IRELAND Trends and Developments Contributed by: Grainne Callanan and Elaine Long, Matheson LLP
Other Relevant Developments Artificial Intelligence
• It was confirmed that the requirement to issue a pre-renewal reminder/notification in respect of insurance products 20 working days ahead of the date on which the full renewal notice is required will remain. • A requirement for health insurance providers to notify all affected adults of a cancellation of cover was introduced. More generally, changes and clarifications to Addi- tional Policy Proposals that are also worth noting have been outlined below. • Regarding the handling of errors and complaints, it was confirmed that the frequency of complaint analysis will remain at six months. However, it was also confirmed that the Central Bank will apply the principle of proportionality in terms of the approach to be taken, and expects that firms will carry out this analysis in a manner appropriate to the nature and scale of their business, and to the volume and complexity of errors and complaints to be ana- lysed. The General Guidance provides more clarity as to what might constitute a ‘significant error’, as follows. • With retention of records, it was confirmed that the record-keeping requirements applicable in cases where a consumer engages with a firm but does not proceed to become a customer will remain at the proposed 12-month period. The require- ment was amended to clarify that it applies only to records created after the regulations commenced. • It was confirmed that the proposal to require firms to acknowledge instructions within three days of receipt will not be adopted. • The proposal to change the requirement on firms to provide at least 2 months’ notice to affected consumers where they intend to cease operating, merge with or transfer regulated activities to anoth- er entity by increasing it to at least six months’ notice will not be adopted. • Guidance has been developed to support firms in implementing the updated suitability assessment requirements.
Throughout 2025, the Central Bank frequently addressed artificial intelligence (AI) in the context of regulation and other evolving topics. In its February 2025 Regulatory and Supervisory Outlook Report (“RSO”), one of the Central Bank’s stated key supervisory objectives is to keep abreast of how the use of AI is creating new value chains, business models, techniques and processes. Further, the RSO set out that, through its regular supervisory engagement and its innovation hub, the Central Bank will continue to engage with firms to understand how AI is being used in practice and provide regulatory advice and support for innovative projects, articulating its approach in this area as one of being responsive to evolving circumstances. An examination of Central Bank speeches is helpful for gauging the Central Bank’s focus in the sphere of AI. Governor of the Central Bank, Gabriel Makhlouf, in an October 2025 speech, noted the rapid change the financial sector has undergone over the last number of years, not least due to technological innovation, specifically mentioning the rapid evolution of AI and its use. At the September 2025 European Insurance Forum, Seána Cunningham, Director of Insurance at the Central Bank, highlighted that the insurance indus- try has long been at the forefront of using data and statistics to support risk-based decision-making. She went on to remark that the management of new data and technologies, particularly those using GenAI, will mean that firms will need to carefully consider the ethical and responsible use of such tech, including the governance and controls needed to effectively oversee their use. She went on to address the regula- tors’ position, stating that the Central Bank will focus on developing a deeper understanding of AI use in the insurance sector and on assessing whether firms have the necessary governance and risk management measures in place to make the best use of innovation in a responsible way.
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