Welcome to the FIG Top 5 at 5

On 25 August 2026, the Department of Finance (“Department”) published the new Ireland for Finance Strategy (“Strategy”), entitled, “Vision 2030 – Renewed and Refocussed for a Digital Age”. The Strategy comes on foot of previous such strategies and is focused on driving further progress as regards Ireland’s international financial services sector until 2030.

Consultation

The Department consulted on the Strategy in July 2025 – for more information, see FIG Top 5 at 5 dated 24 July 2025. There were 57 submissions received and over the consultation period, 11 ministerial roundtables were held with industry bodies, together with international stakeholder engagement via foreign visits by Minister of State, Robert Troy.

Core ambitions

Highlighting the importance of Ireland retaining its position as one of the leading financial services locations, in the context of an increasingly complex and uncertain geopolitical environment, the Strategy aims to strengthen this position and further Ireland’s reputation as a stable and predictable location for international financial services. This goal is centred around four core ambitions, as follows:

• to be a trusted, predictable and stable location for international financial services;
• to deepen expertise to enable economic growth in Ireland and the EU;
• to leverage technology to support digital transformation; and
• to develop links between the international financial services sector and Irish businesses and citizens.

The Strategy states that these ambitions will be supported by targets and key performance indicators, together with 31 actions, aimed at developing stronger competitiveness.

Key actions

The 31 actions will support the timeliness of financial services legislation, simplify regulatory and taxation frameworks, facilitate transformation and innovation, and deepen skills and talent pools. The Strategy highlights that the actions are complimented by actions being taken by other Government departments and state agencies, all, ultimately, focused on enhancing Ireland’s competitiveness.

The actions are set out under the following areas: legislation / financial regulation / international banking / international and speciality insurance / digital assets and tokenisation / sustainable finance / transformation and innovation / skills and talent / enhancing links to businesses and citizens / governance / international engagement.

Some of the key high priority actions as regards legislation are as follows:

• the Department will support efficient and timely transpositions of financial services legislation, with a focus on high impact legislative files;
• supporting the development of tokenisation of investment funds, which will foster innovation;
• modernisation of the 1907 Limited Partnership Act to support growth in private assets, particularly investment in venture capital;
• establishment of a policy delivery forum to provide industry stakeholders with a forum to engage on issues related to financial services legislation; and
• the Department will collate a rolling multi-annual legislative plan to outline the status and indicative timelines for proposed financial services legislation.

In terms of financial regulation, the Strategy sets out that the Department will work closely with the Central Bank of Ireland (“Central Bank”), and industry, on the implementation of the Central Bank’s simplification roadmap, the industry levy consultation and the introduction of a new regulatory impact assessment – many of these matters have been covered in the FIG Top 5 at 5 over the last number of months.

In the area of international banking, the Strategy states that the Banking and Payments Federation will support the international engagement work of Government in targeted locations coordinated through the high quality management team (“HQMT”).

When it comes to international and speciality insurance, the following actions are set out:

• to support the growth of the specialty insurance sector, a speciality forum to deepen engagement has been established in conjunction with Insurance Ireland; and
• Insurance Ireland will support the international engagement work of Government, coordinated through the HQMT and the office to promote competition in the insurance market.

As a high priority action in the area of digital assets and tokenisation, the Strategy states that the Department will strengthen its engagement with industry on digital assets policy through periodic specific roundtables, including with key international stakeholders. This will include the convening of a digital assets industry group.

The Strategy also sets out actions under the area of transformation and innovation, two of which are marked as high priority, as follows:

• Enterprise Ireland will examine how the national start-up hub can support the international financial services sector and the fintech ecosystem with engagement from the Department of Finance and Industry; and
• the Department’s remit will actively support innovation in financial services. Development of an innovation desk within the Department will be considered.

The Strategy also sets out actions under a governance category, some of which are as follows:

• the joint committee will be reduced in size and focus on: (1) assessing progress against a range of KPIs (2) horizon scanning for emerging trends and (3) consideration of new policy proposals. This is marked as a high priority matter;
• coordinated international engagement and promotion with financial services trade associations, supplementing work already undertaken; and
• the Central Bank will liaise with public bodies to support the communication of the Central Bank’s approach to its mandate internationally.

Keeping track of progress

The Strategy sets out that progress will be reflected in a published annual state of the IFS sector report, to be considered at a subgroup on International Financial Services within the Cabinet Committee on the Economy, Trade and Competitiveness and through refreshed Ireland for Finance governance structures. Publication of the report will take place by the end of February each year.

Commentary

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

“International financial services are a major Irish success story. Employment in the sector has grown from around 35,000 when I launched IFS2020 in 2015 to more than 60,000 today. Our ambition now is to build on that success and grow employment to 70,000 by 2030, with one in four of those jobs located in the regions. But we cannot take that success for granted. Technology is transforming financial services, competition for investment is intensifying and the global environment is changing rapidly. Ireland has to move with that change and stay ahead of it. That is why this strategy is firmly focused on competitiveness. Its 31 actions will help cut red tape, simplify regulatory and taxation frameworks, accelerate important financial services legislation, support innovation and ensure we have the skills needed for the next phase of growth.”

On 29 July 2026, the Central Bank of Ireland (“Central Bank”) published its feedback report (“Report”) following its cross sectoral thematic review (“Review”) of the customer experience through the lens of customer complaints. The scope of the Review included a range of firms across domestic life and non-life insurance, retail intermediary and payment institution / e-money sectors.

The Central Bank had previously flagged its intention to carry out the Review in its February 2026 Regulatory and Supervisory Outlook Report – for more information, see FIG Top 5 at 5 dated 5 March 2026.

Overall, the Report shows that across all sectors, in scope of the Review, all firms have frameworks in place for dealing with customer complaints but that action is needed to improve the customer experience when it comes to how complaints are managed end to end, including post resolution actions firms should take and how firms use and learn from complaints management information.

Securing customers’ interests

The Report highlights that the Central Bank, in carrying out its supervisory work, continues to see cases across all sectors where consumers do not always receive the quality of service that they should. This poor customer service, the Report goes on to explain, can create potential consumer risks and lead to an increased risk of consumer harm. In this regard, the Report points to the fact that complaints to the Financial Services and Pensions Ombudsman (“FSPO”) are rising yearly, with around 50% of complaints linked to customer service.

The Report reminds regulated entities of their duty to secure customers’ interests under the Consumer Protection Code (“CPC”), including the requirement to resolve any complaints from consumers efficiently, fairly and in a timely manner. The Central Bank expects firms to:

• fulfil their complaint resolution obligations under the CPC and other relevant regulations; and
• use the complaints handling process as a means to monitor, address and learn from consumer risks more generally.

Areas reviewed

The Review considered a number of key areas, including:

• complaints handling, examining the end to end complaint journey and the approach taken by firms to resolving complaints. A sample of individual customer complaint files were also looked at to assess how customers were treated; and
• complaints management information (“MI”) – here, the Review examined how firms use MI to monitor and manage risks, learn from complaints and trends, understand the underlying drivers giving rise to complaints.

Findings and expectations

The Report identifies four “headline findings”, and sets out corresponding expectations, as follows:

• Failure to identify and resolve complaints – some of the matters highlighted here include:

• • some firms failed to identify a complaint at the earliest opportunity when customers were clearly expressing dissatisfaction, either in writing or orally – firms did not consistently identify and / or record these interactions as complaints, and often not until much later in the engagement with the customer on the same issue;
  • in some cases, customers were not advised of the option to have an oral complaint treated in line with the firm’s complaints procedures; and
  • there were instances where complaints were deemed to be ‘closed’ by the firm, despite not being effectively investigated and resolved.

Under this finding, some of the Central Bank’s expectations are as follows:

• • firms must comply with all regulatory requirements relating to complaints handling and complaints management;
  • a firm must have regard to its obligation to implement the formal complaints procedure for consumers as outlined in the CPC;
  • regulated firms must correctly categorise complaints, as distinct from queries, or negotiations on price; and
  • firms should examine their complaints handling processes and procedures on foot of the findings of the Review and should ensure that all staff dealing with customers have adequate training to identify and act on a customer’s expression of grievance or dissatisfaction. In that regard, firms are advised to ensure that all such complaints are being correctly logged and included in returns to the Central Bank.

• Ineffective engagement – some of the matters highlighted here include:

• • ineffective engagement with customers was identified as an issue across all sectors;
  • some firms took a disproportionate amount of time to resolve issues, even though the issues complained of were relatively straightforward, resulting in a prolonged complaint process for the customer; and
  • some firms did not follow up on requests and / or engage with customers as promised, and customers needed to engage with the firm multiple times to have issues resolved.

Under this finding, some of the Central Bank’s expectations are as follows:

• • firms must communicate clearly, effectively and in a timely manner as per regulation 4(1)(e) and regulation 9 of the Standard for Business Regulations;
  • firms should endeavour to fully understand the issue that a customer engages on at the earliest point of engagement to ensure that it can be dealt with effectively and that the communication with the customer is clear and deals with the issue(s) raised;
  • firms should examine their governance and control frameworks, processes and procedures with a view to ensuring they are effective so that complaints are dealt with quickly, fairly and efficiently as per the CPC; and
  • firms should ensure there is adequate staff training on effective engagement, including training on dealing with vulnerable customers.

• Ineffective root cause analysis – some of the matters highlighted here include:

• • some firms may not be effectively identifying the root cause of complaints which results in the potential that underlying issues are not being uncovered and resolved for all customers. This can also mean that some complaints are incorrectly being categorised as individual, isolated cases.

Under this finding, some of the Central Bank’s expectations are as follows:

• • a proactive approach should be taken when it comes to identifying the underlying root causes of complaints through an effective root cause analysis – particularly where complaints are repeatedly occurring;
  • firms should have and use, appropriate and timely MI and should implement structured reporting arrangements to the board of directors and / or senior management;
  • firms should examine their governance, controls, processes and procedures to ensure it is clear when and how a root cause analysis should be undertaken, and who is responsible for such reviews; and
  • firms should assess whether their initial corrective actions constitute clear accountability for remediation and evidence of learning from the issue, or if further intervention is required.

• Quality assurance effectiveness – some of the matters highlighted here include:

• • it was found that whilst firms demonstrate quality assurance (“QA”) activity as regards complaints, there were variances in the effectiveness of firms’ QA approaches, for example, firms relying on front line QA and peer reviews could result in some systemic issues not being identified or mitigated; and
  • in some cases, deficiencies were not captured by the firm’s QA activities, for example, timeline breaches, ineffective resolution of complaints and ineffective engagement with customers.

Under this finding, some of the Central Bank’s expectations are as follows:

• • firms should have effective complaints handling QA processes in place;
  • there should be sufficient independent oversight to ensure that any issues in complaint identification, resolution and customer engagement are identified and mitigated; and
  • firms should establish ways to embed QA findings into training and continuous improvement initiatives.

Next Steps

The Report emphasises that all firms in all sectors should review and consider its findings and, in that context, should examine their complaints handling processes and how they engage with customers to effectively resolve complaints. In the event that gaps or weaknesses are identified, firms should develop and implement actions to mitigate any risk and improve the customer experience. Any such weaknesses may need to be escalated within the firm, depending on their significance.

On 18 August 2026, the Central Bank of Ireland (“Central Bank”) published guidance (“Guidance”) on appropriate and sustainable alternative repayment arrangements (“ARAs”) under the Consumer Protection Code 2025 (“CPC 2025”) as regards mortgage arrears.

The Guidance references the Code of Conduct on Mortgage Arrears (“CCMA”), highlighting that the CCMA has now been incorporated into the CPC 2025 – with the CCMA now being referred to as the Conduct Requirements – Mortgage Arrears (“CRMA”). The Guidance replaces all previous guidance issued by the Central Bank regarding appropriate and sustainable ARAs.

The CMRA sets out the Mortgage Arrears Resolution Process (“MARP”) that regulated entities are obliged to follow when dealing with certain cases.

Emphasising that ARAs have been, and continue to be, an essential tool when it comes to the resolution of mortgage arrears cases, the Guidance details the applicable criteria, which the Central Bank consider necessary, in order for an ARA to be seen as appropriate and sustainable for a borrower’s individual circumstances, in line with the mortgage arrears provisions of the CPC 2025.

Key Priority

The Guidance highlights the Central Bank’s position that the protection of mortgage loan borrowers is one of its key priorities. It is emphasised that all cases, where borrowers are in or facing mortgage arrears on a primary residence, must be handled sympathetically and positively by regulated entities.

Scope

The criteria set out in the Guidance apply to all regulated entities and activities in scope of the CPC 2025, including:

• assessments undertaken when an existing ARA is being reviewed or expires; and
• all ARAs offered to or put in place for borrowers who are in scope of the CRMA, except for temporary ARAs that are offered to, or put in place for, borrowers for a limited period of time, prior to completing the full assessment of the borrower’s standard financial statement, in accordance with regulation 254(4) and (5) of the CPC 2025.

Criteria

The Guidance sets out the overarching criteria that an ARA must fulfil such that it may be considered to be appropriate and sustainable for a borrower’s individual circumstances, highlighting that all of the following should apply:

• the ARA must provide for affordable repayments, taking account of the borrower’s reasonable expenses. Any repayments due under an ARA must not represent a disproportionately high proportion of the borrower’s net disposable income;
• full repayment of the outstanding principal sum or an agreed revised principal sum must be provided for;
• the ARA must take account of the borrower’s individual circumstances;
• the ARA must be based on realistic assumptions regarding the borrower’s future ability to pay;
• the ARA must be clear and unambiguous concerning its full implications for the borrower over the life of the mortgage; and
• the ARA must be agreed to by both the individual and the regulated entity before it can be put in place.

Additional considerations

The Guidance details additional considerations and expectations that regulated entities should take into account in their implementation of the overarching criteria, referred to above, for an ARA to be considered appropriate and sustainable. These considerations fall to be considered under the following areas:

• servicing capacity;
• full repayment;
• short-term ARAs – the Guidance highlights its previously expressed concerns / expectations around the excessive use of short-term ARAs, stating that they should only be used where it is in a borrower’s longer term interest and also where the ARA fulfils the criteria in the Guidance as to appropriateness and sustainability;
• existing ARAs – the Guidance references regulation 257 of the CPC 2025 whereby a regulated entity is required to review an ARA at intervals that are appropriate to the type and duration of the arrangement. Actions applicable where a standard financial statement has been last received either before or after 12 months have elapsed are set out. The Guidance also emphasises that all ARAs that will have an outstanding balance owing on expiry should include communications and engagement regarding the plan for repayment of that balance – all reviews of such ARAs should also include verbal contact attempts with borrowers to support effective engagement;
• engagement – regulation 231(1) of the CPC 2025 is referred to where a regulated entity must proactively encourage borrowers to engage with it about financial difficulties which may prevent the borrower from meeting mortgage repayments; and
• no appropriate and sustainable ARA option – highlighting that the Central Bank expects that regulated entities challenge their traditional solutions for resolving mortgage arrears and consider innovative long-term ARA options that are appropriate and sustainable, the Guidance, nonetheless, recognises that there may be cases where an appropriate and sustainable ARA cannot be identified. In such cases, the Guidance states that the regulated entity should support the borrower as regards other option that will allow the borrower to stay in their home, such as:

• • personal insolvency arrangements; and
  • the mortgage-to-rent scheme.

The Guidance recognises that sometimes, legal proceedings are the only realistic resolution option, pointing to regulation 261 of the CPC 2025, which sets out the conditions under which a regulated entity may commence legal proceedings for repossession of a borrower’s primary residence where the borrower is in mortgage arrears.

Next Steps

The Central Bank expects all regulated entities to incorporate the Guidance into their policies, processes and procedures as regards compliance with the CMRA, ensuring that:

• where relevant, clear reference is made to the Guidance and its criteria for an ARA to be considered appropriate and sustainable; and
• throughout the credit assessment process, particularly as regards regulation 253 of the CPC 2025, there is full alignment in use and meaning of the term “appropriate and sustainable” with the CMRA and the Guidance.

On 20 August 2025, the Central Bank of Ireland (“Central Bank”) published its Funding Strategy and Guide to the 2026 Industry Funding Regulations (“Guide”).

The Guide deals with the Central Bank Act 1942 (Section 32D) Regulations 2025 (“Regulations”), which are directed at recovering the industry share of the costs of financial regulation. The Regulations apply to all entities / persons that are regulated by the Central Bank.

The Regulations were signed into law by the Deputy Governor, Financial Regulation, on 20 July 2026 and came into operation on that day – for more information, see FIG Top 5 at 5 dated 30 July 2026.

The Guide is comprised of six sections as follows:

• Funding strategy, which aims to:

• • increase the proportion of costs paid by industry and reduce the burden on the taxpayer, while avoiding excessive movements in levy rates at a sectoral level from one year to the next insofar as is possible; and
  • reduce complexity and risk in the areas of funding policy and execution.

The Guide highlights that the 2026 invoices are based on the Central Bank’s actual costs of financial regulation in 2025.

• Background to the 2026 Industry Funding Regulations – some of the matters addressed are as follows:
• • the applicability of the Regulations;
  • collection of the levy, noting that the Central Bank sends a levy invoice to almost all regulated entities after the Regulations are published. However, even if a regulated entity does not receive a levy invoice, it is still legally obliged to pay the appropriate levy for its industry funding category in the Regulations;
  • arrangements for levy notices, including information as to use of the Central Bank portal;
  • supplementary levies as regards an additional levy in respect of the funding of a particular initiative or regulatory action; and
  • appeals and waivers.

• Recovery Rates, with the Guide highlighting that the Regulations reflect the recovery rates agreed with the Minister for Finance in 2019 – 100% now applies to all industry categories, except for credit unions where a recovery rate of 50% applies.

The Guide also points out that an industry funding levy has been applied to crypto-asset service providers (“CASPs”) for the first time. Virtual asset service providers (“VASPs”) are not included in the 2025 levy process due to the fact that all entities registered under the VASP regime prior to 30 December 2024 have already been subject to a pro-rata revocation levy during 2025 in line with the end of the transitional period permitted under the markets in crypto assets regulation (“MiCA”).

• Calculation of the Industry Funding Levy for each industry category:

• • credit Institutions / intermediaries and debt management firms / credit unions / high-cost credit providers / approved professional bodies / bureaux de change / retail credit firms and credit servicing firms / payment institutions and e-money institutions / CASPs / crowdfunding service providers are required to pay an industry funding levy as set out in the various corresponding tables in the Guide;
  • insurance undertakings, investment firms and category E2 alternative investment fund managers are required to pay the levy contribution corresponding to their impact category as determined in accordance with the Central Bank’s probability risk and impact system (“PRISM”) framework; and
  • a credit union is liable to pay a levy of 0.0304% of total assets as reported in its quarterly prudential return setting out its balance sheet as at 31 December 2025.

• Financial Information for Industry Sectors – some of the matters highlighted under this heading include:

• • the adjusted costs of financial regulation in 2025 were €273.3 million, an increase of €11.4 million compared to 2024; and

• • details as to subvention, with the Guide highlighting that subvention is only applied in certain circumstances where the Central Bank is of the opinion that relief is warranted – details of subvention amounts are set out in section 5.5.

• Appendices, which consist of:

• • a table showing a comparison of the 2024 and 2025 net annual funding requirement; and

• • the population of each industry sector.

1. Commission seeks advice from EIOPA and ESMA on RIS level 2 measures

 

On 24 August 2026, the European Commission (“Commission”) published a call for advice to the European Insurance and Occupational Pensions Authority (“EIOPA”) and a call for advice to the European Securities and Markets Authority (“ESMA”) for technical advice on level 2 measures under the proposed directive on retail investment protection (“Omnibus Directive”), in the context of the retail investment strategy (“RIS”).

The RIS was adopted by the Commission is May 2023, with the European Parliament (“Parliament”) and the European Council (“Council”) reaching provisional agreement on the RIS in December 2025 – – for more information, see FIG Top 5 at 5 dated 15 January 2026. This provisional agreement was approved by the Council on 5 June 2026 and by the Parliament on 23 June 2026. The adopted text is subject to legal-linguistic review, but the Commission does not expect any substantive changes.

The Omnibus Directive amends MiFID II / the insurance distribution directive (“IDD”) / the undertaking for collective investment in transferable securities directive (“UCITS”) / the alternative investment fund managers directive (“AIFMD”) / Solvency II / the PRIIPs Regulation. A number of provisions laid down in the Omnibus Directive need to be further specified in level 2 measures. Some of those L2 measures will be implemented through delegated regulations to be adopted by the Commission

Call for advice to EIOPA

In the call for advice the Commission is seeking EIOPA’s advice on the possible content of delegated acts under the IDD in the context of the RIS.

Call for advice to ESMA

With the call for advice, the Commission is seeking ESMA’s technical advice on certain delegated acts to supplement or specify specific provisions of MiFID II, UCITS and AIFMD. In the interests of simplifying the adoption of the proposed L2 measures, ESMA is requested to group the mandates into one delegated regulation and one delegated directive for each of the sectoral legislative frameworks.

Areas to be covered

Both EIOPA and ESMA have been asked to provide advice that covers the following matters:

• product oversight and governance;
• value for money;
• inducements;
• simplification and burden reduction in the retail investor journey;
• suitability and appropriateness assessment, simple advice; and
• marketing communication.

Coordination

Where appropriate, ESMA and EIOPA have been asked co-ordinate to ensure there is consistency across the different legal frameworks.

Next Steps

In view of the fact that the Omnibus Directive is expected to be published at the beginning of 2027, at the latest and should be applicable 30 months later, EIOPA and ESMA are invited to submit their technical advice by 1 October 2027.

 

2. EBA launches consultation on revised RTS for reclassification of investment firms as credit institutions

 

On 25 August 2026, the European Banking Authority (“EBA”) launched a consultation (“Consultation”) on draft regulatory technical standards (“RTS”) specifying:

• the methodology for calculating the thresholds referred to in article 8a(1) of Directive 2013/36/EU (“CRD”) – article 8a(6)(b) CRD;
• the information to be provided to competent authorities for monitoring the thresholds of article 8a(1) CRD – article 55(5) of Regulation (EU) 2019/2033 (“IFR”); and
• the elements to be taken in consideration by competent authorities when deciding on the waiver set out by article 8a(3a) CRD – article 8a(7) CRD.

Investment firms whose total assets exceed €30 billion are required to obtain credit institution authorisation under the CRD IV directive rather than operating under a MiFID investment firm licence.

Methodology RTS

The EBA had already consulted on the methodology for calculating the thresholds but the methodology needed to be reconsidered due to the changes introduced by article 8a CRD, which now limits the scope of the group test. In particular, the scope of entities to be considered for the calculation is now limited to those domiciled in the EU, rather than referring to all the entities in the group.

Provision of information RTS

The draft RTS on the provision of information for the effective monitoring of the thresholds specify what investment firms in scope should report. In line with article 55(5) of the IFR, undertakings would have to report only if their total assets are in excess of €5 billion. Investment firms would need to fill out two templates quarterly. Annex I to the consultation contains a reporting template, with instructions contained in Annex II.

Waiver RTS

To decide on a waiver request, competent authorities would be expected to:

• assess the group’s organisational structure, booking practices and allocation of assets;
• analyse the entity’s business model and the share of its deals on behalf of clients;
• draw on available regulatory instruments to measure its systemic risk; and
• analyse the size and complexity of its derivatives portfolio and footprint.

Next Steps

The Consultation is open for feedback until 25 November 2026. The EBA will hold a virtual public hearing on 30 September 2026. Interested parties may register here by 25 September 2026.