Welcome to the FIG Top 5 at 5

1. Ireland for Finance 2025 Action Plan is published

On 29 July 2025, the Department of Finance (“Department”) published its Ireland for Finance 2025 Action Plan (“Action Plan”).

The Action Plan sets out priority measures and initiatives that stakeholders have committed to delivering over the course of this year, under the five themes of the strategy which include: sustainable finance; fintech and digital finance; diversity and talent; regionalisation and promotion; and operating environment.

Key Areas of Focus for 2025

• Mobilise significant financial resources to combat the climate crisis and unlock capital for the green transition;
• Foster Ireland’s reputation as a global fintech leader and leverage strengths in financial services and technology;
• Respond to emerging training needs in areas like data, AI, and sustainable finance, while strengthening and diversifying the talent pipeline;
• Deepen the talent pool, increase available opportunities, and promote Ireland as an attractive operating location for international financial services;
• Ensure Ireland remains an appealing and secure location for international financial services firms, characterised by consistent policymaking, robust regulation, and strong governance.
•  innovation through hubs and funding;

Another key focus for the Department in 2025 is the development of the new international financial services strategy. The Programme for Government includes a commitment to continue to implement the Strategy and develop a new strategy for the period 2026 – 2030, seeking to further build on the success of the sector. This work will take place over the remainder of this year for intended launch in early 2026.  Until then, the current iteration of the Strategy will remain in force.  For more information on the Strategy, see FIG Top 5 at 5 dated 24 July 2025.

2. Ireland for Finance 2024 Progress Report is published

On 29 July 2025, the Department of Finance (“Department”) published its 2024 Ireland for Finance Progress Report (“Report”).

The Report provides an update on the 13 action measures that were due for reporting last year under the Ireland for Finance Strategy . Most are marked as complete, a while a few are ongoing or delayed. The actions are focused on the five core themes of the strategy; fintech, sustainable finance, diversity and talent, regionalisation and promotion and operating environment.

Notable Achievements

Some notable achievements in the 2024 Report include:

• promoting Ireland as a hub for sustainable finance through the International Sustainable Finance Centre of Excellence;
• fostering fintech innovation and international expansion via Enterprise Ireland and IDA Ireland; a new Client Transformation Division created by IDA Ireland, which will act as a centre of excellence to drive a transformation agenda with client companies;
• the Central Bank’s first innovation Sandbox Programme opened for applications in 2024, a key milestone;
• promotion and participation in national events by enterprise agencies and other stakeholders, including Nordic Fintech week, Nigeria Fintech week and Singapore Fintech Festival; and
• Enterprise Ireland approved 90 grants aimed at helping client companies acquire essential skills and training.

On 22 July 2025, S.I. No. 310 of 2025 – European Union (Information Accompanying Transfers of Funds) Regulations 2025 (“Regulations”) was published.

The Regulations are primarily designed to supplement the EU’s revised Wire Transfer Regulation (Regulation (EU) 2023/1113) by making the Central Bank of Ireland (“Central Bank”) the competent authority for ensuring compliance with that law. In addition, in an easily overlooked provision at the end: Regulation 15, the Regulations introduce substantive amendments to the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (“2010 Act”).

Throughout 2024, there was much industry anticipation around two key issues:

• when and how the 2010 Act would be updated to reflect the EU’s new crypto-assets framework; and
• when the Virtual Asset Service Provider (“VASP”) regime would finally sunset in favour of authorisation under MiCAR (Regulation (EU) 2023/1114).

Regulation 15 brings clarity to these issues, through the following:

• it deletes now outdated definitions of “virtual asset” and “virtual asset service provider”;
• introduces MiCAR-aligned definitions of “crypto-asset” and “crypto-asset service provider (CASP)”;
• brings CASPs within the scope of AML obligations as “financial institutions”:
• formally repeals Chapter 9A of the Act (which governed VASP registration).

Those VASPs registered with the Central Bank before 30 December 2024 may continue to operate under the 2010 Act only until the earlier of:

1. a MiCAR authorisation decision is granted (Article 63); or
2.  30 December 2025.

Thereafter, the current VASP framework in Irish law will cease to have effect. This is a critical milestone for firms preparing to transition into full compliance under MiCAR or else cease business in Ireland. There certainly appears to be no chance of any further extension of the MiCAR transition period in Irish law following this development.

Separately, Regulation 15 also inserts a new provision—Section 109F—allowing the Central Bank to require the appointment of a central AML contact point. However, this obligation is limited to:

• E-money issuers (as defined under Directive 2009/110/EC), and
• Payment service providers (under PSD2)

Following a much anticipated judgment handed down by the Supreme Court of England and Wales on Friday, 1 August 2025, motor car finance lenders in the UK market likely breathed a sigh of relief.

The English Supreme Court found that

1. discretionary commissions paid by lenders to car dealers did not constitute bribes; and
2. the car dealers did not to owe fiduciary duties to their customers and, as such, the lenders could not be liable, as accessories, for breach of fiduciary duties.

The English Supreme Court decision has now restored the more orthodox judicial approach to common law bribery and fiduciary duties. This has been welcomed by legal commentators in the UK, but may be seen as a blow for consumer rights groups.

On the specific facts of one case, however, the English Supreme Court identified the existence of “an unfair relationship”, within the meaning of the provisions of section 140A of the (English) Consumer Credit Act 1974, between one lender and its customer. That customer was entitled to succeed in his appeal. The court recognised that a broad range of factors are normally relevant to any assessment of the test for unfairness, including: the size of the commission relevant to the charge for credit; the nature of the commission (because, for example, a discretionary commission may create incentives to charge a higher interest rate); the characteristics of the consumer; the extent and manner of the disclosure […]; and compliance with the regulatory rules.

UK commentators are reporting that the English Supreme Court decision means that motor finance consumers in the UK, who believe they should not have paid as much or any commission, will be confined to statutory claims and / or any redress scheme which may ultimately be put in place by the Financial Conduct Authority (“FCA”).  The FCA confirmed on 3 August 2025 that it will consult on an industry-wide scheme to compensate motor finance customers who were treated unfairly. It intends to publish the consultation by early October 2025 and to finalise any scheme in time for consumers to start receiving compensation in 2026. The FCA estimates the cost of any scheme (including administrative costs) would not be materially lower than £9 billion – and it could be materially higher, with estimates of a total cost as high as £18 billion.

While the decision relates to the laws and regulatory regime applicable in the UK, the litigation has attracted substantial attention in this jurisdiction also. It is relevant from an Irish law perspective, given the commonality of jurisprudence in relation to fiduciary duties and common law bribery, and the persuasive authority of English law judgments in some areas of Irish law. The return to a traditional approach to common law bribery and fiduciary duties will likely be welcomed here also.

From a financial services regulatory perspective, however, Irish law differs from the applicable regime in the UK in a number of key respects. For this reason, the FCA consultation and any redress scheme may not be of direct relevance to regulated firms and / consumers in the Irish market, but will still be of interest from the broader perspective of consumer protection.  Firms will be aware that on 12 June 2024, the Central Bank issued a Dear CEO letter setting out its expectations in relation to discretionary commission arrangements and that the revised Consumer Protection Code (due to take effect in March 2026), makes specific provisions for those types of arrangements. Regulated firms will of course be paying careful attention to these requirements.

Matheson will continue to analyse the impact of this decision for our financial services clients and will provide a further update in the coming weeks.

On 1 August 2025, the European Banking Authority (“EBA”) published the results of its 2025 EU-wide stress test involving 64 banks from 17 EU and EEA countries and covering 75% of EU banking sector assets. The results show that the euro banking system is resilient against a severe economic downturn scenario.

Key Findings

• The capital depletion under the adverse stress test scenario amounts to 370 bps, resulting in a CET1 ratio at the end of the scenario of 12%. The strong income generation during the exercise helps banks to partly offset their losses and results in a lower depletion compared to the 2023 exercise;
• Banks start the exercise with higher profitability and capital than in recent years. While banks are more risk-sensitive, showing higher nominal losses, they have better absorption capacity through income generation. Banks show more vulnerabilities in credit and market risk, which are the main contributors to the stress test losses;
• Specific adverse scenarios affect economic sectors differently. Banks have improved their ability to differentiate the impact of adverse scenarios across sectors, but there is still a need to further improve their modelling efforts; and
• Strong performance of the EU banks in the 2025 EU-wide stress test is reassuring, nonetheless, maintaining adequate capital remains essential to ensure the safety of the EU banking system.

AIB Group plc, Bank of Ireland Group plc, Barclays Bank Ireland PLC, Citibank Holdings Ireland Limited plc and Bank of America Europe Designated Activity Company were subject to the EBA EU-wide stress test exercise.  The results for the Irish banks are available here.

Next Steps

The findings of the stress test will inform the 2025 Supervisory Review and Evaluation Process for banks, which is conducted by Joint Supervisory Teams made up of staff at the European Central Bank and the Central Bank of Ireland.

On 31 July 2025, the European Banking Authority (“EBA”) launched a public consultation on its draft Implementing Technical Standards (“ITS”) for the supervisory reporting of third-country branches under the Capital Requirements Directive (“CRD”).

The EBA explains that the draft ITS aim at harmonising reporting formats and definitions but also at enhancing supervisory oversight of third-country branches. By introducing structured data collection –  covering both the third-country branches and their head undertakings – the ITS support the effective supervision of third-country branches by addressing previous inconsistencies in national approaches and enabling a standardised reporting of their activities across the Union.

The EBA further explains that the new templates that form part of the ITS should provide a clear picture of the financial soundness, risk exposures, and intra-group dependencies of third-country branches, thereby supporting more effective and consistent supervision across the EU. Importantly, the ITS incorporate a proportionate approach through a “core + supplement” model, ensuring that reporting obligations are tailored to the systemic relevance of each third-country branch. This ensures that supervisory scrutiny is risk-sensitive while maintaining a level playing field.

Next Steps

The Consultation is open to comment until 31 October 2025. A public hearing on the draft ITS will take place on 5 September from 10:00 to 12:00.

Following the consultation, the EBA will finalise the draft ITS and submit them to the European Commission by January 10, 2026. The first reference date for the application of these ITS is anticipated to December 2026, so as to grant Competent Authorities and third-country branches to have an implementation period of approximately one year.