IRELAND Law and Practice Contributed by: Grainne Callanan, April McClements and Aisling Kavanagh, Matheson LLP
with the use of separate legal entities for the provision of extensive staffing to the undertaking (usually part of the same group as the undertaking) and highlighted that the CBI is focused on such arrangements, due to their potential to undermine the operational resilience of regulated entities, if not effectively managed. Under this heading, the CBI emphasised the impor- tance of compliance with its 2022 Guidance on the Use of Service Companies for Staffing Purposes in the Insurance Sector and its 2021 Cross Industry Guid- ance on Outsourcing for firms with hybrid staffing arrangements. The CBI highlighted that, although the Assessment related to speciality insurance firms, the risks, expec- tations and findings set out by the CBI are relevant to all (re)insurance firms with significant intra-group outsourcing arrangements in place. The CBI issued a “ Dear CEO Letter” to all speciality firms, setting out the main messages of the Assess- ment and stating that, where relevant, individual risk mitigation programmes and recommendations were issued to firms. CBI reduces Insurance Compensation Fund levy On 3 October 2025, the CBI announced that the Insurance Compensation Fund levy (Levy) would be reduced from 2% to 1% as of 1 January 2026. This is the first change to the Levy in 14 years, and the CBI noted that the reduction will positively affect many customers with non-life insurance policies, such as home and motor insurance (where the motor insur- ance provider is regulated by the CBI). The CBI has stated that it is the responsibility of insur- ance firms to pay the correct levy and stressed the importance of being ready to implement the Levy change from 1 January 2026. The CBI expects firms to act in consumers’ best inter- ests. As regards firms which explicitly pass the levy on to policyholders as a separate charge listed within their documentation, the CBI expects that the reduction is reflected in the policy from 1 January 2026 onwards.
This expectation is also applicable to current policies, which are paid in instalments into 2026, and where the Levy charge is explicitly stated within the policy, the Levy should be updated to reflect the reduction from 1 January 2026. Central Bank publishes roadmap for more effective and efficient regulation and supervision On 10 December 2025, the CBI published a document (“Roadmap”) entitled “Regulating & Supervising well – a more effective and efficient framework”. The Road- map sets out the Central Bank’s simplification agenda, describing it as a multi-year, disciplined programme. The Roadmap refers to the Draghi and Letta reports and the renewed focus on competitiveness and resil- ience, with the European simplification agenda form- ing part of this. The Central Bank has conducted an assessment of areas for simplification and improvement, with the Roadmap outlining its current and intended direction of travel. The Roadmap provides an overview of how the CBI will, in line with initiatives across Europe, enhance the effectiveness and efficiency of its supervision and domestic regulatory framework, improve gatekeeping processes, and deliver a more integrated and less bur- densome reporting and data framework. These initia- tives form part of a multi-year programme aligned with the Central Bank’s strategic commitment to transform regulation and supervision. The Roadmap highlights that the simplification meas- ures set out will, amongst other things, contribute to: • maintaining and strengthening resilience; • a regulatory framework that is clearer, simpler, and more coherent, aligned with the evolving European system; • greater and better demonstrated proportionality; • improved effectiveness and efficiency of supervi- sion; and • more predictable processes and procedures for firms, including for initial authorisations.
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