IRELAND Law and Practice Contributed by: Grainne Callanan, April McClements and Aisling Kavanagh, Matheson LLP
it will be completing work in relation to risk trans- fers and value for money, and reviews of pricing discipline, adequacy of reserves and capital; • sectoral supervision focusing on the monitoring of the potential impacts of changes in financial mar- kets and the macroeconomic environment on the insurance sector and its consumers. • assessing firms’ reliance on parent groups for ser- vices and capital support; • assessing the embedding of DORA requirements and adherence to the Central Bank’s Cross Indus- try Guidance on Operational Resilience; • reviewing the use of AI in pricing and underwriting processes; and • as regards the Solvency II review, industry partici- pants will be asked to engage in an assessment of the expected impacts in terms of quantitative elements as well as qualitative elements. Individual accountability The IAF Act was enacted on 9 March 2023 and aims to support the advancement of an improved culture in the Irish financial system through greater account- ability in the regulated sector. On 16 April 2024, the CBI published its final related Guidance on the IAF as well as a statutory instrument in relation to its Senior Executive Accountability Regime (the “SEAR Regula- tions”). 2024 was the year of embedding the IAF. Firms that fell within the scope of the SEAR Regulations had to be compliant by 1 July 2024. 2025 saw the application of the confirmation of com- pliance with the certification process in respect of pre- approval controlled functions (PCFs) and controlled functions as of 1 January 2025, and independent non- executive directors and non-executive directors came into scope from 1 July 2025. In its November 2025 Investment Firm and Interme- diary Newsletter (Newsletter), the CBI provided an update on the implementation of the IAF, highlighting that industry feedback in relation to the implementa- tion of the framework has been consistently positive, with industry representatives acknowledging the ben- efits of the regime. Further, the CBI stated that it has
seen positive internal changes in firms on the basis of the IAF framework. It was also highlighted that extending the senior exec- utive accountability regime to non-executive directors, including to independent non-executive directors (“(I) NEDs”), requires firms to allocate applicable pre- scribed responsibilities to (I)NEDs, and to ensure that each (I)NED has a documented statement of respon- sibilities. The CBI also stated that it is of the view that the expectations of (I)NEDs under the new framework are fully consistent with their existing responsibilities under the corporate governance framework and that the standards to be met relate purely to non-executive oversight functions and are limited to what should rea- sonably be expected of individuals in that context. CBI publishes F&P standards and Guidance on the Standards of F&P In April 2025, the CBI launched a consultation (CP 160) on revisions to its Fitness and Probity (F&P) Regime. CP 160 stemmed from the recommendations made in the Enria report, following Mr Andrea Enria’s inde- pendent review of the CBI’s F&P assessment process, the results of which were published in July 2024. On 25 November 2025, the CBI published its updat- ed F&P Standards (Standards) and accompanying Guidance on the Standards of F&P (Guidance). The Standards and Guidance were finalised following the completion of CP160. While the Standards have now been consolidated and incorporate the provisions in respect of Credit Unions that were previously published in a separate docu- ment, the substance of the Standards themselves has not otherwise changed. The consolidation of the Guidance is in line with the recommendations included in the Enria Report. Spe- cifically, the CBI has now consolidated all guidance relating to the F&P Regime into a single document, including cross-references to other relevant guidance and guidelines that address the F&P Regime, thereby providing assistance to firms in complying with their obligations.
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