Ireland asset management regulatory update, Q1 2026

This briefing gives a practical overview of recent legal and regulatory developments for the asset management industry in Ireland.

If you require further detail about any of the below updates and how they affect you and your business, get in touch with any of the key contacts below.

If you have been directed to this update by a colleague, client or service provider and would like to receive future briefings direct your inbox, you can sign up for our e-mail newsletter. Make sure you tick the boxes for Investment Funds, Regulatory and Ireland to be added to our list to receive future editions of this newsletter.

Newsletter contents

Ireland updates

• Funds Review 2030 Report

• Central Bank of Ireland updates

• Irish legislative updates

EU updates

• New EU Directives and Regulations

• European Commission's 2026 Work Programme

• European Commission updates

• Recently adopted EU measures

The European Supervisory Authorities (the ESAS)

• European Securities and Markets Authority (ESMA)

• European Banking Authority (EBA)

• Anti-Money Laundering Authority (AMLA)

2026 – 2027 timeline for EU Directives and Regulations

Key Ireland updates

Funds Review 2030 Report

Implementation plan and key updates

The Department of Finance has published an implementation plan and progress report addressing recommendations from the Funds Review 2030 Report. 30 of the 42 recommendations have either been completed, are on track for completion, or are progressing.

Key measures have been implemented on: ETFs and the AIF Rulebook, by the Central Bank of Ireland (the CBI).

Of the 12 recommendations that remain under consideration, four relate to retail investment tax. A roadmap to simplify and adapt the tax framework is expected in early 2026 to encourage retail investment. Meanwhile, the Finance Bill 2025 will reduce the tax rate on Irish and equivalent offshore funds, in addition to Irish and foreign life assurance products, from 41% to 38%.

The proposed consultation on an entity-level tax for Irish Real Estate Funds (IREFs) will not proceed, but there are plans to launch a public consultation in 2026 on the simplification of the IREF regime with a view to implementing amendments in the Finance Act 2026.

Considerations: Responding to the IREF public consultation will provide stakeholders with an opportunity to have their say ahead of any implementing measures. Reach out to us if you need assistance with this.

Back to top

Central Bank of Ireland updates

Investment fund statistics

The CBI has released its Investment Fund Statistics for Q3 2025. In summary, net asset values (NAV) of Irish resident investment and money market funds grew to €5.309 trillion in Q3 2025, almost four times its value in 2014. Equity holdings rose to €2.89 trillion with USD denominated equities recording €114 billion in positive revaluation.

Central Bank of Ireland Report on Regulating and Supervising well 

The CBI published this report outlining their regulatory framework roadmap which includes plans for a more effective and efficient regulatory framework across various pillars. Learn more on the CBI's website.

The report also notes that the CBI will launch a comprehensive review of the Fund Service Provider (FSP) Framework, covering AIFMs and UCITS management companies to ensure it remains robust post AIFMD II. Initial proposals are expected in H1 2026, focusing on updating management company rules, delegation / outsourcing provisions, and consolidating regulations and guidance. The updated and consolidated Financial Service Providers (FSPs) rulebook is expected by H2 2027.

According to the report, the CBI will also review the Corporate Governance Codes to eliminate duplication, enhance alignment across sectors, and ensure proportionality and clarity in governance design.

Considerations: Firms should engage proactively with the comprehensive review of the FSP Framework, assessing delegation, outsourcing, and governance policies to ensure continued compliance in the AIFMD II environment. Operational and transformational teams will be well placed for implementation if they commence preparations this quarter.

Central Bank of Ireland Prospectus Rules

On 17 December 2025, the CBI published a Notice of Intention to make amendments to the Central Bank (Investment Market Conduct) Rules 2019 (the CBI Prospectus Rules). The proposed amendments are of limited technical nature and will be implemented by an amending statutory instrument.

Considerations: Technical amendments to the CBI Prospectus Rules may require prospectus updates. Clients are advised to review the amending statutory instrument and update prospectuses where necessary.

Regulatory Impact Assessment Framework

The CBI is expected to publish a public consultation on a new Regulatory Impact Assessment (RIA) Framework during H1 2026. The RIA Framework will formalise the CBI's approach to balancing regulatory effectiveness with efficiency and ensuring clear intent and proportionate impact.

Considerations: Responding to consultations provides industry with an opportunity to have a say in how they are regulated. Get in touch if you would like Ogier to assist with this process.

Fitness and Probity reforms

The CBI published a Feedback Statement on amendments to the Fitness and Probity (F&P) regime in response to its Consultation Paper on Amendments to the Fitness and Probity Regime, along with the Fitness and Probity Standards.

The Guidance on the Standards of Fitness and Probity 2025 (the F&P Guidance) consolidates all CBI related material into a single document. The new F&P regime took effect on 20 November 2025 and provides:

• targeted revision of the PCF list, with certain roles eliminated and safeguarding functions added to address evolving activities in payments, e-money, and crypto assets
• heightened expectations for the Head of AML / CFT (PCF52), requiring firms to allocate accountability for anti-money laundering and counter-terrorist financing measures to senior management and, where warranted by risk, possibly to a board member
• guidance around "temporary officer" appointments is more flexible and transparent, with firms potentially now able to fill vacant PCF positions with a temporary officer for up to six months, provided prior written approval is secured from the CBI
• the categorisation of company secretaries has been clarified: the CF1 designation now applies only when the individual has substantive influence over the firm, rather than automatically to all company secretaries. Those with a purely administrative role as company secretary are likely to fall outside of the remit of a CF1 designation.
• where a PCF or CF role is conducted outside Ireland, firms are expected to evidence meaningful presence and decision-making in Ireland, including the management of critical risks

Considerations: Clients should act promptly to review governance structures and existing PCF nominations in light of the new guidance, ensuring policies and procedures meet the revised standards. It is advisable for your respective teams to conduct a gap analysis and proactively address any areas of concern, which will facilitate a smoother transition and mitigate regulatory risk.

ESMA Common Supervisory Action on Sustainability Risks and Disclosures in the Investment Funds Sector

The CBI published the ESMA Common Supervisory Action on Sustainability Risks and Disclosures in the Investment Funds Sector Report (the ESMA Report) following a review of the ESMA Common Supervisory Action on sustainability risks and disclosures. The Common Supervisory Action aimed to improve consistency in how firms address sustainability risks and related disclosures, focusing on issues like misleading statements, Sustainable Finance Disclosure Regulation (SFDR) compliance and greenwashing. The report reviews how UCITS managers and AIFMs are meeting these requirements and sets out key areas for improvement, such as monitoring practices, data quality, and the effectiveness of controls. You can read the full report on the CBI's website.

Considerations: The CBI expects firms to maintain clear policies, periodically review them and strengthen monitoring and due diligence efforts. Firms should discuss the ESMA Report on sustainability at board level and ensure robust controls are in place.

Consumer Protection Code

The CBI has revised the 2012 Consumer Protection Code (the code) with amendments coming into effect from 24 March 2026.

The CBI's information page providing materials and guidance on the code can be found on its website.

The revisions follow a public consultation and introduce a new structure and additional requirements around customer suitability, sustainability preferences, conflicts of interest, complaints handling and the use of digital platforms. The code applies to certain non-exempt regulated firms that provide services to consumers in Ireland.

The definition of a consumer under the code has seen a change to threshold levels, increasing the scope of firms under its remit. A consumer is now defined as including:

• a natural person
• a group of natural persons (including a partnership, club, charity, trust or other unincorporated body, or
• an incorporated body that had an annual turnover of less than €5 million in the previous financial year or one that is a member of a group of companies having a combined turnover of less than €5 million

Considerations: With the effective date as close as next month, in scope firms should be well advanced in preparing for compliance, including updating their terms and conditions, website disclosures, record retention procedures, staff training and communication with customers.

Central Bank of Ireland outsourcing guidance

On 24 October 2025, the CBI published a Notice of Intention in relation to the application of the European Securities and Markets Authority (ESMA) Guidelines on outsourcing to cloud service providers. The CBI will consult industry on incorporating provisions into the CBI UCITS Regulations and AIF Rulebook requiring AIF and UCITS depositaries to comply with the ESMA Guidelines, where they are not financial entities to which the Digital Operational Resilience Regulation and Directive (DORA) applies.

Considerations: Firms should carry out a gap analysis for all current and planned outsourcing and engage with legal and compliance to ensure a smooth transition.

Financial Crime Bulletin

The CBI published the first edition of its Financial Crime Bulletin on 11 December 2025. This biannual bulletin will provide updates on key regulatory and supervisory developments regarding Anti-Money Laundering (AML), combatting the financing of terrorism (CFT), financial sanctions and fraud. The full bulletin discusses risk assessments, crypto and payments, frauds and scams, financial sanctions and regulatory, supervisory and EU AML updates. 

The key focus for 2026 includes: 

• the CBI’s shift to an integrated national supervisory approach, considering risks and activities holistically; collaboration with the Anti-Money Laundering Authority (AMLA), which is now operational at EU level
• ongoing work to implement the new AML Framework (as defined below)

Considerations: It is important for firms to review the CBI's Bulletin against internal AML / CFT practices, ensuring compliance with regulatory requirements and expectations.

Operational Resilience in the MiFID Investment Firm Sector (the Thematic Assessment)

The CBI has published the results of the Thematic Assessment which outlines key findings and reiterates the CBI's expectations for firms and their boards regarding the design and effectiveness of their operational resilience frameworks, along with the next steps arising from the review.

While the Thematic Assessment was directly focused on MiFID investment firms, the results will also be relevant for fund management companies and other regulated firms within the scope of the Cross Industry Guidance on Operational Resilience Guidance.

Considerations: Firms should compare the findings of the Thematic Assessment against current practices and identify any gaps or improvements to be made. For further information, see our recent article: Operational resilience: the Central Bank of Ireland’s review of MiFID firms

AIF and UCITS updates

The updated CBI AIF rulebook is expected to become effective no later than the transposition deadline of 16 April 2026 (the deadline for EU Member States transposition of AIFMD II - Directive (EU) 2024/927). Feedback on the respective consultations are expected during Q1 2026.

In a recent Markets Update (Issue 6 2025), the CBI announced facilitation of a streamlined process for post-authorisation updates to UCITS and AIF fund documentation in connection with AIFM and UCITS Directive amendments and related CBI rulebook updates. The process covers prospectus and / or supplement changes, except those affecting investment objectives, policies, or strategies.

Considerations: Proactively review current fund documentation and monitor the consultation feedback to assist in ensuring compliance with all amended regulatory requirements.

Other Central Bank of Ireland updates

The second Financial Stability Review of 2025 was published on 17 November 2025. The CBI highlighted that macroprudential policy development remains a priority, including for investment funds, with new frameworks proposed to address leverage and liquidity risks. They also highlighted that Irish domiciled investment funds, including property and private credit funds, are under increased scrutiny due to their interconnectedness within the financial system and the potential to amplify shocks, including through high leverage and liquidity mismatches. Regulatory measures, including a 60% leverage limit for property funds to be fully in effect by November 2027 and new liquidity management tool guidance, seek to bolster sector resilience.

In the CBI's Markets Update, Issue 8 2025, they confirmed the postponement of EMIR 3.0 reporting, to align with that of ESMA and other national competent authorities. This was due to ESMA's statement that it expected the first reporting under Article 7d of EMIR on 2025 data would be submitted together with the 2026 reporting cycle, following the implementation of the necessary Level 2 measures.

Back to top

Irish legislative updates

Upcoming changes

In October 2025, the Department of Finance published a statement on the outcome of the public consultation on the transposition of Directive (EU) 2023/2673 on distance marketing of consumer financial services in relation to five national discretions in the Directive. Directive (EU) 2023/2673 will be transposed into Irish law primarily by amendments to the Consumer Rights Act 2022, with a transposition deadline of 19 December 2025 and measures taking effect from 19 June 2026. The Directive amends Directive 2011/83/EU and repeals Directive 2002/65/EC, introducing new consumer protection requirements for financial services contracts concluded at a distance.

Considerations: Firms that provide consumer financial services at a distance, such as online or telephone sales of financial products to consumers should assess whether their activities fall within scope. If so, carry out a gap analysis against existing frameworks and potentially update policies, procedures, and client documentation where necessary to ensure compliance, by 19 June 2026.

Budget 2026

The Minister for Finance (the Minister) plans to publish a roadmap early in 2026 to simplify and modernise the funds tax framework, aiming to encourage retail investment.

The Minister also plans to launch a public consultation in 2026 on proposals to simplify the Irish Real Estate Fund (IREF) regime with a view to implementing amendments in the next Finance Act.

Considerations: Keep an eye out for the launch of the IREF public consultation if you wish to submit your views. Assess current tax structures and the Finance Act 2025 to determine whether opportunities have arisen for your business.

New Irish Statutory Instruments (S.I.s)

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 and amends S.I. No. 194 of 2021, the European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021 on beneficial ownership of trusts, imposing new obligations on designated persons when trust details are not registered in the Central Register.

S.I. No. 436/2025 - European Union (Markets in Financial Instruments) (Amendment) Regulations 2025 came into operation on 29 September 2025 to give further effect to MiFID, as amended by Directive (EU) 2024/790. In summary, the S.I.:

• updated and clarified reporting, data quality, and policy requirements for investment firms and trading venues, aligning Irish requirements with recent EU MiFID II amendments
• enhanced and standardised position reporting for firms and trading venues dealing in commodity derivatives and emission allowances
• provided for stricter data quality requirements for reporting entities

To ensure compliance investment firms were required to review and possibly amend their order execution and reporting arrangements, update policies and implement transparent client notification procedures.

S.I. No. 309/2025 – European Union (Corporate Sustainability Reporting) Regulations 2025 has been transposed for the purpose of giving effect to Article 1 of Directive (EU) 2025/794 of the European Parliament and of the Council of 14 April 2025, amending Directives (EU) 2022/2464 and (EU) 2024/1760 as regards the dates from which Member States are to apply certain corporate sustainability reporting and due diligence requirements, and giving further effect to Directive (EU) 2022/2464 of the European Parliament and of the Council.

Back to top

EU updates

New EU Directives and Regulations

SFDR 2.0

On 20 November 2025, the European Commission published its formal proposals for the revision of the Sustainable Finance Disclosure Regulation (SFDR), otherwise referred to as "SFDR 2.0".

SFDR 2.0 proposes to introduce a product categorisation regime with three new product categories, namely, transition category (Article 7), ESG basics category (Article 8) and Sustainable category (Article 9). Each of the new "Article 7, Article 8 and Article 9" product categories are subject to a minimum investment commitment of 70% linked to the proportion of investments to meet the objectives of the respective category, a mandatory list of exclusions and compliance with a list of permitted investment types.

Other key changes proposed by SFDR 2.0 include:

• new disclosure templates for sustainability-related financial products limited to a maximum of two pages
• removal of the PAI regime in its entirety at the entity level (that is so say, asset managers)
• removal of financial advisers and investment firms providing investment advice, and portfolio management services (provided by an investment firm or credit institution) from the scope
• deletion of the definition of ''sustainable investment''
• deletion of the requirement for financial market participants to disclose in their remuneration policies and publish on their websites how they are consistent with the integration of sustainability risks

In terms of next steps, the European Council and the European Parliament will deliberate the publication. The new regime is expected to apply 18 months after its entry into force.

Considerations: Firms should start considering the potential impact of SFDR 2.0 on their businesses and product ranges, including reviewing product categorisations, fund documentation and disclosures and data collection systems.

For further information on the proposed changes please see our article: SFDR 2.0 - a closer look at the European Commission’s published proposals

Regulation on shorter settlement cycle in the Union

Regulation (EU) 2025/2075 was entered into force on 3 November 2025 and will apply from 11 October 2027.

This regulation makes a targeted amendment to the Central Securities Depositories Regulation (909/2014) (CSDR) to shorten the current settlement cycle on trades in transferable securities executed on EU trading venues from two business days (T+2) to one business day after the trade (T+1).

Regulation on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities

Regulation (EU) 2024/3005 amends Regulations (EU) 2019/2088 and (EU) 2023/2859 (ESG Ratings Regulation), and introduces a regulatory regime for ESG rating providers operating in the EU. It will apply from 2 July 2026.

European Market Infrastructure Regulation and Amending Directive

Regulation (EU) 2024/2987 (EMIR 3) as regards measures to mitigate excessive exposures to third-country central counterparties and improve the efficiency of Union clearing markets entered into force and has applied since 24 December 2024, subject to provisions which will not apply until the date of entry into force of certain technical standards. EMIR 3 amends Regulations (EU) No 648/2012, (EU) No 575/2013 and (EU) 2017/1131. Its aim is to increase the efficiency of EU central counterparties (CCPs), whilst reducing reliance on third-country CCPs.

Directive (EU) 2024/2994 as regards the treatment of concentration risk arising from exposures towards central counterparties and of counterparty risk in centrally cleared derivative transactions not yet in force. Member States are expected to transpose the Amending Directive by 25 June 2026. It amends Directives 2009/65/EC, 2013/36/EU and (EU) 2019/2034, Its aim is to amend the rules on risk management for credit institutions and investment management firms to enhance financial stability.

The Listing Act package

The Listing Act package was published in the Official Journal of the European Union on 14 November 2024. Its aim is to make public capital markets in the EU more attractive to companies, whilst also facilitating the listing of companies of all sizes. This package consists of the following Regulation and Directives:

Regulation (EU) 2024/2809 to make public capital markets in the Union more attractive for companies and to facilitate access to capital for small and medium-sized enterprises. This Regulation amends Regulations (EU) 2017/1129, (EU) No 596/2014 and (EU) No 600/2014. Whilst many provisions have already come into force, there are key new rules to be transposed in 2026.

Directive (EU) 2024/2810 on multiple-vote share structures in companies that seek admission to trading of their shares on a multilateral trading facility must be transposed by 4 December 2026. Its aim is to assist small and medium-sized enterprises (SMEs) entering the public EU market by enabling them to adopt multiple-vote share structures when listing on multilateral trading facilities, whilst also providing safeguards for investors.

Directive (EU) 2024/2811 to make public capital markets in the Union more attractive for companies and to facilitate access to capital for small and medium-sized enterprises and repealing Directive 2001/34/EC must be transposed by 5 June 2025. It amends MiFID II to again assist SMEs on the public capital markets.

The MiFID II amendments

A new amending directive and regulation have been introduced to enhance market transparency and improve access to trading data. It comprises of the following:

Regulation (EU) 2024/791 as regards enhancing data transparency, removing obstacles to the emergence of consolidated tapes, optimising the trading obligations and prohibiting receiving payment for order flow has been applied since 28 March 2024. Its aim was to introduce an EU-wide consolidated tape, combining market data from all trading venues into a single source, and it prohibits payment for order flow, ending the practice of brokers receiving fees for directing client orders to specific platform.

Directive (EU) 2024/790 on markets in financial instruments amends Directive 2014/65/EU, and has been applied since 29 September 2025. Its aim is to enhance market competitiveness and transparency by facilitating better investor data access.

Back to top

European Commission's 2026 Work Programme

The 2026 European Commission's Work Programme was published on 21 October 2025 (the programme). The programme outlines an ambitious legislative agenda for the coming year, signalling a clear shift in priorities for financial services and investment funds.

As part of the programme, all current proposals pending adoption were assessed to determine whether they should be maintained, amended or withdrawn. Some of the key proposals on the 2026 agenda include:

Integration proposal

A comprehensive package to fully integrate EU financial markets to significantly amend key asset management rules, including the AIFMD and UCITS Directive. This will impact UCITS management companies and EU AIFMs, offering benefits such as faster passporting, streamlined marketing, an EU depositary passport, simplified group delegation rules, removal of national "gold plating," and stronger supervisory consistency across the EU. More information can be found in the European Commission's press release: Commission launches major package to fully integrate EU financial markets

Securitisation proposals

The Council agreed its position with the Commission's proposals to revise and simplify the EU Securitisation Framework on 19 December 2025. This allows for negotiations to proceed with the European Parliament prior to adoption of the legislative proposals. Learn more in the Council's press release: Savings and investment union – Council agrees position on revitalising the EU’s securitisation market

Retail Investment Proposals

On 18 December 2025, the Council and European Parliament reached provisional agreement on Retail Investment Proposals. Final legal texts are expected in early 2026. Member States will have 24 months from publication in the EU Official Journal to transpose the rules, with application beginning 30 months after publication, except for the KID Regulation, which will apply after 18 months, likely in 2027. For further information, see the Council's press release and the Parliament's press release.

EU Payments package

On 27 November 2025 provisional political agreement was reached in relation to proposed directives on the EU Payments package. Crypto-Asset Service Providers with authorisations under the Markets in Crypto-Assets Regulation (MiCAR), will be subject to a streamlined procedure. It is expected that the payments package will be published in the EU Official Journal during H1 2026.

Considerations: Firms should closely monitor the programme and prepare to adapt business models, compliance processes, and product disclosures in response to major changes in financial services regulation, including integration of markets, simplified sustainability reporting, updated securitisation and retail investment rules, and new procedures for payments and crypto-asset services.

Back to top

European Commission updates

On 15 January 2026, the EC published a targeted consultation reform of the regulatory frameworks for venture and growth capital funds aimed at fund managers, businesses, institutional investors and public authorities / supervisors to collect feedback on key obstacles faced by EU venture and growth capital fund managers and possible legislative and supervisory measures to address those challenges and covers rules stemming from the European Venture Capital Funds Regulation ((EU) 345/2013), AIFMD framework and national legislation applicable to small-and mid-sized AIFMs. A public consultation was also launched by the EC in parallel.

Considerations: The deadline for both consultations is 12 March 2026.

The Commission is due to complete a review of sustainability aspects of the European long-term investment funds Regulation by 11 January 2026.

Back to top

Recently adopted EU measures

On 8 January 2026, the Commission Delegated Regulation (EU) 2026/73 was published, simplifying reporting requirements under Article 8 of the EU Taxonomy Regulation. It applies from 1 January 2026 and amends relevant delegated acts to ease sustainable investment disclosure obligations.

On 16 December 2025, the Commission adopted Implementing Regulation (EU) 2025/2530, laying down rules for the application of Regulation (EU) 910/2014 (eIDAS) as regards requirements for qualified trust service providers providing qualified trust services.

On 17 December 2025, the Joint Committee of the European Supervisory Authorities published a joint report to the Commission advising that statutory auditors and firms are not warranted to be included within the DORA regime at this stage. They concluded that the negative impact of extending DORA to them outweighed the benefits.

On 17 November 2025, the Commission adopted Delegated Regulations on regulatory technical standards (RTS) on liquidity management tools under AIFMD and UCITS Directive. You can read more about these Delegated Regulations here, and here.

On 24 November 2025, the Commission adopted a Delegated Regulation on equity transparency under MiFIR. The proposed changes relate to criteria for identifying a liquid market for equity instruments, the obligation to provide market data on reasonable commercial basis, the specification of financial instrument size for systematic internalisers, and the definition and disclosure requirements for post-trade risk reduction.

On 26 November 2025, the Commission Implementing Regulation (EU) 2025/2263 was published, amending the standard forms and digital formats for automatic exchange of crypto-asset information between EU countries under DAC8. The Regulation takes effect on 1 January 2026.

Back to top

The European Supervisory Authorities (ESAs)

European Securities and Markets Authority (ESMA)

Key initiatives include the release of the ESMA Annual Work Programme 2026, the introduction of a Common Supervisory Action on conflicts of interest under MiFID II and renewed focus on ESG claims and greenwashing risks.

Other priorities include updated guidelines for liquidity management tools and stress testing for funds, risk-based supervisory principles, cross-border fund marketing data, and technical standards for derivatives and MiCAR implementation. Reports assess costs of investing in funds, depositary supervision, and outcomes of peer reviews.

Considerations: Review compliance with ESMA’s focus areas to get ahead on compliance and implementation of new processes where required.

European Banking Authority

Key initiatives include the release of the release of the European Banking Authority (EBA) Work programme 2026, the launch of consultations on supervisory processes, prudential standards for ancillary services and technical standards on material transactions under the Capital Requirements Directive.

The EBA also published this final report providing two sets of guidelines on internal policies, procedures, and controls that Payment Service Providers and Crypto-Asset Service Providers must implement to ensure compliance with EU and national financial sanctions when transferring funds and crypto assets under the Wire Transfer Regulation. These guidelines will apply from 30 December 2025.

Considerations: Monitor the EBA’s regulatory updates and where desired partake in the newly released consultations. 

Anti-Money Laundering Authority

Key initiatives include the release of the Anti-Money Laundering Authority (AMLA) Single Programming Document 2026-2028, the direct supervision of 40 EU financial institutions, and the implementation of new AML / CFT framework (see below).

The direct supervision programme will be launched in March to determine test risk assessment models with direct supervision beginning in 2028. The aim of this supervision is to ensure money laundering risks are adequately and consistently assessed across the EU. This exercise will include involvement at a national and private sector level from 2027 to begin the data collection process.

Other priorities include, becoming fully operational and effectively, strength cooperation and inclusiveness in the EU, and consolidating the EU's position as a global financial crime prevention leader.

The new AML Framework will consist of the following:

Regulation (EU) 2024/1620 (AMLA):

The AMLA Regulation establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism applies since 1 July 2025. The key enhancements that ALMA focuses on are:

• the setting up of AMLA to supervise high-risk cross-border financial institutions, with full supervision beginning in 2028
• the implementation of a harmonised approach to AML / CTF throughout the EU through the Single Rule (defined below)
• fully taking over AML/CTF powers from EBA

Regulation (EU) 2024/1624 (the Single Rulebook)

The Single Rulebook Regulation on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing will apply from 10 July 2027. The key enhancements that the Single Rule focuses on are:

• the replacement of patchwork transpositions of AML/CFT rules to ensure uniformity throughout the EU
• further due diligence rules regarding consumer verification and monitoring
• increased and new obligations for professional football clubs and high-value goods traders
• risk-based assessments and mechanisms regarding technological advancements and new forms of crime

Directive (EU) 2024/1640 (AMLD6):

An amending Directive on the mechanisms to be put in place by member states for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing will apply from 10 July 2027, with some exceptions. The key enhancements that AMLD6 focuses on are:

• central registers of beneficial owners holding more accurate data, with authorities having power to document inspections for verification purposes
• member states will have to provide Financial Intelligence Units (FIUs) and other relevant authorities wit single-point access to real estate registers
• FIUs will be granted more powers to block and suspend transactions and increase cross-border cooperation
• a clearer risk-based approach at both EU and domestic level is mandated 

Considerations: There is a huge emphasis being placed on improving and harmonising AML / CFT practices throughout the EU. An internal review of compliance framework should be carried out to ensure alignment with these standards. Risk assessments should be carried out to ensure all registers are adequately updated and all new due diligence measures are being followed.

Back to top