Welcome to the FIG Top 5 at 5

1. Deputy Governor Kincaid of the Central Bank delivers speech to DPER Management Conference on strategy, workforce and AI

 

On 10 September 2026, Deputy Governor of Consumer and Investor Protection at the Central Bank of Ireland (“Central Bank”), Colm Kincaid, delivered a speech (“Speech”) entitled “Tending the Public Garden – Accountable for today, Stewarding for tomorrow” to the Department of Public Expenditure, NDP Delivery and Reform (“DPER“) Management Conference, in which he addressed the future of public sector workplaces, including digitalisation, demographics, lifelong learning, artificial intelligence and hybrid working.

The Deputy Governor framed his remarks around the need for public institutions to be accountable for “delivering today” while being custodians of  future capabilities for tomorrow.

Although addressed to a public-service management audience, the Speech addresses themes around institutional management, strategic prioritisation and accountability.

Strategy versus strategic plans

Deputy Governor Kincaid distinguished between a strategy, which he described as something that defines outcomes and makes choices about where an organisation directs its attention and capability, and a strategic plan, which he characterised as an implementation roadmap setting out actions, owners, milestones, budgets and timelines.

He referenced the Central Bank’s own strategy and reminded his audience of its four connected themes of being future focussed, being open and engaged, transforming how the Central Bank works, and safeguarding the system and the public interest.

Forward-looking risk factors

The Deputy Governor identified a number of forces informing the Central Bank’s scenario planning beyond 2027, including rapid technological change, geopolitical tensions, global financial interconnectedness, sophisticated financial crime, the increased economic impact of climate and environmental risks, and pressure on trust in public institutions – as described in the update below on the Central Bank’s new strategy survey.

Digitalisation

Deputy Governor Kincaid described digitalisation as a behavioural shift affecting the public’s expectations of service. He stated that digital services should be designed around the person being served, rather than the institution providing the service, with success  “tested by whether people reach the right outcome, not merely by whether the system completes a transaction at a technical level.” In particular, he highlighted that where algorithms are used to allocate, prioritise or communicate, firms and institutions need to be able to explain results, detect unequal effects and provide meaningful human recourse.

Diversity and inclusion

Deputy Governor Kincaid rejected the suggestion that diversity and inclusion should move down the agenda, stating that the ability to invite different perspectives and avoid groupthink is increasingly important to the quality of institutional decision-making. He noted that the Central Bank published its first gender pay gap analysis in 2018, ahead of statutory reporting requirements, and continues to publish annually, describing “transparency as a starting point for accountability, not a declaration of success.”

Lifelong learning and artificial intelligence

When it comes to AI, the Deputy Governor noted that institutions will need people who can build AI tools, people who can navigate them, and leaders who can operate at the intersection of both to enhance productivity responsibly, while preserving “core human capabilities of context, empathy, judgement, that AI can support but should not own.” He sounded a note of  caution as regards adoption of AI, highlighting that adopting AI too slowly risks a loss of relevance and the emergence of ungoverned shadow use, while adopting it too quickly, and without control, risks eroding public trust.

Conclusion

In conclusion, the Deputy Governor set out a number of themes, that he envisages will inform the Central Bank’s strategy beyond 2027, as follows:

• clarity of durable public purpose amid changing priorities;
• translating that purpose into real strategic choices;
• cultivating capabilities ahead of crises;
• diverse and inclusive workplaces supporting longer, less linear careers; and
• demonstrating the competence, honesty, transparency and reliability through which public trust is earned.

 

2. Central Bank publishes survey on its new strategy 2028 – 2032

 

On 3 September 2026, the Central Bank of Ireland (“Central Bank”) published a survey (“Survey”) on its new strategy for 2028 – 2032.

This new strategy, which the Central Bank is currently developing, will replace the current strategy which runs until the end of 2027.

The Central Bank highlighted the progress made as a result of the current strategy, such as:

• ensuring faster and safer payments for consumers;
• strengthening consumer protections with the updated Consumer Protection Code;
• establishing a dedicated team to address climate risks;
• programmes aimed at testing innovative financial services; and
• enhancing policy and supervisory frameworks.

Medium term

The Central Bank cites new technologies, climate risks and evolving banking practices as factors to be taken into account in terms of its strategic priorities for the medium term, ensuring that it can continue to maintain financial stability, protect consumers and support the Irish economy.

The new strategy will be approved by the Central Bank’s Commission in May 2027 and presented to the Minister for Finance in September 2027.

Survey

The Survey is open for feedback until 16 October 2026. The Central Bank welcomes views from everyone, from those who use financial services, work in the industry, run a business or have an interest in how Ireland’s financial system operates to community groups.

On 16 September 2026, President of the European Commission (“Commission“), Ursula von der Leyen, delivered her sixth State of the Union address (“Address”) to the European Parliament, setting out the Commission’s priorities for the year ahead, including for financial services, together with a number of other initiatives such as competitiveness, energy, critical raw materials, artificial intelligence, and climate resilience.

For the purposes of this note we are focusing on those aspects of the address that are likely to impact the financial services sector.

Economic backdrop

President von der Leyen opened her Address by describing the EU as simultaneously the strongest, and the most precarious, it has ever been, noting that while unemployment is close to a record low, rising energy and borrowing costs are placing pressure on households and businesses, and that clear budgetary choices will be needed to safeguard fiscal sustainability while protecting investment.

She highlighted that the EU has a large internal market, a strong industrial and services base, a substantial pool of savings and one of the world’s leading currencies, but that capital, networks and purchasing power remain fragmented across the Union.

Referencing the Draghi and Letta reports, the President stated that the Commission’s plan is to build an economy in which innovation and energy move freely across borders, companies grow across the EU, and savings finance the Union’s future. She also confirmed that political agreement has been reached on the “One Europe, One Market” roadmap, emphasising that this overhaul of the single market must be completed by the end of 2027.

Savings and Investment Union

On the Savings and Investment Union (“SIU“), the President stated that while the Commission’s work on the SIU is critical, developing capital markets takes time. In that regard, she acknowledged that businesses cannot wait and that their needs are urgent.

New banking package

The President highlighted that the EU needs a banking system designed for growth, not just stability. On that matter, the President confirmed that the Commission will put forward a new banking package focused on simplification and tackling fragmentation, stating that demand for capital exists but that greater capacity and appetite for risk are required.

Simplification and reducing administrative burden

The President stated that the Commission’s 12 omnibus proposals are reducing administrative burdens by close to €17 billion per year, but that “simplification cannot be a one-way street”, calling on member states to match this effort and proposing a pact against “gold-plating” of EU rules at national level.

Climate resilience and insurance

On climate resilience, the President described the summer of 2026 as a “the summer of truth”, and in that regard, referred to some relevant statistics in terms of various categories of losses incurred on foot of heatwaves.

She noted that only around 25% of catastrophe losses in Europe are currently covered by private insurance, meaning that national budgets too often act as the insurer of last resort. President von der Leyen announced that the Commission will establish a climate insurance alliance to help close this protection gap, alongside a new climate resilience framework, a European heatwave plan and a new European water initiative.

Artificial intelligence

Turning to AI, the President described it as fast becoming a foundational layer of the EU’s economy and security, stating that the EU does not need to develop frontier AI technology itself in order to capture the greatest economic value from it, and that the focus will be on moving AI “from the screen to the real economy”, with particular attention to the health, transport, agri-food, advanced manufacturing, and defence and space sectors.

On 10 September 2026,  the European Parliament’s (“Parliament”) committee on economic and monetary affairs (“ECON”) voted in favour of adopting a draft report (“Report”) on the European Commission’s proposal (“Proposal”) for a regulation amending regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”), regulation (EU) 1286/2014 on key information documents for packaged retail and insurance-based investment products (“PRIIPs”) and repealing Commission delegated regulation (EU) 2022/1288.

ECON published a draft version of the Report in May 2026 – for more information, see FIG Top 5 at 5 dated 7 May 2026. At that time, it was pointed out that the Proposal could be improved as regards transparency, effectiveness and burden relief and accordingly, ECON set out a number of suggested amendments to the Proposal.

In a press release (“Press Release”) published by the Parliament, it was stated that ECON are of the view that the SFDR revision “should cut red tape and lower costs, without weakening the credibility of green investments.”

Some further matters highlighted by the Press Release are as follows:

• transition products channelling investments towards companies not yet sustainable should exclude those earning revenue from fossil fuel exploration, extraction, mining, or refining, unless such companies invest heavily in environmentally sustainable activities, have a measurable, time-bound plan to cut emissions, and put more capital into sustainable activities than into new fossil fuel projects;
• it is agreed to exempt professional investors, and to remove financial advice and portfolio management from the rules’ scope, without limiting firms’ ability to recommend other products that genuinely match clients’ sustainability preferences;
• in the interests of credibility, the investment companies would need due diligence and monitoring processes for categorised financial products, reviewed at least yearly, and updated as needed; and
• companies would be required to report on exposure to the fossil fuel sector, greenhouse gas emissions, and activities harming biodiversity-sensitive areas, and disclose any adverse impact on a product’s ESG objectives.

Next steps

The Press Release notes that the negotiating mandate will be announced at the start of the October plenary session.

On 14 September 2026, the European Parliament’s Committee on Economic and Monetary Affairs (“ECON“) published a draft report (“Report“) on the competitiveness of the banking sector in the European Union, prepared by rapporteur Isabel Benjumea Benjumea.

The Report comes on foot of the European Commission’s (“Commission“) communication of 17 July 2026 on the “Competitiveness of the Banking Sector and the Single Market in Banking”– for more information, see FIG Top 5 at 5 dated 23 July 2026. The Report also has regard to Enrico Letta’s report of 10 April 2024 on the Single Market and Mario Draghi’s report of 9 September 2024 on European competitiveness.

Rationale

ECON notes that fragmentation of the EU banking sector, persistent national barriers, excessive regulatory complexity and a lack of market-driven cross-border consolidation undermine the sector’s global competitiveness and widen the profitability gap between EU and US banks. The Report highlights that preserving financial stability must remain as the primary objective, but that this must be compatible with a regulatory framework that is proportionate and predictable while also fostering competitiveness, innovation and the financing of the European economy.

Key matters highlighted by ECON in the Report are as follows:

Market integration and consolidation

Here, the Report highlights various matters, some of which are as follows:

• the Banking Union, based on the three pillars of supervision, resolution and deposit insurance, should be further developed with a clear timeline and measurable milestones;
• ECON welcomes the Commission’s proposal to use the enforcement toolkit in cases of breaches of EU law, particularly with regard to mergers and acquisitions, and stresses that bank consolidation should be market-driven and assessed under clear, predictable and consistently applied prudential and competition rules, warning that unjustified government interventions may deter investment and hinder the emergence of stronger, more competitive European banking groups; and
• ECON welcomes the Commission’s intention to address the risk of excessive concentration of sovereign exposures by encouraging diversification of banks’ sovereign bond portfolios.

Capital requirements, competitiveness and proportionality

Some matters highlighted by the Report, in these areas, are as follows:

• the mandates of the European Supervisory Authorities (“ESAs”) should be expanded to include an explicit competitiveness and innovation dimension as a secondary objective, without prejudice to financial stability being their primary objective;
• genuine simplification of the capital stack is needed, highlighting that the objective should be to reduce the number of overlapping buffers and supervisory addons, creating a more transparent hierarchy of capital requirements, including with regard to the differentiation of going concerns and gone concerns;
• unlike the US, UK and Switzerland, the EU applies the full Basel framework to almost all banks regardless of risk profile or cross-border activity. This, the Report notes, creates a structural competitiveness gap for smaller European banks. In that regard, the Report calls for the upcoming review of Regulation (EU) No 575/2013 to explore an optional and simpler regime for small, non-systemic banks that do not operate across borders; and
• ECON welcomes the Commission’s intention to ensure similar regulatory treatment of intragroup exposures in domestic and cross-border situations where risk is effectively managed and supervised on a consolidated basis.

Simplification

With regard to simplification, the Report highlights:

• the need for an omnibus legislative initiative to identify and remove obsolete, excessively burdensome or overlapping provisions, focusing on eliminating duplication and avoiding multiple data requests to EU banks for the same information;
• more efficient supervision must go hand in hand with addressing “gold-plating”, and the ESAs should be permitted to challenge disproportionate national add-ons more effectively; and
• simplification should extend to supervisory processes, including streamlining and harmonising the supervisory review and evaluation process to avoid duplicative data requests, inconsistent timelines and limited transparency around risk assessments.

Digital framework

Here, some matters highlighted include:

• banks should be encouraged to deploy AI in areas such as creditworthiness assessments, fraud prevention and risk management, and that EU regulation must not become an obstacle to the adoption of technology;
• ECON calls on the Commission to clarify the interaction between the Artificial Intelligence Act and sectoral financial services legislation, particularly when it comes to internal governance and quality management processes; and
• as regards the tokenisation of money and assets, ECON believes this has the potential to deliver real-time settlement, lower transaction costs, increase liquidity and offer banks meaningful efficiency gains, and that shaping the digital assets regulatory framework correctly will allow the EU to preserve its role in global finance and avoid dependence on non-European providers.

Next steps

The Report instructs the President of the European Parliament to forward the resolution to the Council and the Commission once adopted.

1. Commission adopts delegated regulation on central contact points for CASPs under MLD4

 

On 8 September 2026, the European Commission (“Commission”) adopted a delegated regulation (“Delegated Regulation”) amending the regulatory technical standards (“RTS”) contained in delegated regulation (EU) 2018 / 1108 as regards the criteria for the appointment of central contact points for crypto-asset service providers (“CASPs”) and rules on their functions.

The amendments to the RTS extend their application to CASPs on foot of the  of amendments made to the Fourth Money Laundering Directive (“MLD4”) by the Wire and Cryptoasset Transfer Regulation.

The European Banking Authority published its final report on the RTS in April 2025 – for more information, see FIG Top 5 at 5 dated 1 May 2025.

Next steps

The European Parliament and the Council of the EU now have a period of three months to scrutinise the Delegated Regulation, If neither institution objects, the Delegated Regulation will be published in the official journal of the EU and will enter into force 20 days following such publication.

 

2. Delegated regulation on prudential framework for banks’ market risk under CRR published in OJEU

 

On 11 September 2026, Commission Delegated Regulation (EU) 2026/1221 (“Delegated Regulation”), which amends the capital requirements regulation (“CRR”), as regards temporary targeted operational relief measures and targeted multipliers for the calculation of an institutions’ own funds requirements for market risk, was published in the official journal of the European Union (“OJEU”).

The Delegated Regulation was adopted by the European Commission in June 2026 – for more information, see FIG Top 5 at 5 dated 11 June 2026.

Next steps

The Delegated Regulation entered into force on 12 September 2026, being one day following publication in the OJEU. The amendments introduced by the Delegated Regulation will apply from 1 January 2027, while the temporary targeted measures will cease to apply after 31 December 2029.

 

3. EBA responds to Commission’s non adoption of draft amending RTS on own funds and eligible liabilities under CRR

 

On 8 September 2026, the European Banking Authority (“EBA”) published a letter (“Letter”) sent to the European Commission (“Commission”) in response to the Commission’s letter of 20 July 2026, in which it informed the EBA that it would not endorse the EBA’s draft regulatory technical standards (“RTS”) on own funds and eligible liabilities under Regulation (EU) 575/2013 (“CRR”).

The draft RTS were aimed at speeding up the processing of prior permission applications under the RTS adopted in 2021, which both industry and competent authorities had considered unnecessarily lengthy.

The EBA published its final report containing the draft RTS in March 2026 – for more information, see FIG Top 5 at 5 dated 26 March 2026.

Next steps

In its Letter, the EBA has stated that it does not intend to resubmit a revised draft of the RTS. Instead, as suggested by the Commission in its letter, the EBA will consolidate the proposed amendment and any further simplification measures into the ongoing comprehensive review of the prior permission regime, with a view to the framework being revised one time only and having a lasting effect.

In a related press release, the EBA stated that it “will proceed with the broader review of the RTS, in line with the European Commission’s proposal, with a view to delivering further simplification and efficiency gains at a later stage.”