MMFs) should maintain to strengthen the liquidity available in times of stress. The[NM1] proposed levels are consistent with the European Commission’s report on the MMF Regulation (published on 11 May 2026 with an accompanying FAQ), which identified WLA resilience levels of 40% for stable NAV MMFs and 20% for VNAV MMFs. The consultation closed on 3 August 2026.

Separately, ESMA has consulted on a new framework for publishing its annually updated stress test scenario parameters under the MMF Regulation, responses were due by 6 August 2026.

On 26 May 2026, the Central Bank published a Notice of Intention on the application of ESMA’s 2025 guidelines on stress test scenarios for MMFs The guidelines apply from 26 May 2026 and the Central Bank expects compliance by that date. ESMA has indicated that the guidelines will be updated at least annually to reflect market developments.

Key actions to take: Pending the outcomes of the consultations, MMF managers may need to assess their WLA levels and liquidity risk frameworks against CP168, the Commission’s resilience levels and any guidance that follows. MMF managers should ensure their stress testing frameworks reflect the 2025 ESMA guidelines and update them as ESMA revises them.

Consultation on Regulatory Impact Assessments and the Central Bank’s approach to consultation (CP170)

On 22 June 2026, the Central Bank published Consultation Paper 170 (CP170) seeking feedback on a draft Statement of Approach to Regulatory Impact Assessment (RIA) and a proposed updated approach to public consultation.[NM2] The consultation forms part of the Central Bank’s ongoing work to deliver a more effective and efficient regulatory framework, building on its recently published supervisory approach and roadmap of regulatory initiatives. Governor Makhlouf noted that the consultation is about “strengthening that process: setting out, more clearly and consistently, how we weigh evidence, assess costs and impacts and reach judgements, so that the regulation we deliver is well-founded and well understood.” CP170 does not introduce new regulatory requirements. The consultation closes on 30 September 2026.

Key actions to take: Firms should consider responding to CP170 by 30 September 2026.

Fitness and Probity review – 2026 report on implementation of recommendations

In June 2026, the Central Bank published its Fitness and Probity review report on the implementation of the recommendations from the F&P Gatekeeping Review conducted in 2024. The report concludes that all 12 recommendations from that review have been successfully implemented, and includes a schedule setting out each recommendation and the associated implementation output.

Key actions to take: Depositaries should review their risk assessment and conflicts of interest frameworks against the Central Bank's findings and the good practices identified, and remediate any gaps.

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Financial stability assessment of the Irish hedge funds sector

In April 2026, the Central Bank published its Financial Stability Risk Assessment of Irish Hedge Funds. The Central Bank recognises that hedge funds support liquidity and price discovery, but notes that their use of leverage could pose financial stability risks through fire sales or counterparty losses, with relative value and credit strategies displaying particular vulnerabilities due to high leverage and / or low liquidity. The assessment will inform the Central Bank’s macroprudential surveillance and ongoing supervisory engagement with the sector.

Key actions to take: Managers of leveraged hedge fund strategies should review their leverage and liquidity risk management in light of the Central Bank’s findings and anticipate continued supervisory focus in this area.

Thematic assessment – compliance function in the MiFID investment firm sector

The Central Bank published its Compliance Function Assessment Industry Report 2026 following a thematic assessment of the compliance function in the MiFID investment firm sector.

The Central Bank identified weaknesses requiring remediation, including a lack of effective succession planning and contingency arrangements to ensure the permanence and effectiveness of the compliance function, and the absence of compliance-led training programmes. The report sets out the Central Bank’s expectations of firms and their boards regarding the design and operating effectiveness of a robust compliance function, and the next steps firms should take.

Key actions to take: Although directed at MiFID investment firms, the findings are also relevant to fund management companies. Firms should assess their compliance function against Central Bank expectations, with particular attention to succession planning, contingency arrangements and training.

Application of ESMA Guidelines on Liquidity Management Tools

On 7 May 2026, the Central Bank published a Notice of Intention on the application of the ESMA Guidelines on Liquidity Management Tools of UCITS and open-ended AIFs.[NM3] While the ESMA Guidelines provide that managers should consider one quantitative-based tool and one anti-dilution tool, the Central Bank expects managers to use one of each, except where a derogation applies.

Key actions to take: Managers should review their selection of liquidity management tools against the Central Bank’s expectation of one quantitative-based tool and one anti-dilution tool, and document the basis for any derogation.

Prohibition Notices

The Central Bank published a press release regarding the High Court decision in the Central Bank of Ireland v. CD. The Central Bank has now also issued its Supplemental Guidance on Prohibition Notices under the Fitness and Probity Regime.

Key actions to take: The judgment provides useful clarity on the Central Bank’s prohibition notice procedures under the Fitness and Probity regime. Firms should review the supplemental guidance and monitor how the Central Bank’s approach develops, including in light of its related consultation on prohibition notices.

Guidance for the Fund Metadata Return

The Central Bank has published Guidance for the Fund Metadata Return. This serves as a practical guide to the reporting requirements for Irish authorised investment funds and to navigating and using the Central Bank’s portal.

Central Bank Annual Report and Performance Statement 2025

On 5 June 2026, the Central Bank published its Annual Report and Performance Statement for 2025 setting out its supervisory and enforcement activity and priorities over the past year.

Updated approach to supervision

In May 2026, the Central Bank published an updated version of its Approach to Supervision document. The updated version clarifies the Central Bank’s supervisory approach in a number of areas and contains some notable updates for regulated firms.

Governor's Pre-Budget Letter 2027

On 13 July 2026, the Central Bank published the Governor’s annual Pre-Budget Letter to the Tánaiste and Minister for Finance ahead of Budget 2027. The letter underscores the importance of building economic resilience amid heightened global uncertainty, highlighting five priority areas:

• growing supply-side capacity (including housing and infrastructure)
• strengthening the indigenous business sector
• building fiscal buffers through prudent fiscal policy
• supporting household resilience by enabling greater retail participation in financial markets
• strengthening Europe’s economic infrastructure

The Governor warned of emerging fiscal pressures, noting the increasing reliance on corporation tax receipts (23% of total revenue, with 10 companies responsible for 56% of receipts in 2025) and called for a binding domestic fiscal framework.

Key actions to take: The letter provides useful macro-economic context for fund boards on the Irish fiscal outlook, corporation tax concentration risk and the Government’s approach to retail investor participation — all of which may inform strategic planning and investor communications.

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Irish legislative updates

Upcoming changes

Changes to Framework Governing Provision of Financial Services Remotely

Directive (EU) 2023/2673 has now been transposed into Irish law by the European Union (Distance Contracts for Financial Services) Regulations 2026 (S.I. No. 309 of 2026). The Regulations insert a new Part 5A into the Consumer Rights Act 2022.

Key actions to take: Firms that provide consumer financial services at a distance, such as online or telephone sales of financial products to consumers, should confirm whether their activities fall within the new Part 5A of the Consumer Rights Act 2022 and update their pre-contractual disclosures, cancellation processes (including any online cancellation function) and client documentation accordingly.

Funds Review 2030 and Finance Act 2025

As part of Budget 2026, the Finance Act 2025 reduced the rate of tax applying to Irish and equivalent offshore funds, and to Irish and foreign life assurance products, from 41% to 38%. This forms part of the Government’s response to the Funds Review 2030 report, which is aimed at keeping Ireland’s investment funds sector resilient and internationally competitive.

Key actions to take: Managers and product providers should factor the reduced 38% rate into product design and investor communications, and monitor the forthcoming roadmap and IREF consultation for further changes to the funds tax framework.

National Treasury Management Agency (Miscellaneous Provisions) Act 2026 – dissolution of NAMA

The National Treasury Management Agency (NTMA) (Miscellaneous Provisions) Act 2026 (No. 22 of 2026), enacted on 15 July 2026, provides for the dissolution of the National Asset Management Agency (NAMA) and the transfer of its assets, rights, liabilities, obligations, causes of action and entitlements to the NTMA.

Key actions to take: This marks the wind-down of the State’s post-crisis “bad bank”, with NAMA now dissolved and its residual portfolios transferred to the NTMA from 1 August 2026.

Arbitration (Amendment) Act 2026

The Arbitration (Amendment) Act 2026 (No. 13 of 2026), enacted on 17 June 2026, amends the Arbitration Act 2010 to enable effect to be given in the State to certain international agreements concerned with the protection of investment.

Key actions to take: Managers and funds that make cross-border investments protected under CETA, the EU–Chile agreement or similar investment-protection treaties should note the clearer route to enforcing investment-treaty arbitral awards in Ireland, subject to the constitutional and EU-law safeguards.

New Irish Statutory Instruments (S.I.s)

S.I. No. 290 of 2026: European Union (Investment Firms) (Amendment) Regulations 2026 came into operation on 25 June 2026 and give further effect to the Investment Firms Directive (Directive (EU) 2019/2034) as amended by Directive (EU) 2024/2994. They introduce requirements for investment firms to identify, manage and report concentration risk arising from exposures to central counterparties, and empower the Central Bank to require firms to reduce or realign such exposures.

S.I. No. 317 of 2026: European Union (Transparency and Integrity of Environmental, Social and Governance (ESG) Rating Activities) Regulations 2026 give effect to the ESG Ratings Regulation (Regulation (EU) 2024/3005) and designate the Central Bank as the competent authority in the State.

S.I. No. 335 of 2026: European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) (Amendment) Regulations 2026 give effect to Articles 11, 12, 13 and 15 of the Sixth Anti-Money Laundering Directive (Directive (EU) 2024/1640), introducing a ‘legitimate interest’ basis for access to the Central Register of Beneficial Ownership of Trusts, together with revised timelines and safeguards for such access.

S.I. No. 307 of 2026: European Union (Money Laundering and Terrorist Financing) (Administrative Sanctions) Regulations 2026 came into operation on 30 June 2026 and give effect to the Sixth Anti-Money Laundering Directive by inserting a new administrative sanctions regime into the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.

S.I. No. 348 of 2026 and S.I. No. 321 of 2026 amend the Central Bank’s industry funding levy.

S.I. No. 318 of 2026: Stamp Duty (Designation of Exchanges and Markets) Regulations 2026 came into operation on 8 July 2026 and designate certain additional markets for the purposes of the intermediary stamp-duty exemption under section 75 of the Stamp Duties Consolidation Act 1999.

S.I. No. 365 of 2026: European Union (Restrictive Measures against Cyber-attacks threatening the Union or its Member States) (No. 3) Regulations 2026 provide for the enforcement in the State of the EU cyber-attacks sanctions regime under Council Regulation (EU) 2019/796, including offences and penalties for breach.

S.I. No. 440 of 2025: European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) (Amendment) (No.2) Regulations 2025 came into operation on 1 October 2025. They amend the European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021 (S.I. No. 194/2021) and introduce new obligations on designated persons where details of a relevant trust have not been registered in the Central Register of Beneficial Ownership of Trusts.

S.I. No. 147/2024: Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Senior Executive Accountability Regime) Regulations 2024, which give effect to the Central Bank’s Senior Executive Accountability Regime (SEAR) by specifying the aspects of a regulated financial service provider’s affairs for which a PCF holder has inherent responsibility, and the arrangements a regulated financial service provider is to adopt.

S.I. No. 20/2025 and S.I. No. 12/2025: European Union (Digital Operational Resilience) Regulations 2025 and European Union (Digital Operational Resilience) (No. 2) Regulations 2025, which give effect to Directive (EU) 2022/2556 as regards digital operational resilience for the financial sector and designate the Central Bank as the competent authority in the State for DORA purposes.

S.I. No. 41/2025: European Union (European Green Bonds Standards and Disclosures) Regulations 2025, which provide for the entry into force of the European Green Bonds Regulation ((EU) 2023/2631) and give the Central Bank the necessary competent authority powers for enforcement, sanctions and appeals in respect of green bonds and optional sustainability-linked bond disclosures.

S.I. No. 21/2025: European Union (Investment Firms) (Amendment) Regulations 2025, which give further effect to Directive (EU) 2019/2034 on the prudential supervision of investment firms and amend the European Union (Investment Firms) Regulations 2021 and the European Union (Capital Requirements) Regulations 2014.

Key actions to take: FMCs and their boards should note the SEAR governance requirements applicable to PCF holders, confirm the Central Bank’s role as DORA competent authority when preparing ICT risk management and register submissions, and consider the relevance of the green bonds and investment firms prudential frameworks where applicable to their activities.

S.I. No. 311 of 2025: European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) (Amendment) Regulations 2025 came into operation on 10 July 2025. They amend the 2021 Trust Beneficial Ownership Regulations to align with AMLD6, clarifying who can access beneficial ownership information and under what conditions.

Key actions to take: Firms should ensure their MiFID market-data and order-handling procedures and their AML / trust beneficial ownership processes reflect these amendments, including the updated access and registration obligations for trusts.

SFDR 2.0 – Council negotiating position and PEPP

On 24 June 2026, the Council of the EU adopted its negotiating position on the SFDR 2.0 proposals. The Council’s position would, among other things, require all categorised funds to report on a minimum number of principal adverse impact (PAI) indicators, clarify the exclusion criteria for ‘transition’ products (including limited investment in fossil fuel companies that allocate sufficient CAPEX to taxonomy-aligned activities and follow a time-bound decarbonisation strategy), and provide an opt-out from the categorisation framework for QIAIFs. The European Parliament’s Economic and Monetary Affairs Committee (ECON) is expected to vote on its position in September 2026, with trilogue negotiations anticipated under the Irish Presidency. The Council also agreed its position on reform of the Pan-European Personal Pension Product (PEPP).

Market Integration and Supervision Package (MISP) – ECON draft reports

The Commission’s package to integrate EU financial markets has progressed. On 11 June 2026, the European Parliament’s ECON committee published draft reports proposing amendments to the three legislative files:

• the omnibus directive amending the UCITS Directive, AIFMD and MiFID II
• the omnibus regulation amending fourteen financial services regulations (including the Cross-Border Distribution of Funds Regulation, EMIR and the ESMA Regulation)
• the regulation replacing the Settlement Finality Directive

The deadline for ECON members to table amendments is 16 July 2026, and the Irish Presidency has confirmed it aims to conclude negotiations during its term.

EU Retail Investment Strategy – Council position and value for money

On 5 June 2026, the Council of the EU endorsed the final compromise text of the EU Retail Investment Strategy (RIS). The compromise is understood to introduce, under the UCITS and AIFMD frameworks, obligations to carry out undue cost assessments (before launch and periodically), a documented "value-for-money" assessment benchmarking funds marketed to retail investors against comparable EU funds, and an annual assessment of whether undue costs have been charged, with reimbursement of affected investors. The European Parliament is expected to vote at its November 2026 plenary, and the new rules are likely to apply from early 2029 at the earliest.

Key actions to take: Fund manufacturers should prepare for the value-for-money and undue cost assessment obligations, including the data and peer-comparison capabilities they will require.

EU AI Act – amendments and guidance

On 29 June 2026, the Council approved amendments to the EU AI Act aimed at simplifying the framework. The amendments delay the application of the rules for high-risk AI systems (to 2 December 2027 for stand-alone high-risk systems and 2 August 2028 for high-risk systems embedded in products) and move the deadline for transparency (watermarking) obligations for AI-generated content to 2 December 2026.

The European Commission has also published draft guidelines on the classification of high-risk AI systems (19 May 2026) and, through the EU AI Office, a Code of Practice on transparency obligations (10 June 2026). In Ireland, the National Cyber Security Centre published guidance on securing AI adoption on 30 June 2026.

Separately, Ireland’s Regulation of Artificial Intelligence Bill 2026, which will give full effect to the EU AI Act domestically (including establishing an AI Office of Ireland and empowering the Central Bank to use its existing administrative sanctions procedures for AI Act breaches via amendments to the Central Bank Act 1942), is before Dáil Éireann at Stage 1 (as at 19 June 2026).

Key actions to take: Firms deploying AI should factor the revised timelines into their implementation plans and review governance, transparency and cyber-security controls against the new guidance.

The European Single Access Point

The European Single Access Point (ESAP) Framework is a centralised platform, managed by the European Securities and Markets Authority housing required disclosures for entities under the EU financial services regulations. A new statutory instrument, S.I. No. 322 of 2026, has been introduced under the ESAP Framework (S.I. No. 322 of 2026): European Union (European Single Access Point) (No.4) Regulations 2026 amend S.I. No. 33 of 2026 (the ESAP Omnibus Directive regulations) by correcting the reference in section 33ANF(2) from “investment holding company” to “insurance holding company” and related entities, enabling the Central Bank’s enforcement capabilities in relation to insurance holding companies, administrators and liquidators.

Capital Requirements Directive VI (CRD VI) – Irish transposition

The Capital Requirements Directive VI (CRD VI) has now been transposed into Irish law by the European Union (Capital Requirements) (Amendment) Regulations 2026 (S.I. No. 326 of 2026), giving further effect to Directive 2013/36/EU as amended by Directive (EU) 2024/1619. Transposition followed the deadline of 10 January 2026 and the European Commission’s announcement on 27 March 2026 of infringement action against 22 Member States, including Ireland, for failure to fully transpose CRD VI. The EBA is expected to publish further CRD VI guidelines later in 2026.

Key features of the transposing regulations include:

• a harmonised authorisation and prudential framework for third-country branches carrying on banking activities in the state, with class 1 and class 2 branches subject to minimum capital-endowment, liquidity, governance, booking and reporting requirements (applying from 11 January 2027)
• enhanced requirements for the identification, management and stress-testing of environmental, social and governance (ESG) risks, including transition plans with quantifiable targets
• the extension of fitness and suitability requirements to the chief financial officer, heads of internal control functions and other key function holders; new advance-notification regimes for material holdings, material transfers of assets and liabilities, and mergers and divisions involving credit institutions and (mixed) financial holding companies
• specific requirements addressing crypto-asset exposures; strengthened supervisory powers and sanctions (including administrative penalties of up to 10% of annual net turnover)
• new conflict-of-interest and “cooling-off” rules for Central Bank staff and Commission members

Key actions to take: In-scope credit institutions, and third-country groups operating or proposing to operate branches in Ireland, should assess the impact of the transposed CRD VI requirements, monitor the forthcoming EBA guidelines, and prepare for the third-country branch framework applying from 11 January 2027. FMCs with MiFID top-up permissions should note the enhanced ESG risk-management and fitness and probity expectations, where relevant to their activities.

Key bills relevant to the funds and financial services sector

Several bills of relevance to the sector are progressing through the summer 2026 legislative programme:

1. the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill, to transpose aspects of the EU’s New AML Framework (including AMLD6) requiring primary legislation, included for priority drafting
2. the Criminal Justice (Violation of Restrictive Measures) Bill, to transpose Directive (EU) 2024/1226 on criminal offences and penalties for the violation of Union restrictive measures, included for priority publication
3. the UN Restrictive Measures Bill, to create a "bridging measure" for asset-freezing obligations under UN Security Council Resolutions
4. the Asset Covered Securities (Amendment) Bill, which would amend the Asset Covered Securities Act 2001 to facilitate the issuance of covered bonds by specialist covered bond subsidiaries or by non-specialist credit institutions operating under a universal banking model (General Scheme published June 2026, included for priority publication in the summer session)

Key actions to take: Managers of Irish firms with AML and sanctions obligations should track these Bills, as they may require changes to structures, registrations and financial crime frameworks once enacted. Credit institutions and specialist covered bond issuers should monitor the Asset Covered Securities (Amendment) Bill as it progresses.

Consultation on reform of limited partnership framework in Ireland

On 7 July 2026, DETE published a public consultation on the reform of the limited partnership framework, seeking views on three specific policy proposals expected to be included in the Miscellaneous Provisions (Registration of Limited Partnerships and Business Names) Bill 2024:

1. increasing the statutory maximum number of partners from 20 to 149, in line with the member limit for private companies limited by shares
2. introducing a statutory ‘whitelist’ of activities that limited partners may undertake without being treated as taking part in management (and so without losing limited liability), similar to the whitelist that already exists for Investment Limited Partnerships
3. introducing a controlled mechanism to allow the withdrawal or adjustment of limited partners’ capital contributions, subject to solvency, creditor-protection and disclosure safeguards. The consultation forms part of a broader modernisation of the Limited Partnerships Act 1907 aimed at improving Ireland’s competitiveness for investment structuring while enhancing transparency and regulatory oversight

Key actions to take: The consultation closed on 14 August 2026 and we responded to it. We will continue to monitor developments and include updates in our future updates. At this point in time the final form, effective date and any grandfathering provisions applicable to existing 1907 Limited Partnerships, remain undetermined. It is expected that updated 1907 Limited Partnership requirements will become legally effective in 2027.