Welcome to the FIG Top 5 at 5

On 26 February 2026, the Central Bank of Ireland (“Central Bank”) published its Regulatory and Supervisory Outlook Report (“Report”). The Report sets out the Central Bank’s assessment of the key trends and risks that are shaping the financial sector. On foot of such assessment, the Report also details the Central Bank’s regulatory and supervisory priorities for the next two years.

As reported in the FIG Top 5 at 5 on 12 February 2025, Governor Gabriel Makhlouf wrote to the Tánaiste, Mr Simon Harris TD, by letter (“Letter”) dated 29 January 2026. The Letter set out the Governor’s views on the macro financial environment, the financial services landscape and the regulatory and supervisory priorities of the Central Bank for 2026. Stemming from that Letter, the Governor stated, in the Report, that the Report “sets out for the benefit of the Central Bank’s various stakeholders our latest view of how the accelerating changes in the global environment are shaping the risk landscape domestically and internationally and the key vulnerabilities we see across the sectors and firms we supervise.”

The Report is comprised of a number of sections as follows:

• section 1 is focused on the global macro environment, major trends and the drivers of risk;
• section 2 sets out the Central Bank’s assessment of the main risks for regulated entities and also for consumers and investors. It also has two “Spotlights” on specific topics as follows:
  • approaching AI from a supervisory perspective – this considers trends in AI and its adoption, specifically focusing on three aspects related to financial services, as follows: the deployment of agentic AI / AI related consumer protection risks / operational resilience; and
  • supporting resilient service provision, with the Central Bank highlighting that services resilience and effective ICT risk management are non-negotiable requirements so that financial services firms deliver on commitments to consumers and investors to maintain their critical services through disruption.
• section 3 addresses the Central Bank’s overarching supervisory priorities in the context of its safeguarding outcomes. This section also has a “Spotlight” addressing the supporting of better outcomes for consumers and investors, which reiterates that consumer and investor protection is at the heart of the Central Bank’s mandate; and
• section 4 is comprised of a sectoral focus, including the key areas of supervisory focus and main supervisory activities for: banking and payments; insurance and reinsurance; and markets and funds.

The Report also has a number of appendices, including one setting out the Central Bank’s key regulatory initiatives and another providing an overview of the AI landscape.

Risks

The Report identifies three main drivers of risk as follows:

1. macroeconomic and geopolitical environment – risk areas identified under this driver include: operational and cyber risks / financial risks including credit, liquidity, leverage and market risks.
2. the way in which regulated entities are responding to today’s changing world – risk areas highlighted in this category include: consumer and investor detriment risk / AI and modelling risks / financial crime / risk management practices.
3. longer term structural forces at play – risks identified here include: climate risks / business model and strategic risks.

The Report highlights that the Central Bank’s assessment is that operational risks remain at a very elevated level against a background of the current geopolitical position, the increase in digitalisation and increasingly complex operating models. As for asset valuation and market risks, the Report highlights that these have increased. Risks stemming from data, models and AI have also increased, while inflation and interest risks have decreased.

Cross Sectoral Supervisory Priorities

The Report sets out the Central Bank’s supervisory priorities, stating that they take account of the most material risks facing the financial system and supporting the Central Bank’s safeguarding outcomes. The five overarching supervisory priorities for 2026 are as follows:

• supervisory priority 1 – maintaining and building resilience to geopolitical risks and macro-financial uncertainties, covering work on matters such as: operational resilience / cyber security and financial resilience in the context of a volatile macro environment / how climate and environmental factors are being embedded in risk management, business models and governance.
• supervisory priority 2 – securing consumer and investor interests in a rapidly changing world addressing areas such as the customer experience / effect of digitalisation on consumers / financial crime.
• supervisory priority 3 – responding to technology-driven transformations, with the Report setting out that there will be a focus on the expanding use of AI, digital money and tokenisation.
• supervisory priority 4 – helping to address the environmental and societal transitions underway, including work on protection gaps / retail investment participation / sustainable finance.
• supervisory priority 5 – enhancing how the Central Bank regulates and supervises with a focus on its supervisory approach to ensure its effectiveness / improvements to gatekeeping / simplification as set out in its December 2025 publication “Regulating & Supervising well – a more effective and efficient framework”- for more information, see FIG Top 5 at 5 dated 11 December 2025.

In order to address the changing landscape, the Report emphasises that the Central Bank will continue to be outcomes-focused, risk-based and forward-looking, further highlighting that it expects firms to:

• maintain strong governance, risk management and operational resilience; and
• act in the best interests of their customers.

Dear CEO Letter – Key Regulation and Supervision Priorities 2026

On 26 February 2026, the Central Bank also issued a “Dear CEO” letter (“Dear CEO Letter”). The purpose of the Dear CEO Letter is to bring the Report to the attention of regulated firms and to outline the Central Bank’s regulatory and supervisory priorities for 2026.

Further to the above update on the Central Bank of Ireland’s (“Central Bank”) Regulatory and Supervisory Outlook Report (“Report”), the following sectoral specific priorities should also be noted:

Banking and Payments: Key Supervisory activities

The Report sets out five key areas of supervisory focus for the banking sector, as follows:

• business model and strategy, with some of the related planned activities as follows:
  • a reviews of banks’ corporate strategy setting, alignment with risk appetite and the credibility of the underlying assumptions;
  • an assessment of the impact of CRD6 article 21c on banks’ balance sheets. Supervisors will undertake tailored engagements with impacted banks depending on the nature, scale and complexity of any impact;
  • an assessments of banks’ strategies given the evolution in payments; and
  • an assessment of new bank licence applications in collaboration with the European Central Bank (“ECB”) as part of the Single Supervisory Mechanism (“SSM”).
• treatment of consumers, some of the main planned activities include:
  • a thematic review of the sale of products via banking apps with a focus on how banks identify and mitigate risk to consumers on a sample of products sold;
  • cross-sectoral thematic reviews on how customers are being informed effectively and on the treatment of customers in vulnerable circumstances; and
  • a cross-sectoral thematic review of customer service standards including, in the banking and lending sector, a review of the impact on customer service of supervisory actions arising from previous conduct-related thematic reviews.
• operational and cyber resilience, some of the main planned activities include:
  • supervisory assessment of cyber resilience remediation programmes;
  • tracking remediation of outsourcing deficiencies identified in previous reviews; and
  • continued engagement with banks and interventions where outages occur, including focus on communications, customer service and customers in vulnerable circumstances.
• financial resilience, some of the main planned activities here include:
  • an assessment of the AI landscape in the banking sector to build supervisory knowledge on AI use;
  • reviews of the remediation of shortcomings in the integration of climate and environmental risks into banks’ risk management frameworks, in addition to consideration of ESG transition plans; and
  • financial resilience assessments, incorporating capital position assessments, distribution strategies, securitisation, provisioning, liquidity, market risk and recovery planning.
• financial crime and market integrity, some of the main planned activities include:
  • an assessment of individual banks and aggregated sectoral data from the enhanced AML / CFT Risk Evaluation Questionnaire submissions;
  • targeted supervisory engagements, including inspections, desk based reviews and review meetings; and
  • cross-sectoral thematic review of controls on certain types of fraud as well as the fair treatment of customers who fall victim to fraud.

Payments and E-Money Supervisory activities

As with the banking sector, the Report sets out five key areas of supervisory focus in this area and identifies the main planned activities related to each area of focus. The areas of focus, and some of the activities, are as follows:

• Safeguarding of customers’ funds, planned activities include:
  • an assessment of the actions taken by firms to address identified gaps in safeguarding processes and procedures; and
  • an assessment of firms’ implementation of the new head of safeguarding PCF role.
• Financial crime, planned activities include:
  • an assessment of the adequacy and effectiveness of AML / CFT risk management frameworks through AML inspections, targeted and thematic reviews and financial crime review meetings.
• Business models and financial resilience, planned activities include:
  • a thematic review of financial resilience, including strategic planning and wind down planning.
• Operational and cyber resilience, planned activities include:
  • the issuing of feedback on the thematic review of the governance and effectiveness of IT outsourcing;
  • supervisory assessment of DORA reporting, including registers of information and major incident reporting; and
  • a focus on the implementation and development of incoming regulations and initiatives, in particular the Payment Services Directive and Payment Services Regulation.
• Culture, governance and risk management, planned activities include:
  • an assessment of board composition, resourcing levels and governance structures; and
  • a thematic review of the operation of distributors and agents model.

Insurers and Reinsurers: Key Supervisory activities

Five key areas of supervisory focus are identified by the Report for this sector and the main planned activities related to each area of focus are highlighted. The areas of focus, and some of the activities, are as follows:

• Treatment of customers, planned activities include:
  • a thematic review of customer service levels in the domestic non-life sector and complaints handling in the domestic life and domestic non-life sectors (this is continued from 2025);
  • a cross-sectoral review of a range of commission arrangements in the sale of products and services to customers through intermediaries;
  • a thematic review of aspects of new business administration processes in the domestic life sector (this is continued from 2025); and
  • a thematic review in the domestic life sector as to how customers are being informed effectively.
• Financial resilience, with some of the planned activities as follows:
  • a Solvency II Review survey will issue to all (re)insurance firms (except captives), focusing on the expected impact of Solvency II changes, and to ascertain how many firms intend to apply for proportionality measures;
  • a supervisory review of investment risk in the domestic non-life sector; and
  • a cross-sectoral review of pricing, underwriting and reserving practices for international and reinsurance firms.
• Digitalisation and artificial intelligence, planned activities include:
  • engagement with individual firms on their current use of and strategy for AI; and
  • supporting the effective implementation of the EU AI Act and incorporation within supervisory strategies across all insurance sectors.
• Climate change and sustainability, planned activities include:
  • a cross-sectoral review of how international insurance and reinsurance firms have integrated climate change risks into their business model, strategy and underwriting practices; and
  • monitoring (re)insurance firms’ progress on the integration of climate change risks into their risk management and governance frameworks and assessment of climate change risk.
• Operational and cyber resilience, planned activities include:
  • thematic reviews of operational resilience in the international insurance sector and in the domestic life sector; and
  • a thematic review of domestic non-life insurers to assess ICT risk management.

MiFID Investment Firms Sector: Key Supervisory activities

2026 will see the Central Bank focused on five supervisory focus areas, set out below. The Report also includes planned supervisory activities, some of which are detailed below under the corresponding area of focus.

• Operational and cyber resilience, some planned activities include:
  • engagement with certain SREP category 1 and 2 firms in relation to IT risk management frameworks, DORA implementation and cyber resilience; and
  • supervisory assessment of DORA incident reporting and registers of information annual submission.
• Conflicts of interest, planned activities include:
  • participation in the ESMA common supervisory actions on conflicts of interest in the distribution of financial instruments.
• Treatment of investors, some planned activities include:
  • a focus on the new Consumer Protection Code (“CPC”) and related guidance as regards how it will be embedded into supervisory practices and firm engagements;
  • a thematic review of complaints handling began in Q4 2025. This review will consider how firms deal with individual customer complaints and use management information to identify trends and mitigate against recurring issues; and
  • the deployment of an enhanced conduct of business return to support the Central Bank’s data driven approach to supervision.
• Artificial intelligence, some planned activities include:
  • supporting any future work and surveys undertaken by ESMA on AI.
• Financial crime, some planned activities include:
  • a thematic review of a sample of MiFID investment firms to be included in a market abuse frameworks and surveillance thematic review alongside other sectors;
  • reviews of venue and firm trade surveillance implementations and frameworks; and
  • firms with higher impact ML / TF ratings are subject to cyclical reviews, such firms may be subject to inspection and/or review meetings during the year.

Retail Intermediary Sector: Key Supervisory activities

The Central Bank’s five supervisory focus areas for the retail intermediary sector are set out below. Some of the main planned activities are also set out under the corresponding supervisory focus area:

• Operational and cyber resilience, planned activities include:
  • integrated supervision of larger retail intermediaries owned by health insurers, with a continued focus on digital and operational resilience.
• Treatment of customers, planned activities include:
  • the continuation of a cross-sectoral customer experience review, that was commenced in 2025, with a focus on the customer support that firms, including retail intermediaries, have for engaging with customers.
• Unregulated products and services, planned activities include:
  • a review of the provision of unregulated services and products by retail intermediaries, to understand how firms are meeting the new requirements and expectations in the CPC and related guidance.
• Commission and remuneration, planned activities include:
  • a cross-sectoral review of a range of commission arrangements in the sale of products and services to customers through intermediaries, to understand how they are working to secure customers’ best interests, to include engagement with, and data gathering from, product producers and providers.
• Business model and strategy, the main planned activity is:
  • a review of consolidation in the market at a sectoral level to gauge the impact on consumers and identify any emerging trends or risks.

1. Governor Makhlouf publishes blog post focused on resilience and stability

On 27 February 2026, Governor of the Central Bank of Ireland (“Central Bank”), Gabriel Makhlouf, published a blog post (“Blog”) focused on building economic resilience. The Governor also addressed access to cash, the independence of central banks and the Central Bank’s work programme for 2026.

Resilience

The Governor highlighted that building economic resilience is “not optional but rather a prerequisite for sustained prosperity for Ireland’s financial system, and for households and firms navigating a rapidly shifting global landscape.”

In terms of the macro-financial landscape and actions required to strengthen Ireland’s economic resilience, the Governor referred to his letter of 29 January 2026 to the Tánaiste and Minister for Finance – for more information, see FIG Top 5 at 5 dated 12 February 2026.

The Governor also referred to the Regulatory and Supervisory Outlook Report 2026 (“Report”) and stated that the Report sets out, in greater detail, the Central Bank’s perspective on the key trends and risks that are influencing the operating landscape for the financial sector.

Access to Cash

Governor Makhlouf referenced the recent access to cash report, stating that ensuring appropriate access to cash is part of building a resilient financial system – for more information, see FIG Top 5 at 5 dated 26 February 2026.

Independence

The Governor highlighted his recent remarks on the role of central banks as institutions and the concept of independence – for more information, see FIG Top 5 at 5 dated 26 February 2026. In the Blog, he concluded that a central bank’s institutional credibility, which anchors confidence, serves to support financial stability and well functioning markets.

Work programme 2026

Noting that the Central Bank’s work is continuing against a background of rapid and complex change, the Governor highlighted some priority areas of work, as follows:

• maintaining access to cash is a practical priority within the payments landscape;
• building economic resilience is a strategic imperative;
• safeguarding the principles that underpin central bank independence; and
• continued engagement with the public and with the Government as it prepares to host the EU presidency.

2. Central Bank welcomes publication of OECD consumer finance risk monitor 2026

On 2 March 2026, the Central Bank of Ireland (“Central Bank”) published a press release (“Press Release”) welcoming the publication of the OECD’s consumer finance risk monitor 2026 (“Monitor”).

The Monitor looks at trends and challenges affecting financial consumers in 60 jurisdictions, including Ireland, and discusses responses for policymakers, regulators and supervisors.

Some of the main points highlighted in the Monitor include the following:

• digitalisation offers many benefits for financial consumers, but it can also intensify scams and frauds, drive financial exclusion and disrupt customer service channels;
• high levels of consumer debt, and its cost, are a major risk for the resilience of households;
• low levels of financial literacy are the most significant demand-side risk to financial consumers, identified by 81% of jurisdictions;
• ineffective disclosures represent the most significant conduct-related risk, identified by 44% of responding jurisdictions;
• financial scams and frauds are the leading operating-environment risk currently facing consumers, identified by 85% of responding jurisdictions; and
• financial products and services are becoming increasingly complex, and complaints are generally rising, with the total volume of consumer complaints received by supervisory authorities increasing in 70% of responding jurisdictions between 2024 and 2025.

Enhancing safeguards

Colm Kinkaid of the Central Bank, and also Chair of the OECD working party on financial consumer protection, education and inclusion, stated:

“Today’s report from the OECD echoes many of the specific consumer and investor protection risk areas the Central Bank of Ireland highlighted this week in our Regulatory and Supervisory Outlook report… In the area of financial scams and fraud, technology is providing criminals with new and innovative ways to harm consumers. In the face of this, regulated financial institutions must continue to enhance their safeguards against fraud and put better supports in place for consumers who fall victim to fraud.”

Evidence

Mr Kinkaid also highlighted that the Monitor is an important source of evidence to inform the Central Bank’s regulatory and supervisory responses, further stating that the Central Bank is engaging in specific work regarding each of the key themes identified by the OECD at a global level.

In that regard, the Monitor identified actions for policymakers, regulators and supervisors, some of which are as follows:

• ensure effective and comprehensive financial consumer protection frameworks are in place at national level;
• ablish and strengthen market conduct supervision and enforcement functions and capabilities;
• strengthen system‑wide approaches to tackling financial scams and frauds;
• develop clear policies and regulatory expectations for new types of financial products and services, including for example digital assets, digital credit, Buy Now Pay Later, and AI‑enabled financial services; and
• encourage international policy, regulatory and supervisory knowledge-sharing and cooperation.

Mr Kinkaid also highlighted the work of the Central Bank as regards scams and frauds regarding the SAFE test and also its work as regards building financial literacy by supporting the work of the Government on the National Financial Literacy Strategy – for more information, see FIG Top 5 at  dated 27 February 2025.

On 3 March 2026, the Financial Services and Pensions Ombudsman Act 2017 [Financial Services and Pensions Ombudsman Council] Financial Services Industry Levy Regulations 2026 (“Regulations”) were published in Iris Oifigiúil.

The Regulations provide:

• that each financial service provider is liable to pay an annual levy in respect of the services provided by the Office of the Financial Services and Pensions Ombudsman (“Office”) to the financial services industry;
• for the collection and recovery of the levy;
• for certain obligations as regards information to be provided to the Office to enable it to assess the levy to be paid by certain financial service providers;
• for certain record keeping by financial service providers; and
• for the calculation of the required levy contribution payable by each category of financial service provider for the year ended 31 December 2026.

The Schedule to the Regulations details the different categories of financial service providers and how their required levy contribution for the year ended 31 December 2026 is calculated.

Some of the applicable levies are as follows:

Credit institutions

• a levy calculated at the rate of €0.798 per consumer, where the underlying contract between the credit institution and the consumer is based on Irish law, as at 31 December 2024.

Insurance undertakings

• life assurance undertakings: a levy calculated on the basis of a sum no greater than 0.0061% of its total gross premiums earned from Irish risk business, and where the underlying contract between the life insurance undertaking and the consumer is based on Irish law, for the year ended 31 December 2024;
• non-life assurance undertakings (other than captive insurers): a levy calculated on the basis of a sum no greater than 0.0615% of its total gross premiums earned from Irish risk business other than private health insurance contracts where the underlying contract between the non-life insurance undertaking and the consumer is based on Irish law for the year ended 31 December 2024; and
• non-life assurance undertakings (as regards liability for health insurance): a levy calculated on the basis of a sum no greater than 0.0214% of its total gross premiums derived from Irish private health insurance business where the underlying contract between the non-life insurance undertaking and the consumer is based on Irish law for the year ended 31 December 2024.

Payment institutions and e-money institutions

• a levy of €5,000.

Investment business firms (other than investment product intermediaries)

• a levy calculated on the basis of a sum equal to 3.2920% of the annual industry funding levy payable to the Central Bank of Ireland (“Central Bank”) by the financial service provider for 2024.

Intermediaries and debt management firms

• a levy calculated on the basis of a sum equal to 15% of the levy payable to the Central Bank for 2024. Intermediary and debt management firms which were levied the minimum amount by the Central Bank for 2024 under SI No 358/2025 – Central Bank Act 1942 (section 32D) Regulations 2025, are exempt from the levy for the year ended 31 December 2026.

Next Steps

These Regulations come into operation on 6 March 2026.

On 2 March 2026, Minister of State at the Department of Finance (“Department”), Robert Troy TD, launched the motor insurance transparency code (“Code”).

Background

The Code is a priority action under the action plan for insurance reform 2025 – 2029 (“Action Plan”). The Action Plan, which was published in July 2025, identified a programme of 26 actions targeted at improving affordability, transparency, competition and availability in the insurance market – for more information, see FIG Top 5 at 5 dated 31 July 2025.

Code objectives

The Code is aimed at making motor insurance pricing clearer, fairer and easier for consumers to understand. In this regard, the Code builds on exiting Irish law, for example, the Consumer Insurance Contracts Act 2019, and sets out new measures to improve transparency, consistency and consumer confidence. Some of the objectives, highlighted in the Code, include:

• the provision of accessible and concise explanations of market conditions, such as claims costs, repair inflation, and legal-expense trends, based on publicly available data;
• to support consumers in making more informed decisions around their premiums;
• to improve alignment between insurers’ communications and consumer protection objectives; and
• to provide consumers with the necessary information such that they can understand what is within their control to lower their individual risk profile and consequently, improve their premium.

Voluntary

All insurers and intermediaries writing or selling private motor insurance policies in Ireland, including all cross-border entities and intermediaries, may sign up to the Code. By signing up to the Code, an insurer, or intermediary, commits to the practices set out in the Code.

The Code highlights that, while it applies to private motor insurance policies only, insurers and intermediaries are encouraged to consider its application to other insurance products, as relevant.

Key Features

Some of the key features of the Code are as follows:

• a new premium summary statement is to be provided, at quotation and renewal, detailing the previous year’s premium, the difference and the main factors influencing the price;
• an annual market overview statement which is to provide consumers with a clear, high-level explanation of the broader market conditions that influence motor insurance premiums across Ireland;
• a summary of the factors that consumers can control or influence will be provided, which may help reduce their insurance premium, without straying into an advice role, where relevant; and
• clear information on the broad reasons for declining insurance applications is also to be provided.

 

Consumer protection code 2025

The Code sits under the Central Bank of Ireland’s (“Central Bank”) consumer protection code 2025 (“CPC”) which sets out a new standard for business requiring firms to seek to effectively inform consumers in their disclosures and communications. The Code highlights that, by becoming a signatory to the Code, it may contribute to meeting the overall requirements as to informing effectively under the CPC.

Welcoming the publication of the Code, Tánaiste and Minister for Finance, Simon Harris TD, stated:

“…The Code seeks to align with relevant disclosure requirements and requirements to inform customers effectively which will apply to insurers and intermediaries under the Central Bank’s revised Consumer Protection Code (“CPC”). The revised CPC comes into effect on 24 March this year and will be legally binding on insurance companies and intermediaries. The Central Bank’s Administrative Sanctions Procedure will be applicable in respect of non-compliance with the revised CPC”.

Industry reaction

Insurance Ireland published a press release on 2 March 2026, confirming its commitment to supporting the Code, describing it as a “…significant milestone in Insurance Ireland’s ongoing collaboration with the Department of Finance and the Central Bank to enhance transparency and deliver better outcomes for consumers.”

Next steps

Insurers and intermediaries are preparing for a phased implementation of the Code and updating relevant documentation as necessary. The Code will be subject to review within 18 months and the Central Bank will provide a report to the Minister for Finance regarding adherence to the Code and its impact.