Asset Management Essentials: Ireland - Q4 2026

Contents

Timeline tracker: key dates at a glance

• 2026-2027 upcoming deadlines

• Ongoing EU legislative processes

Ireland updates

• Recent developments

• Irish legislative updates

EU updates

• Recent developments

• Recent Commission Delegated Regulations

The European Supervisory Authorities (the ESAs)

• European Securities and Markets Authority (ESMA)

• European Banking Authority (EBA)

• Anti-Money Laundering Authority (AMLA)

Ireland updates

Recent developments

Budget 2027 and the introduction of the Individual Investment Account

Following the publication of Taxation of Retail Investment: A New Path Forward for Ireland, the Irish Government announced details of the Individual Investment Account (the Investment Account). The Investment Account will be open to Irish tax-resident individuals aged 18 or over, with a tax-free threshold of €50,000 and a 1% tax rate on holdings above that threshold - such values being the average account value for the year of assessment.

Derivatives, crypto-assets and other high-risk products will be excluded, deemed disposal will not apply and providers will calculate and pay the tax, taking that burden away from account holders.

Budget 2027 included other broader measures including a reduction of Investment Undertaking Tax (IUT) from 38% to 35%, changes to the Pillar Two framework, amendments to the rules on interest relief on borrowings and a reduction in capital gains tax from 33% to 31%. The Finance (No. 2) Bill giving effect to the Budget is listed for priority publication in the autumn session.

Key actions to take: Fund managers, exchange-traded fund (ETF) promoters and distributors should assess the opportunity presented by the new investment account, including product eligibility and whether they wish to act as account providers.

Central Bank of Ireland supervisory reviews on closet indexing and value for money

In August 2026, the Central Bank of Ireland (CBI) announced that it would shortly launch two ESMA-driven supervisory reviews focused on closet indexing and value for money, supporting its priority of enhancing oversight of product costs and disclosures. The reviews will assess fund management companies’ governance frameworks, policies and procedures using ESMA-developed methodologies. This will recur annually.

Key actions to take: Fund Management Companies (FMCs) should review fee structures, value-for-money and active management governance, and be ready to evidence that fund costs are justified and that actively managed funds are genuinely active.

Central Bank consultations on industry funding levy (CP172) and third-party risk (CP173)

On 25 September 2026, the CBI published Consultation Paper 172 on Industry Funding Levy Proposals (CP172), proposing changes to the methodologies for calculating the industry levy across certain firms, including investment fund service providers and investment firms. The deadline for responses is 8 January 2027.

The CBI also published Consultation Paper 173 on Guidance on Good Practices for the Sound Management of Third-Party Risks (CP173) with a response deadline of 3 December 2026. The CBI is seeking industry views on proposed guidance for managing third-party risks, which is proposed to replace the existing CBI guidance on outsourcing.

Key actions to take: Fund service providers should assess the impact of the proposed levy methodology and consider responding to CP172 by 8 January 2027. FMCs should review CP173 against their outsourcing and third-party risk frameworks and consider responding by 3 December 2026.

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.

National AML / CTF / CPF Strategy 2026

On 13 August 2026, the Tánaiste and Minister for Finance launched Ireland’s first National Anti-Money Laundering, Countering the Financing of Terrorism and Countering Proliferation Financing Strategy (2026–2030), which sets out a comprehensive plan to strengthen Ireland’s response to financial crime. The strategy is built around three strategic pillars: policy and oversight, safeguarding and monitoring, and investigation and enforcement. It is supported by a priority action plan of 30 actions to be delivered across Government departments and agencies over the 2026–2030 period.

Key actions to take: Fund management companies and their boards should consider the strategy alongside the forthcoming new AML framework and the updated Money Laundering, Terrorist Financing and Proliferation Financing National Risk Assessment, and ensure their AML / CFT and financial sanctions frameworks are positioned for a strengthened regulatory and supervisory approach.

Ireland for Finance Strategy

On 25 August 2026, the Department of Finance launched the renewed Ireland for Finance Strategy, refocused for a digital age. The strategy includes commitments relevant to the asset management industry, including a pathway to legislation for the tokenisation of investment funds, a reform of the limited partnership framework and other measures to enhance Ireland’s private markets offering. It also commits to the timely, transparent and coherent transposition of EU financial services legislation, the establishment of a Digital Assets Industry Group and continued support for the CBI’s Innovation Hub and a further iteration of its Innovation Sandbox.

On fund tokenisation, an examination of the ICAV Act and the Companies Act is underway to modernise the legislative framework. The strategy also notes Ireland’s position as domicile for roughly 70% of European ETFs and indicates that a bill modernising the 1907 limited partnership is being drafted for publication in 2027.

Key actions to take: Managers developing tokenised fund products or private markets structures should monitor the implementation of the strategy, along with forthcoming legislative and policy changes in these areas.

225% increase in Irish Investment Limited Partnership launches

The CBI updated its rulebook governing alternative investment funds (AIFs) and AIF managers in Ireland in May 2026. As well as aligning the Irish regime with key elements of the updated version of the EU’s Alternative Investment Fund Managers Directive (AIFMD), the reforms enhance Ireland's appeal as a fund domicile, particularly for private equity and private credit managers.

In our article Ireland private funds regime: key AIF Rulebook changes, which was featured in Private Equity Law Report, Ogier Investment Funds partner in Ireland, Oisin McClenaghan, examines Ireland's position as a leading funds domicile, the 225% increase in Investment Limited Partnership (ILP) launches in Ireland over the last 12 months, the new more flexible Irish loan-origination requirements applicable since mid-2025, and breaks down the key enhancements to the Irish regulatory framework including:

• fund finance

• intermediary investment vehicles

• side letters

• participation exemptions

• CBI filing streamlining

• side pockets

Tokenisation of Irish Money Market Funds

The Central Bank approved, for the first time, the tokenisation of units of 3 Irish money market funds (MMFs) in Summer 2026. The paper, published by Irish Funds in September 2026 explains the case for tokenisation of existing MMFs and the related structuring and regulatory considerations.

Governor’s address to the funds sector

On 1 October 2026, CBI Governor Gabriel Makhlouf addressed the Irish Funds Annual Global Funds Conference. He highlighted liquidity management, operational resilience and concentration risk in third-party technology providers and stated that firms are expected to test exit strategies. Governor Makhlouf confirmed that the CBI will consult on changes to the governance of fund management companies early next year, emphasising genuine substance and effective oversight of delegates.

Key actions to take: FMCs should test exit strategies for critical third-party providers and prepare for a 2027 consultation on fund management company governance, alongside their delegation remediation plans.

Feedback Report on the Collective Supervisory Action on compliance and internal audit functions

On 29 July 2026, the CBI published its Feedback Report on the Common Supervisory Action on Compliance and Internal Audit Functions in the Investment Funds Sector. The findings confirm that the compliance and internal audit governance structures and operations within firms are broadly in line with regulatory expectations. Areas that require attention include the consistent application of documented compliance policies and procedures, compliance resourcing and training, compliance monitoring and testing, board engagement and reporting, as well as oversight of delegated and group-level compliance and internal audit arrangements.

The CBI observed that some firms lacked a single board-approved compliance framework covering planning, monitoring, policy reviews and reporting. It also noted that some group-level policies had been approved before being presented to the local board, limiting the board’s ability to tailor them. All sampled firms outsourced internal audit to group level, with board influence over audit coverage varying significantly. Firms are expected to develop time-bound remediation plans to address any deficiencies identified.

Key actions to take: The CBI expects the report to be discussed by the board and relevant personnel so its observations and expectations can be given due consideration so that appropriate measures and controls are in place. FMCs should read it alongside European Securities and Markets Authority’s final report on the same Collective Supervisory Action (CSA).

Thematic assessments – fitness and probity and operational resilience in the MiFID investment firm sector

On 1 September 2026, the CBI published a feedback statement on its thematic assessment of the implementation of key aspects of the Fitness and Probity (F&P) regime in the MiFID investment firm sector. It sets out key findings, reminds firms of the CBI's expectations on the operating effectiveness of F&P frameworks and on embedding the Individual Accountability Framework / SEAR in governance frameworks, and outlines next steps all MiFID investment firms should take.

Although FMCs were not in scope, the findings contain useful takeaways for all regulated firms. These include that firms must apply their F&P policies effectively in practice; carry out appropriate due diligence on all controlled function (CF) and pre-approval controlled function (PCF) role-holders before appointment and as part of the annual certification process. This due diligence includes obtaining signed agreements to comply with the F&P standards, conflict of interest self-certifications and documentary evidence of competence assessments, tailor individual accountability framework (IAF) policies to their business model, as well as providing training to relevant staff.

The CBI has also published the results of its thematic assessment of operational resilience in the MiFID investment firm sector. The results note a maturing of operational resilience frameworks (with varying degrees of maturity) and identify cyber and digital operational resilience as a key focus. The CBI expects firms to revisit its Cross Industry Guidance on Operational Resilience, with particular attention to guidelines 4, 7 and 8 on identifying and mapping critical or important business services and capturing third-party dependencies. While directed at MiFID investment firms, the results are also relevant to FMCs.

Key actions to take: FMCs should benchmark their F&P frameworks and their identification and mapping of critical or important business services against the CBI’s findings and ensure boards review and approve the firm’s strategic approach to operational resilience.

Central Bank year-end filing deadlines 2026

The CBI has published its year-end filing timetable. For further information, see our briefing: CBI year-end filing deadlines: key dates for fund and fund service providers

Key actions to take: Managers and service providers planning year-end launches, service provider changes, ICAV registrations or revocations should diarise the relevant cut-off dates now.

MiCA knowledge and competence – Minimum Competency Code

Changes to the Minimum Competency Code 2017 incorporating crypto-asset knowledge and competence requirements, aligned with ESMA’s Markets in Crypto Assets (MiCA) guidelines, have applied since 28 July 2026 and are given effect by S.I. No. 295 of 2026. The changes bring crypto-asset service provider (CASP) staff who give information or advice within the same competency framework that applies to other regulated investment and financial services staff, with transitional grandfathering available to some existing providers.

MiFID authorisation portal

On 14 August 2026, the CBI confirmed that applicant firms seeking MiFID authorisation, and all other MiFID post-authorisation applications, will be required to submit their documentation through the Central Bank portal. A systems guide was due to be published by the end of Q3 2026.

Financial Crime Bulletin

In July 2026, the CBI published the second edition of its biannual Financial Crime Bulletin. Highlights include the CBI’s shift to an integrated national supervisory approach, the update of Ireland’s National Risk Assessment, the roll-out of sector-specific Risk Evaluation Questionnaires through to early 2027 and its expectation that sanctions compliance policies, procedures and controls are effective, proportionate and kept under regular review. Firms are expected to familiarise themselves with the new AML framework so they can implement changes effectively once applicable.

Key actions to take: Firms should review the bulletin, prepare for sector-specific Risk Evaluation Questionnaires and confirm that their sanctions screening covers transactions as well as clients.

Forthcoming Central Bank reviews – FSP Framework, Corporate Governance Codes and PCF list

As part of its roadmap for a more effective and efficient regulatory framework, the CBI is undertaking a comprehensive review of the Fund Service Provider (FSP) Framework, including AIFMs and UCITS management companies, covering management company and service provider rules, delegation and outsourcing provisions, and the consolidation of domestic regulations, guidance and Q&As. A modernised, consolidated FSP rulebook is expected in H2 2027. The CBI is also reviewing its Corporate Governance Codes during 2026 to remove duplication and embed proportionality and intends to consult in 2026 on changes to PCF roles and the pre-approval process. Revisions will be implemented in mid-2027 to coincide with the SEAR review.

Key actions to take: FMCs should monitor these reviews closely and consider engaging with the expected consultations, as they are likely to reshape the domestic rulebook for management companies and their governance and PCF arrangements.

Resumption of Outsourcing Register collection

The CBI will resume domestic collection of Outsourcing Registers, with a submission deadline of 28 February 2027 and a data reference date of 31 December 2026. The exercise is limited to firms that submitted registers in the 2024 cycle, and the CBI will contact in-scope firms in Q4 2026 with further details.

Key actions to take: Firms that submitted registers in 2024 should ensure their outsourcing registers are complete and accurate as at 31 December 2026 and watch for Central Bank correspondence.

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Irish legislative updates

Empowering Consumers for the Green Transition

The European Union (Empowering Consumers for the Green Transition) Regulations 2026, which transpose the EMPCO Directive (Directive (EU) 2024/825), entered into force on 27 September 2026, amending the Consumer Protection Act 2007 and the Consumer Rights Act 2022. They introduce prohibited and misleading commercial practices relating to environmental claims made to consumers, including sustainability labels not based on a certification scheme or established by a public body, generic environmental claims that cannot be substantiated, claims of neutral or reduced impact based on offsetting, as well as claims about future environmental performance that are not supported by a detailed, independently verified implementation plan.

Key actions to take: Managers should review fund offering documents, website disclosures and marketing communications for consumers to ensure they contain no prohibited or misleading environmental claims.

Gender Balance on Boards Regulations

Companies within the scope of the European Union (Gender Balance on Boards of Certain Companies) Regulations 2025 must submit information on the gender representation of their boards to the Minister for Children, Disability and Equality by 30 November 2026.

Key actions to take: In-scope companies should confirm their reporting obligations and prepare their submissions ahead of the 30 November 2026 deadline.

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. The Act is not yet in force.

Key actions to take: Managers and funds that make cross-border investments protected under the Comprehensive Economic and Trade Agreement (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.

Criminal Justice (Terrorist Offences) (Amendment) Act 2025

The Criminal Justice (Terrorist Offences) (Amendment) Act 2025, enacted on 7 July 2026, amends the Criminal Justice (Terrorist Offences) Act 2005 to fully implement Directive (EU) 2017/541 on combating terrorism, allowing for the prosecution of a broader range of terrorist activities, including acts with a cross-border element and cyber-attacks intended to cause widespread harm.

Key actions to take: Firms should reflect the expanded offences in their CFT risk assessments and staff training.

New Irish Statutory Instruments (S.I.s)

S.I. No. 406 of 2026: European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) (Amendment) Regulations 2026, published on 7 August 2026, amend the 2019 Regulations (S.I. No. 110 of 2019), which require Irish-incorporated corporate entities to identify, obtain and hold beneficial ownership information and file it on the Register of Beneficial Ownership (RBO), updating those obligations in line with EU AML directives and amending the access regime for the RBO.

S.I. No. 316 of 2026: the Central Bank UCITS Regulations 2026 (discussed above) do not specify a commencement date but were signed by the Central Bank on 7 July 2026, with notice of their making published in Iris Oifigiúil on 10 July 2026; applying the default rule of statutory interpretation, they appear to have come into operation on 7 July 2026.

S.I. No. 295 of 2026: Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Minimum Competency) (Amendment) Regulations 2026 came into operation on 28 July 2026 and amend the Minimum Competency Regulations 2017 (S.I. No. 391 of 2017) to incorporate MiCA-related changes.

Key actions to take: Firms should ensure their beneficial ownership processes reflect the amended RBO access regime, UCITS should confirm that counterparty risk calculations capture non-centrally cleared derivatives, and firms with CASP-facing staff should apply the amended Minimum Competency Code.

EU AI Act – amendments and guidance

Regulation (EU) 2026/1744, the Digital Omnibus on AI, was published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026. It delays 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), moves the deadline for transparency (watermarking) obligations for AI-generated content under Article 50(2) to 2 December 2026, and clarifies supervisory competences for AI systems based on general-purpose AI models.

On 20 July 2026, the European Commission published guidelines on the transparency obligations for providers and deployers of interactive AI systems and AI-generated content, including examples and exemptions. On 7 July 2026, the Commission published an Action Plan on Cybersecurity and Artificial Intelligence. On 31 July 2026, the ESAs published a statement on managing ICT risks from frontier AI models, encouraging financial entities to adjust ICT risk management processes, procedures and controls around prevention, detection and management.

Separately, the Regulation of Artificial Intelligence Act 2026 was enacted on 21 July 2026. The Act establishes the AI Office of Ireland as an independent statutory body acting as Ireland’s central coordinating authority for the EU AI Act, and provides market surveillance authorities, including the Central Bank, with enforcement powers, including the power to receive complaints and impose administrative sanctions.

Key actions to take: Firms deploying AI should factor the revised timelines into their implementation plans, review governance, transparency and cyber-security controls against the new guidance, and adjust their ICT risk management frameworks in line with the ESAs’ statement on frontier AI models, noting the Central Bank’s enforcement role under the new Irish Act.

Key bills relevant to the funds and financial services sector

Several bills of relevance to the sector feature in the autumn 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 - heads are in preparation and the Bill is included for priority drafting in the autumn 2026 session

2. the Criminal Justice (Violation of EU Restrictive Measures) Bill, to transpose Directive (EU) 2024/1226 on criminal offences and penalties for the violation of Union restrictive measures (heads approved March 2025), included for priority publication in the autumn 2026 session

3. the Restrictive Measures Bill, to create a "bridging measure" for asset-freezing obligations under UN Security Council Resolutions pending their incorporation into EU law – heads are in preparation but the Bill is not included as a priority for the autumn 2026 session

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 non-specialist credit institutions operating under a universal banking model (heads approved June 2026, included for priority drafting in the autumn 2026 session)

5. the Finance (No. 2) Bill to give legislative form to the taxation proposals in Budget 2027 (including the new retail investment account), included for priority publication in the autumn 2026 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.

Limited partnership reform

The Department of Enterprise, Tourism and Employment (DETE) consultation on reform of the Limited Partnerships Act 1907 closed on 14 August 2026. The Miscellaneous Provisions (Registration of Limited Partnerships and Business Names) Bill appears in the autumn 2026 programme outside the priority lists, with work ongoing. However, the renewed Ireland for Finance strategy commits to modernising the 1907 Act. Managers and advisers using Irish limited partnerships (including for venture capital, private equity, property and joint ventures) should monitor the outcome, as the reforms could affect permitted partner numbers, limited-partner activities and capital flexibility.

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EU updates

Recent developments

Market Integration and Supervision Package (MISP)

The Council has been finalising its general approach on the MISP, with political points on defined benefit carve-outs and ESMA governance still open. It favours supervisory coordination colleges chaired by the home NCA, with no new ESMA supervisory powers, a lighter regime for intra-group delegation and an opt-in depositary passport. Parliament is moving more slowly, with a Committee on Economic and Monetary Affairs (ECON) vote scheduled for 1 December and plenary expected in late December. Its text retains ESMA powers to suspend cross-border activities and to supervise depositaries directly. Many details are likely to be settled in trilogues.

Key actions to take: FMCs should follow the MISP closely, as the final text could change supervisory and delegation requirements.

SFDR 2.0 proposal

On 3 July 2026, the European Commission adopted revised European Sustainability Reporting Standards (ESRS) under the Accounting Directive (2013/34/EU), as introduced by the Corporate Sustainability Reporting Directive (CSRD), together with a voluntary reporting standard for smaller undertakings covered by the value-chain cap. The acts simplify and streamline reporting requirements. They were published in the Official Journal on 21 September 2026 and the revised ESRS will apply to financial years beginning on or after 1 January 2027. Separately, on 23 July 2026, EFRAG launched a public consultation on an exposure draft ESRS for certain non-EU undertakings meeting the Article 40a thresholds, which will apply for financial years starting on or after 1 January 2028; the European Financial Reporting Advisory Group (EFRAG) expects to deliver its draft technical advice to the Commission in January 2027.

Further update: Both co-legislators now have negotiating mandates: the Council agreed its position on 24 June 2026, ECON adopted Parliament’s position on 10 September and Parliament endorsed it in plenary on 7 October. Trilogues opened on 22 October under the Irish Presidency, with the aim of an agreement on key issues by year-end, although this could slip into early 2027. The three institutions agree on the core architecture of three product categories (Sustainable, Transition and ESG Basics) with a 70% investment threshold, strict naming and marketing rules, and an opt-out for AIFs marketed solely to professional investors.

The most contested points are expected to be the fossil fuel exclusions for Transition products, principal adverse impact reporting (including whether it applies to ESG Basics) and Parliament’s proposed engagement disclosures. Both texts provide for application 24 months after entry into force, so application is not expected before late 2028 or early 2029. Level 2 measures will determine how workable the regime is.

Key actions to take: Managers should begin mapping existing Article 8 and 9 funds against the proposed categories, screening portfolios against the proposed exclusions and reviewing fund names and marketing materials, while monitoring the trilogues.

Securitisation framework – political agreement

On 21 October 2026, ECON negotiators and the Irish Presidency reached political agreement on the review of the EU securitisation framework, proposed by the Commission in June 2025. The deal replaces fixed minimum risk weights with a more risk-sensitive formula (with a 5% floor for safer asset classes), gives ESMA oversight of STS third-party verifiers, requires Member States to set sanctions for due diligence breaches while taking account of parallel sectoral sanctions, as well as distinguishing public from private securitisations, with a simpler reporting template for private deals and a distinct template for CLOs. The agreement must now be formally adopted by Parliament and Council.

Key actions to take: Managers investing in securitisations, including CLOs, should review their due diligence and reporting arrangements against the agreed changes and monitor formal adoption and the final text.

EU Taxonomy Disclosures Delegated Act review

On 1 July 2026, ESMA (alongside the EBA and EIOPA) consulted on technical advice to the Commission on selected key performance indicators under the EU Taxonomy disclosures framework for Article 8 undertakings, proposing simplifications for non-financial undertakings and asset managers, in particular to the operational expenditure KPI. The consultation closed on 12 August 2026 and ESMA is expected to deliver its final technical advice by the end of October 2026.

Key actions to take: Asset managers subject to Taxonomy disclosures should monitor ESMA’s final advice and the Commission’s response, which may reduce reporting burdens.

Retail Investment Strategy proposals

The EU’s Retail Investment Strategy (RIS) package (comprising the Retail Investment Package Directive and the PRIIPs KID Regulation) seeks to harmonise investor protection rules across MiFID II, IDD, UCITS, AIFMD and Solvency II. Following political agreement in December 2025, the compromise was endorsed by COREPER on 5 June 2026 and by ECON on 23 June 2026. 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, as well as an annual assessment of whether undue costs have been charged, with reimbursement of affected investors. The European Parliament plenary vote is expected on 11 November 2026, with Council confirmation to follow and publication in the Official Journal expected by January 2027 at the latest. Member States will have 24 months to transpose the new rules following their publication, which will then apply 30 months after publication (18 months for the changes to the PRIIPs KID Regulation).

On 26 August 2026, ESMA published a letter from the European Commission requesting technical advice on implementing the RIS changes to the UCITS, AIFMD and MiFID II frameworks, including value for money, undue costs, inducements and simplified advice. ESMA is expected to consult in Q1 2027 and must deliver its advice by 1 October 2027.

Key actions to take: Product manufacturers and distributors should begin assessing the likely impact of the retail investment reforms on product governance and disclosures and prepare for the value-for-money and undue cost assessment obligations, including the data and peer-comparison capabilities they will require. The agreed approach relies on firms’ own peer group comparisons rather than EU-wide cost caps and replaces the proposed ban on execution-only inducements with a strengthened test (with Member States free to go further), so divergent national transposition is a risk. Application is estimated around Q2 2029 and firms should align this work with the Central Bank’s closet indexing and value for money reviews.

European Commission consultation on the review of MiCA

On 20 May 2026, the European Commission published a targeted consultation on the review of MiCA, to assess whether the regime remains fit for purpose in light of initial implementation and subsequent market and policy developments. The consultation closed on 30 September 2026. Industry responses focused on technology neutrality, stablecoins (including interest, multi-issuance and the ability of funds to hold them) and harmonised rules for DLT registers.

Key actions to take: CASPs and firms with crypto-asset activities should monitor the outcome of the review, which may lead to changes in the MiCA framework, alongside the MISP proposal to transfer CASP authorisation to ESMA.

Listing Act package

The EU Listing Act package comprises the Listing Directive (Directive (EU) 2024/2811), the Multiple-Vote Share Directive (Directive (EU) 2024/2810) and the EU MiFIR Listing Regulation (Regulation (EU) 2024/2809), all published in the Official Journal on 14 November 2024. The package is designed to make EU public capital markets more attractive and to facilitate access to capital for small and medium-sized enterprises. Member States were required to transpose the Listing Directive by 5 June 2026, but Ireland missed this deadline and Department of Finance transposition work is ongoing. Member States must transpose the Multiple-Vote Share Directive by 4 December 2026.

Key actions to take: Firms advising on listings or operating multiple-vote share structures should assess the impact of the Listing Act package and monitor Irish transposition of the Multiple-Vote Share Directive by 4 December 2026.

MiFID II / MiFIR consolidated tape reforms

Regulation (EU) 2024/791 (the MiFIR Amending Regulation) and Directive (EU) 2024/790 (the MiFID II Amending Directive) update the MiFID II framework to enhance market transparency, introduce an EU-wide consolidated tape combining market data across trading venues and prohibit payment for order flow. The MiFIR Amending Regulation has applied since 28 March 2024 and the deadline for Member States to transpose the MiFID II Amending Directive was 29 September 2025. In Ireland it has been transposed by S.I. No. 436 of 2025. The consolidated tape went live on 14 September 2026 and further changes to the tape are under discussion in the MISP negotiations.

Key actions to take: Firms relying on market data or executing client orders should prepare for the EU consolidated tape and the prohibition on payment for order flow and review their order-handling arrangements accordingly.

UK Consumer Composite Investments regime

The new UK Consumer Composite Investments regime begins to apply on 8 June 2027. Irish funds marketed to UK retail clients will be required to publish a “Product Summary” document in place of a UCITS Key Investor Information Document.

Key actions to take: Managers marketing Irish funds to UK retail investors should begin planning for the production of product summary documents ahead of June 2027.

ESG Ratings Regulation now in application

The ESG Ratings Regulation (Regulation (EU) 2024/3005) has applied since 2 July 2026, introducing a regulatory regime for ESG rating providers operating in the EU, with the CBI designated as competent authority in Ireland under S.I. No. 317 of 2026. Several supplementing Commission Delegated Regulations have since been published (see table below).

Key actions to take: Managers using ESG ratings in investment processes or disclosures should confirm that their providers are authorised or recognised under the new regime.

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The European Supervisory Authorities (ESAs)

European Securities and Markets Authority (ESMA)

T+1 settlement preparations

On 20 July 2026, ESMA published a statement calling on firms to finalise preparations for the transition to a T+1 settlement cycle in EU financial markets, scheduled for 11 October 2027. ESMA underlines that 2026 is a critical year for market participants to test readiness, noting the first regulatory deadline of 7 December 2026 for allocations and confirmations processes.

Key actions to take: Firms should ensure their operational readiness for T+1 settlement across the trading and settlement chain, with particular attention to the 7 December 2026 allocations and confirmations deadline.

Common supervisory action on risk management

On 3 July 2026, ESMA separately announced a CSA with NCAs, to be conducted throughout 2026 and 2027, on the effectiveness, independence and expertise of the risk management function of UCITS management companies and AIFMs. NCAs will focus on the governance and organisation of the risk management function, the identification, measurement and monitoring of risks, and reporting to senior management and governing bodies. ESMA will publish a final report with results in 2028.

Key actions to take: UCITS management companies and AIFMs should ensure their risk management function is adequately resourced, independent and expert, in anticipation of supervisory scrutiny under the CSA.

CSA on conflicts of interest in distribution

ESMA is carrying out a CSA with national competent authorities during 2026 on conflicts of interest in the distribution of financial instruments, assessing how firms comply with their MiFID II obligations to identify, prevent and manage conflicts when offering investment products to retail clients.

Key actions to take: Firms distributing investment products to retail clients should review their conflicts of interest policies and controls in anticipation of supervisory engagement.

Other recent ESMA publications

On 8 July 2026, ESMA published its final report (ESMA91-1505572268-4692) on draft RTS on the elements to be considered when central counterparties (CCPs) define participation requirements under EMIR 3. The final report has been submitted to the Commission, which has three months to decide on adoption.

On 7 July 2026, ESMA published a supervisory briefing (ESMA35-243228190-8065) setting out expectations for firms and NCAs regarding triangular passporting under MiFID II. On 6 July 2026, ESMA published an interim report on the effectiveness of the Active Account Requirement (AAR) and the first annual report of the Joint Monitoring Mechanism (JMM), providing preliminary findings on whether the AAR is achieving its objectives.

On 16 October 2026, ESMA finalised its review of the guidelines on delaying the disclosure of inside information under Market Abuse Regulation.

Key actions to take: Firms active in clearing should review the CCP participation RTS. Those providing cross-border services should note the supervisory briefing on triangular passporting, and entities subject to the active account requirement should assess their position in light of the AAR interim findings.

EMIR 3 – margin and clearing activity reporting

On 31 July 2026, the ESAs published a final report on draft RTS amending the bilateral margin requirements in Commission Delegated Regulation (EU) 2016/2251. Counterparties below the €8 billion initial margin threshold would no longer need to exchange initial margin on legacy uncleared OTC derivative contracts, as well as new ones, aligning the EU more closely with other jurisdictions. The draft RTS have been submitted to the Commission for endorsement. On 18 August 2026, ESMA consulted on draft RTS and Implementing Technical Standards (ITS) on annual reporting by clearing members and clients of their activity at recognised third-country CCPs under EMIR 3. The consultation closed on 12 October 2026 and ESMA expects to publish a final report in Q4 2026.

Key actions to take: Funds with uncleared over-the-counter (OTC) derivatives below the €8 billion threshold should track the margin RTS, which may remove legacy initial margin obligations, and those clearing through third-country CCPs should prepare for the new annual reporting requirements.

ESMA 2027 Work Programme and Trends, Risks and Vulnerabilities report

On 28 September 2026, ESMA published its 2027 annual work programme. Deliverables relevant to fund managers include the integrated funds reporting framework, the Retail Investment Strategy (RIS), SFDR 2.0, the PRIIPs framework, transaction reporting and risk monitoring, with the programme to be adapted depending on the outcome of the MISP. On 10 September 2026, ESMA also published its second Trends, Risks and Vulnerabilities report of 2026, covering the period to 30 June 2026, including statistics on EU fund flows, valuation, credit and liquidity risk in EU bond funds and the use of leverage.

On integrated funds reporting, ESMA is expected to consult on the draft RTS and ITS by the end of 2026. Industry has raised concerns that some member states could introduce interim reporting from April 2027.

Key actions to take: FMCs should use the work programme to anticipate 2027 regulatory change and consider the TRV findings when reviewing liquidity and leverage risk.

ESAs – DORA incident reporting instructions

On 16 September 2026, the ESAs published operational instructions to support competent authorities in their engagement with financial entities on reporting major ICT-related incidents under DORA, clarifying recurring practical points in completing the reporting templates, including language, monetary and free-text fields, incident identification and classification criteria.

Key actions to take: FMCs should review their DORA incident reporting procedures and templates against the instructions.

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European Banking Authority (EBA)

EBA – guidelines on authorisation of third-country branches

On 7 July 2026, the EBA published its final report (EBA/GL/2026/08) setting out guidelines on the authorisation of third-country branches under CRD IV (Directive 2013/36/EU), as amended by CRD VI (Directive (EU) 2024/1619).

EBA – final draft technical standards on material acquisitions, transfers, mergers and divisions

On 17 July 2026, the EBA published its final draft technical standards on material acquisitions, material transfers, mergers and divisions under the Capital Requirements Directive. The standards will be submitted to the European Commission for endorsement.

Key actions to take: Credit institutions and investment firms within the CRD framework should review the guidelines on TCB authorisation and the technical standards on material acquisitions, which will be relevant for group restructurings and branch operations.

EBA – consultation on reclassification of investment firms as credit institutions

On 25 August 2026, the EBA published a consultation paper (EBA/CP/2026/17) on three sets of draft RTS supporting the rules under which large MiFID investment firms must seek authorisation as credit institutions. Under Article 8a CRD, firms dealing on own account or underwriting / placing on a firm commitment basis (MiFID activities (3) and (6)) must apply for a banking licence once their total assets, averaged over 12 months, reach €30 billion, either individually or across the group. The three RTS cover:

Calculating the threshold: Reflecting CRD VI, the group test now counts only EU entities carrying out the relevant activities (plus EU branches of third-country group entities), rather than the global group. Assets are measured on an IFRS basis (local EU GAAP only where IFRS is not used), intragroup exposures are deducted, off-balance sheet items such as assets under management and safekeeping are excluded, and calculations are quarterly, with monthly figures interpolated.

Monitoring: Firms with total assets above €5 billion would report two templates quarterly (by 12 May, 11 August, 11 November and 11 February), allowing the competent authority to track the position against the €30 billion threshold.

Waivers: CRD VI allows competent authorities to waive the authorisation requirement. In deciding, they would assess the group’s structure, booking practices and allocation of assets, the firm’s business model (including whether market risk is systematically hedged) and the share of dealing on behalf of clients, systemic importance, including O-SII status and large exposures of banks to the firm, as well as the size and complexity of its derivatives portfolio, particularly unmargined OTC derivatives.

The consultation closes on 25 November 2026, after which the EBA will finalise the RTS and submit them to the Commission. The EBA expects fewer firms to be caught under the narrower EU-only scope.

Key actions to take: The proposals mainly affect large trading firms and bank-affiliated investment firms. Irish MiFID firms in groups with significant EU dealing or underwriting activity should check their position under the revised group test and, where more than €5 billion, prepare for the quarterly reporting.

EBA – further third-country branch, reporting and prudential measures

On 25 August 2026, the EBA published a consultation paper on three sets of draft RTS on the reclassification of investment firms as credit institutions under CRD IV, which closes on 25 November 2026. On 24 July 2026, the EBA published a draft technical package for version 4.4 of its reporting and disclosure framework, which is expected to apply from Q4 2026. The EBA’s guidelines on instruments available to third-country branches to cover risks or losses will apply from 11 January 2027 and its supervisory reporting requirements for third-country branches will apply from 31 March 2027. The EBA is also expected to issue revised guidelines on the systemic risk buffer relating to climate change in H2 2026.

Key actions to take: Investment firms approaching the relevant thresholds should consider responding to the reclassification consultation by 25 November 2026.Third-country groups should plan for the January and March 2027 third-country branch milestones.

EBA – guidelines on third-party risk for non-ICT services

On 18 September 2026, the EBA published final Guidelines on the sound management of third-party risk relating to non-ICT services, updating its 2019 outsourcing guidelines in line with DORA. The Guidelines set out steps across the life cycle of third-party arrangements, criteria for applying proportionality, and allow a single register for ICT and non-ICT services. The application date is yet to be finalised, and a two-year transition period will apply. While fund management companies are not in scope, the CBI is likely to update its cross-industry outsourcing guidance to align with the Guidelines in due course.

Key actions to take: FMCs should consider the Guidelines alongside the CBI’s CP173 when reviewing their outsourcing frameworks and registers.

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Anti-Money Laundering Authority (AMLA)

AMLA – finalised standards for supervisory cooperation and further Level 2 measures

The consultation period for the draft ITS closed on 20 September 2026. AMLA intends to submit a final draft of the ITS to the European Commission by 30 November 2026.

Key actions to take: Firms should note the finalised ITS on supervisory cooperation (relevant to those potentially within scope of AMLA’s direct supervision) and monitor the final versions of the consulted measures, including the suspicious transaction reporting ITS due to be submitted to the Commission by 30 November 2026.

AMLA advisory note – ML / TF risks from the end of the MiCA transitional period

On 29 June 2026, AMLA published an advisory note on the money laundering (ML) and terrorism financing (TF) risks arising from the end of the MiCA transitional period on 1 July 2026. The note highlights risks associated with the exit of unauthorised VASPs (including weakened AML / CFT controls during wind-down and the concealment of illicit flows), sudden changes in risk exposure for authorised CASPs onboarding large customer volumes, and potential supervisory blind spots during market consolidation. It sets out mitigating measures for unauthorised VASPs, authorised CASPs, AML / CFT supervisors and FIUs, emphasising that incoming VASP customers should be assessed individually under a risk-based approach rather than subject to blanket de-risking.

Key actions to take: Firms providing crypto-asset services should review AMLA’s advisory note and ensure their AML / CFT frameworks are appropriately scaled for customer onboarding volumes, with risk-based CDD applied to clients transitioning from unauthorised VASPs. Firms winding down VASP activities should maintain full AML / CFT controls and reporting obligations until cessation.

EDPB and AMLA joint guidelines on information-sharing partnerships

On 1 July 2026, the European Data Protection Board and AMLA announced that they will jointly develop guidelines on information-sharing partnerships for AML / CTF purposes to help firms and authorities share information effectively while complying with data protection requirements. A stakeholder event is planned for later in 2026 and a public consultation on the draft guidelines is intended for H1 2027.

Key actions to take: Firms participating in, or considering, AML information-sharing arrangements should monitor the guidelines and the forthcoming consultation.

The new AML Framework, as discussed in our Q1 2026 regulatory update is being introduced on a phased basis and requires AMLA to produce a significant number of measures. A de-prioritisation announcement by the Commission regarding the new AML Framework means the measures will not be adopted before 1 October 2027.

Recent AMLA consultations

During the second quarter of 2026, AMLA launched a series of consultations on Level 2 measures under the new AML Framework, including draft guidelines on the ongoing monitoring of business relationships and on business-wide risk assessments, and draft regulatory technical standards on group-wide requirements and on cooperation between home and host supervisors. The guidelines on ongoing monitoring (consultation closed 3 September 2026) are expected to be published in Q4 2026, with national compliance indications expected in Q1 2027.

On 1 October 2026, AMLA submitted its final RTS on customer due diligence to the Commission, together with the RTS on business relationships and on group-wide requirements. The CDD RTS remove the proposed obligation on collective investment undertakings to access documents and information on end investors, as the funds industry had sought.

AMLA also launched a reporting package to help national competent authorities identify obliged entities that will fall under AMLA’s direct supervision from 2028.

Key actions to take: Firms should track AMLA’s consultations and begin preparing for the New AML Framework, including reviewing their group-wide AML / CFT policies and risk assessment methodologies.

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