Welcome to the FIG Top 5 at 5

On 25 November 2025, the Central Bank of Ireland (“Central Bank”) published its updated Fitness and Probity Standards (“Standards”) and accompanying Guidance on the Standards of Fitness and Probity (“Guidance”).  The Standards and Guidance have been finalised following the completion of the  Central Bank’s consultation on revisions to its Fitness and Probity (“F&P”) Regime (“CP160”) launched in April 2025.  For more information on CP160, see FIG Top 5 at 5 dated 17 April 2025.

Standards

While the Standards have now been consolidated and now incorporate the provisions in respect of Credit Unions, which had previously been published in a separate document, the substance of the Standards themselves has not otherwise changed.

Guidance

The consolidation effected is in line with the recommendations included in the Enria Report, specifically, the Central Bank has now consolidated all guidance relating to the F&P Regime into a single document, as well as detailing cross references to other relevant guidance and guidelines which speak to the F&P Regime thereby providing assistance to firms in complying with their obligations.

Structure of the Guidance

The structure of the final Guidance is mostly unchanged from the draft Guidance published in April 2025.  The Guidance comprises five chapters covering:

• Legal Framework;
• Population of Controlled Functions (“CFs”) and Pre Approval Controlled Functions (“PCFs”);
• Fitness and Probity Standards;
• Key Considerations of F&P Assessment; and
• Ongoing Obligations to Comply: Certification.

Updates Introduced in the Guidance

The final Guidance contains a number of changes of note which were not incorporated in the original draft Guidance.  We summarise these below:

Theme : The designation of a company secretary as a CF-1

Update

The Guidance clarifies that the designation of a company secretary as a CF-1 should be determined on a case-by-case basis.
Where the functions carried out by the company secretary enable them to exercise a significant influence over the conduct of the affairs of the firm, they should be designated as a CF-1. Where the role carried out by the company secretary is purely administrative, such individuals need not be designated as a CF-1.

Theme : Individuals performing a PCF on a temporary basis (“Temporary Officers”)

Update

The Guidance provides significant detail in respect of the appointment of Temporary Officers. The key updates include:

• a Temporary Officer may only perform that role for a period of no more than 6 months;
• where a Temporary Officer is appointed to fill a role that has been permanently vacated, a firm must submit a PCF application in respect of the role to the Central Bank within 3 months from the date of the appointment;
• the requirements for a written notification to the Central Bank regarding the appointment of a Temporary Officer must include:
  (i) information on the circumstances which have given rise to the need for the Temporary Officer appointment;
  (ii) confirmation that the proposed Temporary Officer has agreed to comply with the F&P Standards; and
  (iii) for how long the appointment of the Temporary Officer is requested;
• a notification for the appointment of a Temporary Officer will not be accepted as part of a firm’s authorisation application to the Central Bank;
• where a person is accepted by the Central Bank as being suitable to fill the role on a temporary basis this does not imply they are fit and proper to perform the PCF role on a permanent basis; an
• consecutive or cumulative Temporary Officer appointments to a specific PCF role for a period of over 6 months will not be permitted, save for in exceptional circumstances.

Theme : PCF-52 Head of Anti-Money Laundering and Counter Terrorist Financing Compliance (“Head of AML and CTF”)

Update

An additional section has been added to the Guidance in respect of the PCF-52, Head of AML and CTF.

The Central Bank’s expectation is that where a firm is exposed to a significant degree of inherent money laundering or terrorist financing risk, the firm should consider if it is appropriate for the member of the firm’s senior management to be a member of the firm’s board of directors.

Where no such appointment is made by the firm, the firm should record in detail its rationale for such decision.

The Guidance reaffirms that pursuant to Section 54(8) of the Criminal Justice Act 2010, where the firm does not make such an appointment, that the Central Bank may direct the firm to do so.

Theme : Availability and accessibility of a PCF who is residing outside the State to the Central Bank

Update

The Guidance contains an additional section discussing the availability and accessibility of a PCF role holder to the Central Bank who is residing outside the State.

The Guidance states that where a firm requests that a person performing PCF roles resides outside of the State, that such requests will be assessed on a case-by-case basis and will take into account:

• the nature, scale and complexity of the firm and the PCF role;
• the ability of the role holder to carry out that role while residing outside of the State; and

the place residence of other PCF role holders.

Theme : Due Diligence

Update

The Guidance states that firms should, rather than must, maintain a record of the skills and competencies they expect the individual role holder to possess for that role.

Theme : Time Commitments

Update

The draft Guidance noted that the general expectation of the Central Bank was that executive PCF roles are carried out on a full time basis. However, this has now been removed.

Theme : Updates to the list of PCFs

Update

The final list of PCF’s at Appendix 2 of the Guidance has been updated to include:

1. PCF-56 Head of Safeguarding for Payment Institutions / Electronic Money Institutions / Account Information Service Providers / Small Electronic Money Institutions; and
2. an additional section for Crypto-Asset Service Providers which includes PCF-57 Head of Safeguarding.

Theme : Board skills assessment

Update

In relation to assessing the collective suitability of the Board, the Guidance has been updated to account for the requirement for some credit institutions and insurance undertakings to complete the board skills matrix under the applicable Central Bank Codes of Corporate Governance for Credit Institutions and Insurance Undertakings respectively.

The Guidance also states that all firms may consider using the board skills matrix as a matter of good practice to help assess the initial and ongoing suitability of the board and to identify any skills gaps at present or in the future.

Theme : Level of Knowledge and Experience

Update

The above clarify the Central Bank’s minimum expectations for certain roles, which include:

• the ‘level of experience’ requirement for executive directors , in addition to the knowledge and understanding requirements regarding the business and risks outlined in the draft Guidance, now requires the individual to have knowledge and understanding of the relevant financial services legislation;
• non-executive directors and independent non-executive directors may have specialist knowledge that complements the firm’s strategy instead of or in addition to knowledge and understanding of the business, risks and material activities;
• an additional table (Table 8) has been added to outline criteria for Sole Traders and Single Directors; and
• Table 9 (previously Table 8 in the Draft Guidance) outlines criteria for Heads of Control Functions, and now includes criteria for PCF-52 Head of Anti-Money Laundering and Counter Terrorist Financing Compliance.

Conclusion

The consolidated Guidance and Standards is a welcome development which will assist in-scope persons and firms to navigate their regulatory responsibilities.  They also integrate the approach to F&P with relevant aspects of other Central Bank guidance and guidelines, as well as general regulatory developments.

On 25 November 2025, the Governor of the Central Bank of Ireland (“Central Bank”), Gabriel Makhlouf, delivered a speech (“Speech”) at the Central Bank’s fourth Financial System Conference. The theme of the Speech centred around the continual evolution of financial regulation and supervision.

The Governor grounded his Speech in the current climate, stating that the work of central banks and regulators is more important than ever given the ever changing and fragmented world we find ourselves in, highlighting how vital it is that monetary and financial stability are maintained. Indeed, he expressed his belief that effective and efficient regulation and supervision are one of the most important contributors that can be made when it comes to financial stability and resilience.

Governor Makhlouf summarised the progress made by the Central Bank, in terms of its transformation, since he joined the Central Bank six years ago, noting that commitments in that regard, such as changing how the Central Bank thinks, engages and makes decisions, was captured in its 2021 Strategy.

The Governor reminded his audience that the 2021 Strategy was centred around being more future-focused, more open and engaged and transformational as regards the delivery of its key safeguarding functions. He further highlighted the goal of delivering better outcomes.

Noting that recent years have “tested every institution in Ireland, the EU and around the world”, Governor Makhlouf pointed to the fact that the Central Bank has continued to evolve, and in that regard, he proceeded to outline some of the ways in which the Central Bank will continue to evolve.

Simplification

The Governor addressed the topical issue of simplification, acknowleding that “the world of financial regulation has been buzzing with phrases such as deregulation, de-supervision, modernisation and simplification.”

He stated that regulating well is not about reducing standards but rather should be focused on making sure that what is done is carried out in a way that is clear, consistent, and coherent, so that rules are understood, applied predictably, and achieve their purpose without unnecessary burden or complexity.

New supervisory approach

Governor Makhlouf highlighted the Central Bank’s recent transformation of regulation and supervision, describing it as more effective and effective and also more integrated across all of the Central Bank’s safeguarding outcomes. For more information on the new supervisory approach, see FIG Top 5 at 5 dated 6 March 2025.

Further examples of the Central Bank’s evolution

The Director also cited the following examples as regards the Central Bank’s evolution as regards regulation and supervision:

• the improvement of its  external-facing processes including authorisations, making them more transparent, more consistent, and more predictable. In this regard, Governor Makhlouf stated that the Central Bank will continue to make authorisations more effective and efficient, including by further centralising gatekeeping functions;
• the outcomes achieved in the Central Bank’s fist sandbox programme, with the Governor stating that the results have shown the Central Bank that effective regulation requires open engagement with the innovation ecosystem; and
• the Governor also addressed the mortgage measures, first introduced in 2015, highlighting that changes were made in 2022 following their review, illustrating that the Central Bank evaluates and refines frameworks over time, drawing on data, to maintain resilience and access to sustainable lending.

Ongoing and upcoming work / initiatives

The Governor went on to discuss the work of the Central Bank that is ongoing, some of which are as follows:

• actively working with European colleagues on a wide-ranging agenda, taking into account that the majority of financial services policy, legislation and regulation comes from Europe;
• the Central Bank will continue to be an active participant in international standard setting across its entire mandate;
• in the context of the forthcoming reform of Solvency II, the Central Bank will conduct a compatibility review of more than 50 domestic instruments to identify overlap, underlap, and opportunities for consolidation;
• given that the establishment of the EU anti-money laundering authority and the AML Regulation will replace a significant amount of Ireland’s AML framework, the Central Bank will retire or revise domestic guidance, including the 2021 sectoral guidelines, once the AML Regulation enters into force;
• a review of the Senior Executive Accountability Regime will be carried out in 2027, as previously flagged;
• the publication of the finalised proposals making it simpler to appoint people to PCF roles on a temporary basis where needed and to consolidate the guidance to make it easier to follow. For more information, see the update ‘Central Bank publishes Fitness and Probity Standards and Guidance on the Standards of Fitness and Probity’, above; and
• a review of the corporate governance requirements in 2026 to remove duplication, improve alignment across sectors, and embed proportionality and clarity into governance design;
• an upcoming consultation on a new regulatory impact assessment framework next year with the aim of further embedding evidence-based policymaking into the Central Bank’s processes; and
• continued engagement with others on how to streamline the European rulebook in a way that strengthens the single market,

The Governor stated that the Central Bank will publish a list of its ongoing initiatives over the coming weeks including details as to how each initiative will make the domestic regulatory framework more straightforward.

Complexity and good policy making

Governor Makhlouf highlighted that a financial system as interconnected as Ireland’s cannot be “governed through one-page rules” and that the rules must be capable of managing that complexity effectively. In this regard, he stated that firms could help themselves and their customers if they were more straightforward in the design, delivery and explanation of their products.

The Governor emphasised that the efforts of the Central Bank to make better policy and improve its processes should not be taken as a weakening of its approach to regulation and supervision, stating that, “The standards we expect of regulated firms won’t be lowered. We will not dial back our supervision.  We will continue to take enforcement action where necessary.  And if changes to the risk landscape mean we have to introduce new rules or requirements, we will do so.

Conclusion

The Governor noted that the financial system will continue to evolve through AI, digitalisation and new forms of intermediation with a corresponding growth in the need for clear, trusted and agile regulation. He described the Central Bank’s role in this regard as one of anticipating these changes and responding to them in a way that ensures that “Ireland’s financial system remains resilient, and delivers in the best interest of our citizens and economy”.

On 20 November 2025, Gerry Cross, Director of Capital Markets and Funds at the Central Bank of Ireland (“Central Bank”) delivered a speech (“Speech”) at the Central Bank’s annual retail intermediaries roadshow.

The Director acknowledged the important role played by retail intermediaries, highlighting their position as key interfaces between consumers and financial products and services. He then went on to emphasise that a well functioning financial system is vital for citizens, businesses and the economy, noting also the Central Bank’s objective to deliver on its four safeguarding outcomes.

Director Cross pointed out that sometimes there can be a dichotomy between the objectives of regulators and those of industry and framed this in the context of the need for consumers to have good trust and confidence that the financial system will deliver for them.

The Director addressed a number of areas during his speech, a high-level overview of each follows.

Resilience plans

The Director pointed to the progress that has been made over recent years as regards financial resilience and the demonstrated ability of firms to weather shocks, such as Brexit and Covid 19. He went on to emphasise the importance of maintaining this resilience, particularly highlighting operational resilience as an increasingly challenging area, noting it as “a high probability and often high impact risk”. Accordingly, Director Cross stated that it is important that all intermediaries have plans in place to support their customers, and enable recovery from, operational disruption. Such plans are expected to be commensurate with the size, scale and complexity of a firm’s business.

Retail investor participation

Director Cross noted the low levels of direct retail participation in capital markets that exists in Ireland and in that regard also referred to the European Commission’s strategy regarding the savings and investment union and its aim to provide better opportunities for EU citizens to invest in capital markets.

The Director referred to experience from other jurisdictions where it has been shown that availability and choice of suitable products, providers and delivery channels together with access to advice and information, are factors that support consumers’  participation in capital markets. He highlighted that intermediaries are important in delivering both of these “enablers”. As for the Central Bank, the Director stated that its role is to ensure that consumers have confidence that their interests will be secured, with the Central Bank engaging with industry on this point.

On the topic of consumers, the Director noted the December 2024 OECD review of the Central Bank’s consumer protection supervisory functions, where the OECD found the Central Bank to be aligned with international principles – for more information, see FIG Top 5 at 5 dated 19 December 2024. However, Director Cross did point to the identified areas for improvement and stated that the proactive embedding of the consumer experience and consumer perspective into its approach will be a focus for the Central Bank in 2026.

The role of retail intermediaries 

Some of the matters highlighted by the Director under this heading include the following:

• the sector has both economic and social importance in its role as a key distributor for insurance, pensions, investments and mortgage products;
• intermediaries help to ensure that consumers throughout the State can access the financial products and services they need for their day-to-day lives;
• intermediaries facilitate consumers that prefer a face-to-face / personal service, to access financial services in that way, bringing a wider societal benefit;
• the provision of useful and suitable financial services and products to ordinary people, thereby ensuring the financial system is fulfilling one of its basic functions; and
• the Director highlighted the increasing amount of consolidation in the intermediaries sector, stating that the Central Bank will continue to monitor this area with a view to adapting its supervision and engagement with the sector in a meaningful way.

Important outcomes for the intermediaries sector

Director Cross highlighted the following as outcomes the the Central Bank views as important for the intermediaries sector:

• well run firms securing client interests at the core of their culture, demonstrating competence and professionalism and also using the appropriate level of expertise in securing such interests; and
• availability and choice for consumers, with good value offered – innovation and competition are highlighted as important in this regard.

Consumer Protection Code 

With so much emphasis on securing the interests of consumers, the Director took the opportunity to briefly discuss the recent revisions to the Central Bank’s Consumer Protection Code (“CPC”). In stating one of the CPC’s core objectives as being one of placing consumers at the heart of the culture of a firm, Director Cross pointed to the fact that this has been addressed via the new standard regarding securing customers’ interests. He noted the supporting guidance in this area, hoping that such guidance will “help firms to understand the things they need to consider, the actions they need to take, and the mindset they should have towards their customers” – for more information on the CPC and the related guidance, see FIG Top 5 at 5 dated 27 March 2025.  

Supervisory approach

Director Cross highlighted the supervisory priorities for the retail intermediaries sector, some of which are as follows:

• remuneration models – that they are operated in such a way so as to avoid undue conflicts of interest and deliver optimal results for customers, highlighting that commission payments must not interfere with the obligation to secure consumers’ best interests; and
• operational resilience – that intermediaries are operationally resilience, including against cyber risk.

Unregulated activities

Director Cross highlighted that unregulated activity is an area of focus for the Central Bank, referencing the dangers for consumers associated with the ‘halo effect’. In this regard, he reminded his audience that the revised CPC requires regulated firms to ensure that their customers or potential customers do not understand an activity to be, or to carry the protections of, a regulated activity where this is not the case. He pointed to the CPC guidance on the use of branding and other marketing tools.

The Director stated that the Central Bank will be engaging further with the intermediaries sector, as regards unregulated activity, in 2026.

Simplification and proportionality

The Director highlighted that this is an agenda that the Central Bank welcomes and is “actively considering”.

He described simplification as including “making sure regulation is outcomes focused and workable”, requiring stakeholder engagement – citing the revisions to the CPC as an example of such engagement.

As regards proportionality, the Director referenced regulatory compliance costs, stating that the rules should seek to achieve their objectives in a cost effective and proportionate way. He emphasised that “proportionality has been and continues to be at the heart of our approach to high quality regulation”. The Director then went on to give some examples of the way the Central Bank is enhancing its proportionate supervisory approach for intermediaries, such as:

• the Central Bank is currently working on a new streamlined authorisation process for sole traders who propose to become single director companies;
• the expected amendments to the fitness and probity regime on foot of the Central Bank’s recent consultation in that area – for more information, see FIG Top 5 at 5 dated 17 April 2025. Such amendments will be aimed at taking account of the nature and scale of retail intermediary firms; and
• as regards industry communications, the Director referenced the Central Bank’s recent report setting out the findings of retail intermediaries’ fair versus limited analysis of the market – for more information, see FIG Top 5 at 5 dated 20 November 2025. He stated that such communications are intended to support firms by clarifying the Central Bank’s expectations rather than creating additional burdens or requirements.

Director Cross also cited the forgoing list as examples of smart regulation, describing smart regulation as “regulation that it proportionate, targeted on outcomes, and adaptive to changing circumstances”.

1. Access to Cash legislation to come into effect on 28 November 2025

On 24 November 2025, the Department of Finance (“Department”) announced that the new Access to Cash legislation will come into effect on 28 November 2025.

The Department have stated that Tánaiste and Minister for Finance, Simon Harris, TD (“Tánaiste”), will sign two orders, as follows:

• the Finance (Provision of Access to Cash Infrastructure) Act 2025 (Section 5)  Order 2025; and
• the Finance (Provision of Access to Cash Infrastructure) Act 2025 (Section 10) Order 2025.

This latest development follows on from the publication of SI No. 248/2025 – Finance (Provision of Access to Cash Infrastructure) Act 2025 (Commencement) Order 2025 in Iris Oifigiúil on 13 June 2025, with the Finance (Provision of Access to Cash Infrastructure) Act 2025 in operation since 30 June 2025 – for more information, see FIG Top 5 at 5 dated 19 June 2025.

The Tánaiste stated:

“In recent years, the Irish payments system has become increasingly digitalised, yet cash remains an important means of payment for many people in society, such as the older generation or those who are digitally excluded. The Orders will ensure that cash is accessible in communities right across the country.”

Next Steps

The Central Bank of Ireland (“Central Bank”) will be responsible for the monitoring and enforcement of this legislation. Monitoring will be carried out on a quarterly basis. The Central Bank will have the necessary powers to direct designated entities to implement measures to comply with access to cash criteria and address local deficiencies.

2. Commission adopts delegated regulation on equity transparency under MiFIR

On 24 November 2025, the European Commission (“Commission”) adopted a delegated regulation (“Regulation”) amending delegated regulation (EU) 2017/567 as regards equity transparency under the regulation on markets in financial instruments (“MiFIR”).

The  European Securities and Markets Authority (“ESMA”) published a final report on equity transparency measures under MiFIR II and MiFID III in December 2024 – for more information, see FIG Top 5 at 5 dated 19 December 2024.

The Regulation reflects and implements the amendments to MiFIR and MiFID II made by Regulation (EU) 2024/791 (“MiFIR II”) and Directive (EU) 2024/790 (“MiFID III”) following a review. Accordingly, the Regulation addresses the following:

• amends the provisions relating to the determination of what constitutes a ‘liquid market’ for the purposes of Articles 4, 5 and 14 of MiFIR by replacing the ‘free float’ criterion with the ‘market capitalisation’ criterion, in line with the amendments to the definition of ‘liquid market’ laid down in MiFIR, and clarifies certain other issues around the liquidity assessment for equity instruments;
• deletes provisions that clarify what constitutes a ‘reasonable commercial basis’ for trading venues and systematic internalisers. This stems from the changes introduced to article 13 of MiFIR and the introduction of a new empowerment for ESMA to develop draft regulatory technical standards to specify the concept of ‘reasonable commercial basis’;
• deletes the provision specifying the size specific to the financial instrument for the purposes of the requirements applicable to systematic internalisers in respect of non-equity instruments. This stems from the deletion of pre-trade transparency requirements for systematic internalisers in respect of non-equity instruments;
• specifies what constitutes post-trade risk reduction services for the purposes of the exemption laid down in Article 31(1) of MiFIR; and
• deletes publication requirements for portfolio compression services. This stems from the deletion of the obligation for investment firms and market operators, who provide portfolio compression services, to make public, through an approved publication arrangement, the volumes of transactions subject to portfolio compressions and the time they were concluded.

Next Steps

The Regulation will enter into force on the third day following its publication in the official journal of the European Union.

Article 1, point (4) of the Regulation shall apply from 23 August 2026.

1. Implementing regulation amending ITS on process for internal models authorisation under CRR published on OJEU

On 21 November 2025, Commission implementing regulation (EU) 2025/2338 (“Amending Regulation”) was published in the official journal of the European Union (“OJEU”).

In March 2025, the European Banking Authority (“EBA”) published a final report containing draft implementing technical standards (“ITS”) that amend the existing implementing regulation on the joint decision process for internal model authorisation under the Capital Requirements Regulation (“CRR”) – for more information, see FIG Top 5 at 5 dated 20 March 2025.

The Amending Regulation amends Commission implementing regulation (EU) 2016/100, with the amendments relating to:

• the removal of the advanced measurement approach for operational risk, reflecting amendments to the CRR made by the CRR III Regulation;
• the new regulatory technical standards (“RTS”) and ITS on the functioning of supervisory colleges that were published in the OJEU in August 2025 as Commission delegated regulation (EU) 2025/791 and Commission implementing regulation (EU) 2025/790 respectively; and
• Commission delegated regulation (EU) 2025/1496 which sets out the current requirements as the calculation of own funds requirements for market risk will apply until 1 January 2027 – for more information, see FIG Top 5 at 5 dated 25 September 2025.

Next Steps

The Amending Regulation will enter into force on 11 December 2025, being 20 days following its publication in the OJEU.

1. Parliament adopts resolution on use of AI in the financial sector

On 25 November 2025, the European Parliament (“Parliament”) adopted a resolution (“Resolution”) on the impact of artificial intelligence (“AI”) on the financial sector.

Background

On 11 November 2025, the Parliament’s committee on economic and monetary affairs (“ECON”) published a report (“Report”) on the impact of AI on the financial sector – for more information, see FIG Top 5 at 5 dated 13 November 2025.

Resolution

In a related press release, it is stated that the Resolution calls on the European Commission and supervisors  to issue clearer, proportionate guidance rather than producing new rules. Further, the Resolution calls for supervisory authorities to cooperate more effectively through consistent interpretations, information sharing and cross-border cooperation.

The Resolution considers the rapidly growing use of AI by the financial sector and does recognise the potential for increased efficiency, innovation, improvements to consumer services. However, Parliament raised concerns about significant risks, such as:

• data-bias;
• model opacity;
• over-reliance on a few technology providers;
• cyber-security threats; and
• governance challenges.

To counteract such risks, the Parliament highlighted the need for human oversight, robust data governance and a regulatory framework that encourages innovation but does not compromise consumer protection and financial stability.

The author of the original Report, Arba Kokalari, stated:

“With this report, we send a clear message that no new legislation is needed for the use of AI in the financial sector. Instead, existing rules must be clarified, made less bureaucratic, and enable investments. This signals a significant policy shift toward the market from the European Parliament, which has previously been considerably more sceptical of AI…

There is significant potential in the responsible use of AI in the financial sector, which can deliver safer and more efficient products for consumers. Policymakers must now ensure the right conditions for AI deployment, without adding administrative burdens”.

2. EBA publishes factsheet on implications of AI Act for EU banking and payments sector

On 21 November 2025, the European Banking Authority (“EBA”) published a factsheet (“Factsheet”) addressing the implications of the AI Act for the European banking and payments sectors.

Under the AI Act, the use of AI systems to evaluate the creditworthiness or to establish the credit score of natural persons is classified as high-risk and in that regard, the AI Act introduces additional safeguards.

EBA AI Act mapping exercise

In 2025, the EBA mapped the requirements of the AI Act regarding high-risk AI systems, focusing on the use of AI for creditworthiness and credit scoring, against the sectoral requirements included in the acts in the EBA’s scope, as follows:

• Capital Requirements Directive;
• Capital Requirements Regulation;
• DORA;
• Consumer Credit Directive;
• Mortgage Credit Directive; and
• Payment Services Directive.

The mapping exercise was aimed at assessing and promoting a common understanding as to the potential regulatory and supervisory implications of the AI Act for the European banking and payments sectors.

Key findings

Some of the key findings, on foot of the mapping exercise, are as follows:

• no significant contradictions have been found between the AI Act and EU banking and payment legislation;
• the AI Act is complementary to the European banking and payment sectoral legislation, which, it is noted, already provides a comprehensive framework to manage risks. It is pointed out that there may be some work to be done by banks and other financial institutions to effectively integrate the two frameworks; and
• the co-existence of multiple authorities supervising the compliance of financial entities highlights the importance of supervisory cooperation to ensure effective implementation of the AI Act.

The Factsheet sets out that the EBA does not see an immediate need for new guidelines or to review existing guidelines.

Next Steps

The Factsheet states that, over 2026 and 2027, the EBA will engage in specific activities in order to support the implementation of the AI Act in the banking and payments sectors, as follows:

• the promotion of a common supervisory approach, and supervisory cooperation, between relevant national competent authorities; and
• the EBA will provide input to the AI Office as deemed appropriate and will take part in discussions of the AI Board subgroup on financial services.