Welcome to the FIG Top 5 at 5

On 14 October 2026, Deputy Governor, Financial Regulation, at the Central Bank of Ireland (“Central Bank“), Mary-Elizabeth McMunn, delivered a speech (“Speech“) at the Electronic Money Association Conference, entitled “Transitioning through trust – securing the future of payments.” The Deputy Governor addressed the pace of change in the payments sector and the importance of public trust, the Central Bank’s supervisory priorities for the sector, and how the Central Bank has adapted its engagement with innovation.

A fast-changing payments landscape

The Deputy Governor noted that technology and innovation are leading to new payment instruments and infrastructures, with digital finance, distributed ledger technology (“DLT“), tokenisation, and AI frontier models and agentic capabilities, representing a new horizon for payments. However, she identified two risks arising from this pace of change:

• the first being that public money does not keep pace, which is why the Eurosystem is modernising central bank money (including through the Pontes project and the digital euro) and why the Central Bank has increased its focus on digitalisation and tokenisation across its gatekeeping, regulation and supervisory work; and
• secondly, that firms rush ahead without a coherent strategy, leading to products that are not interoperable, sustainable or scalable, and potentially resulting in fragmentation, increased costs and interoperability hurdles for consumers and businesses.

The Deputy Governor stated that recent Central Bank research shows that security, reliability and fraud protection matter most to consumers, and that this insight should inform both industry innovation and the Central Bank’s approach to payments policy development and supervision. She went on to examine concerns around security, reliability, and fraud prevention through the Central Bank’s supervisory lens.

Supervisory priorities: safeguarding and operational resilience

The Deputy Governor identified safeguarding of customer funds and operational resilience as two key supervisory focus areas relevant to security and reliability. As regards safeguarding, she noted that the Central Bank has carried out significant supervisory work and interventions in recent years, and that while there have been improvements, particularly in governance and board oversight, pockets of weakness remain, with more recent safeguarding incidents centring on control failures in outsourced parts of the process. She confirmed that safeguarding will remain a key supervisory priority for the sector.

Ms McMunn also addressed operational resilience, stating that threats to firms’ operations and the wider system are severe and rising, and that increasing digitalisation elevates exposure to fraud, system outages and cyber-attacks. She emphasised that compliance with DORA should not be treated as a mere compliance exercise, that ICT governance is a matter for the board (not just the IT department), and that firms are expected to understand their critical business services, outsourcing arrangements and technology dependencies, set impact tolerances, and regularly test recovery plans.

Specifically touching on AI, the Deputy Governor cautioned against over-reliance and undue confidence, observing that resilience depends on human judgement built over years, and that efficiency and resilience do not necessarily move in the same direction, stating that, “significant adaptive work may be required to maintain resilience while striving for efficiency.”

Fraud prevention

The Deputy Governor described financial crime, including money laundering, terrorist financing, sanctions evasion, market abuse and fraud, as another critical area of supervisory focus. She referenced the Central Bank’s most recent data showing that €179 million in fraudulent payments were recorded by Irish-resident payment service providers during 2025, up 27% from €140 million in 2024, with fraudulent e-money payments increasing by 57.7% to €40.42 million (the largest relative increase for the second year running) and stated that this growth should give pause for thought, notwithstanding that the fraud rate is still relatively low.

She confirmed that combatting financial crime is a key focus area for the Central Bank this year, and that it  has completed a cross-sectoral thematic review of controls on certain types of fraud and the fair treatment of fraud victims, with findings to be communicated in due course.

Engagement with innovation

The Deputy Governor described a shift in the Central Bank’s approach to be more future-focused and open in its engagement with the innovation ecosystem, including being clearer with firms, both supervised firms and those going through authorisation, about the Central Bank’s activities, actions and expectations.

She noted that the Central Bank’s innovation hub had 78 engagements with firms last year (a 10% increase year-on-year) and is on track to exceed that this year – for more information on the innovation hub, see FIG Top 5 at 5 dated 16 July 2026. The Deputy Governor also gave an update on the innovation sandbox, flagging that a report on the outcomes and findings from the sandbox is expected to be published in November. She also confirmed that there will be a third sandbox programme, which will be launched in the coming months.

Conclusion

The Deputy Governor concluded that while payments are changing rapidly, the fundamental importance of trust remains constant, alongside the importance of security, reliability and consumer protection.  She also cited the need for regulators and innovators to collaborate to “deliver a better future, and innovation in the interests of us all.”

1. Deputy Governor Colm Kincaid delivers speech on turning consumer protection commitment into delivery

 

On 15 October 2026, the Deputy Governor of Consumer and Investor Protection at the Central Bank of Ireland (“Central Bank“), Colm Kincaid, delivered a speech (“Speech“) at the Compliance Institute Annual Conference 2026. Mr Kincaid noted that it has been one year since he gave his first speech as Deputy Governor for Consumer and Investor Protection, and with that in mind, he used the Speech as an opportunity to reflect on the progress made since those initial remarks. For more information on that speech, see FIG Top 5 at 5 dated 9 October 2025.

Listening to consumers

The Deputy Governor noted that he has now met bilaterally with more than 30 not-for-profit organisations, and that the Central Bank’s annual civil society roundtable (“Roundtable”) last month brought together 22 civil society organisations and relevant public bodies, the largest such group since the Roundtable began. He also highlighted the broadened membership of the Central Bank’s consumer advisory group.

Mr Kincaid also highlighted the Central Bank’s enhancement of the data it gathers on consumer experiences, citing the launch of a new consumer insights model – a large-scale quantitative survey of 4,000 consumers per year – which, the Deputy Governor stated, is informing the Central Bank’s work across investments, payments, banking, credit and insurance. He encouraged organisations to take more time to listen to customers.

Key emerging priorities

The Deputy Governor identified three priority themes drawn from the Central Bank’s 2026 regulatory and supervisory outlook, being customer experience, digitalisation, and fraud and scams.

When it comes to customer experience, the Deputy Governor highlighted that the Central Bank completed a review of complaints handling across insurance, retail intermediaries, payment institutions and electronic money sectors in July – the feedback report on this review was published in July 2026 – for more information, see FIG Top 5 at 5 dated 27 August 2026.  Mr Kincaid stated that the Central Bank has followed this with a broader examination of customer experience, looking at the quality of customer engagement and communication channels, including underlying enablers such as training and quality assurance

With regard to digitalisation, Mr Kincaid highlighted the work of the Central Bank’s innovation hub and the recent conclusion of the second innovation sandbox programme, which was focused on innovation in payments. In addition, he noted the work on the digital euro in terms of advancing technical readiness.

The Deputy Governor noted that targeted supervisory engagement has influenced feature enhancements within banking apps. He also flagged that, this year, the Central Bank will investigate what products are being offered to customers via banking apps and how they are being sold, having regard to the requirements of the new Consumer Protection Code (“CPC”).

In terms of fraud and scams, the Deputy Governor noted that fraud is now the most common form of personal crime in Ireland and, in that regard, he referred to his speech on collaboration in the fight against economic crime of last week – for more information, see FIG Top 5 at 5 dated 15 October 2026. He concluded that, “…more coordinated and connected action is needed.”

He highlighted that the Central Bank has completed its thematic review of authorised push payment fraud in the banking sector and will communicate outcomes to relevant firms in due course, including on material gaps requiring remediation and how firms should better incorporate fraud risk into their risk and compliance frameworks.

Supervisory framework developments

The Deputy Governor pointed to the Central Bank’s new integrated supervisory model, which he said recognises the increasingly interconnected nature of risk and allows the Central Bank to follow the chain of a customer complaint or risk from the harm experienced by the customer through to underlying weaknesses in culture, governance or systems, and vice versa. Some further supervisory developments highlighted are as follows:

• the implementation of the 18 recommendations from the Organisation for Economic Co-operation and Development’s (“OECD”) review of the Central Bank’s financial consumer protection supervisory functions – for more information, see FIG Top 5 at 5 dated 19 December 2024;
• ongoing delivery of the 21 initiatives under the Central Bank’s “Regulating and Supervising Well” roadmap, intended to make the framework clearer, more proportionate and easier to navigate while maintaining existing protections – for more information, see FIG Top 5 at 5 dated 11 December 2025;
• enhancements to the Central Bank’s approach to gatekeeping and to how it gathers and uses data across its mandate; and
• an external review, commissioned by the Central Bank, regarding its approach to enforcement – for more information, see FIG Top 5 at 5 dated 30 July 2026.

Consumer Protection Code

The Speech also addressed the modernised CPC, which took effect in March 2026 following a 12-month implementation period, with Mr Kincaid confirming that the Central Bank’s focus is now on ensuring the CPC is fully embedded. The upcoming extension of the provisions of the CPC to the credit union sector was also highlighted.

Financial wellbeing

Addressing this area, Mr Kincaid highlighted the following progress:

• the Government’s advancement of the national financial literacy strategy; and
• the announcement, by the Government, of the new savings and investment account.

He also took the opportunity to point the audience to a recent publication of the OECD, “Protecting and Empowering Consumers to Advance their Financial Well-being”, which, he highlighted, contains a valuable conceptual framework for financial wellbeing.  

Conclusion

Mr Kincaid highlighted that compliance is a means to an end, with that end being “a financial system that works in the best interests of consumers, investors and the wider economy. A system characterised by trust, integrity and high standards. A system that enables innovation, growth and the financial wellbeing of those it serves.”

 

2. Central Bank updates general guidance on the CPC 2025

 

In the second week of October 2026, the Central Bank of Ireland (Central Bank”) published an updated version of the general guidance (“Guidance”) on the consumer protection code (“CPC”).

The Guidance was first published in March 2025 and last updated in December 2025 – for more information, see FIG Top 5 at 5 dated 22 January 2026.

This update primarily consists of two additions, which are both marked as having been “added to Guidance September 2026”, and are as follows:

• Section 3.9: Complaints resolution –this addresses regulation 2 of the consumer protection regulations (“Regulations”). A new paragraph has been added whereby firms are referred to the definition of “complaints” in regulation 2 where the complaints requirements refer to the provision of financial services or products. Firms are reminded of their obligations under the Consumer Rights Act 2022 (“2022 Act”) and the Consumer Credit Act 1995 (as amended) and are advised to consult the CCPC’s guidelines on the 2022 Act for examples and roles and responsibilities in relation to hire purchase and consumer hire; and
• Section 3.14: Arrears – mortgage debt secured by a mortgage borrower’s primary residence – this new paragraph addresses the requirements as regards alternative repayment arrangements (“ARAs”) in regulations 253-257 of the Regulations. Specifically, firms are referred to the Central Bank guidance on appropriate and sustainable ARAs under the CPC 2025 – for more information, see FIG Top 5 at 5 dated 27 August 2026.

The new paragraph addresses various expectations as regards ARAs, covering matters such as: the review schedule / robust procedures, controls and monitoring / assessment and remediation of any borrower detriment / regular monitoring / specification as to what review letters should cover / a requirement for explicit checks (in writing and verbally) on any change in the borrower’s circumstances / implications of both increasing and not increasing payments where circumstances change / written communication of the review outcome, including where the borrower did not engage.

On 20 October 2026, the Central Bank of Ireland (“Central Bank”) published its eighth annual private motor insurance report (“Report”) of the National Claims Information Database (“NCID”). The Report, which is based on data up to 31 December 2025, aims to improve the overall transparency of the private motor claims environment.

The Report is accompanied by additional research (“Research”) which aims to help consumers understand the costs associated with insurance and what insurers use their premiums for. The Research addresses some common questions that drivers and policymakers have about the cost of car insurance, increasing transparency around the impact that various factors have on premiums.

It is highlighted that both the Report and the Research support the Central Bank’s work as regards the action plan for insurance reform.

The Report contains six parts and related appendices, covering:

• Part 1 – addresses premiums for private motor insurance between 2011 and 2025;
• Part 2 – this looks at claims as regards motor accidents that took place between 2011 and 2025;
• Part 3 – this provides a breakdown of insurers’ income and expenditure for private motor insurance for the financial years 2011 – 2025;
• Part 4 – this examines how claims were settled between 2015 and 2025, together with the various associated costs;
• Part 5 – this contains an analysis of the impact of the personal injury guidelines on settlement of claims; and
• Part 6 – this looks at the change in the ultimate claim costs for the years 2018 – 2025, containing information as to claim development patterns and large claims from 2011 to 2025.

Some of the key findings from the Report are as follows:

Cost of insurance

• in 2025, the average written premium per policy increased by 4% to €655, although a decreasing trend emerged in the final two quarters, with the quarterly average falling from €658 in Q2 to €650 in Q4;
• the claims cost per policy increased by 10% in 2025 to €424, the highest it has been since 2014;
• damage claims costs per policy reached €197 in 2025, the highest recorded in the Report’s time series, while injury claims costs per policy were €228; and
• claims exceeding €250,000 accounted for approximately 44% of estimated ultimate injury claims costs in 2025, compared with approximately 30% before COVID-19.

Claim settlements

• the total cost of claims settled in 2025 was €753 million across approximately 157,000 claims;
• the number of injury claims settled increased by 7% compared with 2024, but remained 21% below the 2015–2019 pre-COVID average;
• the number of damage claims decreased by 1% and average cost increased by 2% in 2025 compared to 2024;
• as regards injury claims settled in 2025:
  • 46% settled directly with an insurer, taking an average of 1.7 years;
  • 18% settled through the Injuries Resolution Board (“IRB”), taking 2.6 years; and
  • 36% settled through litigation, taking 4.7 years to settle, on average.

For injury claims settled for a total cost below €100,000, average compensation was €19,734 through the IRB, compared with €19,600 through litigation. However, average total costs were €22,523 and €40,800, respectively. Legal costs accounted for 49% of total costs in the litigated channel, compared with 4% through the IRB and 16% for direct settlements.

Personal Injuries Guidelines

Across all settlement channels, 88% of injury claims settled in 2025 were settled under the Personal Injuries Guidelines (“Guidelines”), including 73% of litigated claims. The proportion of litigated claims settled under the Guidelines reached 76% in H2 2025.

Compared with claims settled in the same channels under the book of quantum in 2020, average total costs for claims settled under the Guidelines in 2025 were:

• 26% lower for direct settlements before IRB involvement;
• 1% lower for settlements through the IRB; and
• 5% lower for direct settlements after IRB involvement.

An analysis of smaller claims settled through litigation in 6 years or less suggests that those settled under the Guidelines have average compensation costs that are 22% lower, and total costs that are 4% lower, than similar claims settled under the book of quantum.  The Report cautions that the current sample of claims that settled under the Guidelines in 2021 to 2025 is biased towards faster settling, potentially less complex claims.

Operating profit and accompanying research

Insurers’ operating profit in 2025 was 7% of total income before interest and tax, and 5% after tax. Releases of reserves for prior-year claims contributed 3% to operating profit in 2025.

The accompanying Research explains that claims costs represented 60% of premium income in 2025, while business expenses accounted for a further 36%. The Central Bank’s press release breaks this down further into damage claims (32%), injury compensation (17%), legal costs (9%), operational expenses (22%), broker commissions (8%), reinsurance (3%) and Motor Insurers’ Bureau of Ireland contributions (3%).

Welcoming the publication of the Research, Minister of State Robert Troy, stated:

“I also welcome the publication of Behind the Data, which will provide greater transparency around the factors influencing motor insurance costs. This complements the forthcoming Motor Insurance Transparency Code, which will provide clearer information to approximately 2.2 million private motor insurance policyholders.”

Reaction

In a press release dated 20 October 2026, Minister of State with responsibility for Financial Services, Credit Unions and Insurance, Robert Troy, welcomed the emerging downward trend in premiums. He noted that this aligns with Central Statistics Office figures which show a 5% decrease in motor insurance premiums in the 12 months to September 2026.

The Minister stated:

“While these figures are encouraging there can be no complacency. Insurance companies must ensure that these reforms are felt directly by their customers through lower premiums.”

The Government also highlighted the rollout by participating firms of the motor insurance transparency code’s (“Code”) premium summary statement and market overview statement, intended to explain individual premium changes and wider market conditions. The first review of the Code is to take place within 18 months, with the Central Bank reporting to the Minister for Finance on adherence and impact.

In its press release, also dated 20 October 2026, Insurance Ireland welcomed moderating premiums and the impact of the Guidelines, while arguing that legal costs continue to offset some of the benefits of reform. It called for greater transparency and proportionality in legal costs and more efficient claims resolution.

Moyagh Murdock, CEO of Insurance Ireland, stated:

“Insurance reform is making a difference, but the job is not finished. We must ensure that the progress made in reducing personal injury compensation costs is not undermined by excessive legal fees. Continued collaboration between Government, regulators, the legal profession and the insurance industry will be crucial to delivering lasting benefits for motorists.”

The Central Bank of Ireland (“Central Bank”) has published its feedback statement (“Statement”), dated August 2026, on consultation paper 167 (“CP167”) concerning the methodology for calculating contributions to the Deposit Guarantee Scheme (“DGS”). The Statement confirms the move from a flow-based to a stock-based approach. For more information on CP167, see FIG Top 5 at 5 dated 19 March 2026.

Overview

The Central Bank received five responses, expressing broad support for the change, which aims to make contribution requests more proportionate by taking account of each member institution’s cumulative past contributions, alongside its risk profile and level of covered deposits.

In practice, not every institution will have to contribute whenever additional funding is needed. Contributions will initially be sought from institutions whose past contributions represent the lowest proportion of their risk-weighted covered deposits.

Key points from the feedback

There were a number of issues raised in the feedback received to CP167 around:

• transparency and planning – here the Statement highlights that the Central Bank will seek to engage bilaterally with firms facing significant contribution requests before the end of September in the relevant year. However, final amounts cannot be confirmed until internal governance processes are completed, typically in November or December of a given year;
• risk-based queries – here the Statement highlights that the calculation of risk indicators
  and their weightings did not form part of CP167. Those seeking further details as to how these are calculated are referred to risk-based contributions guidance document
  available on the Central Bank’s website. This document will be updated
  following the consultation to reflect the move to the stock-based approach;
• refund mechanism, with the Statement highlighting that institutions whose past contributions place them in credit will retain that credit against future contribution requirements, rather than receiving a refund;
• smoothing mechanism – here it is highlighted that the Central Bank has decided against smoothing changes in covered deposits or risk weights, noting, for example, that smoothing one institution’s deposit growth would shift contribution requirements to other DGS members; and
• other matters, for example historic contributions and DGS coverage level.

Depositor protection, the DGS fund’s minimum target of 0.8% of total covered deposits and the calculation of institutions’ risk weightings remain unchanged.

Implementation

The Statement sets out the Central Bank’s intention to apply the methodology from Q3 2026, using Q2 2026 covered deposit data. The Statement states that the Central Bank will engage with member firms “in the coming weeks” to confirm their stock levels in advance of the stock-based methodology being applicable.

1. Joint Committee of the ESAs publishes 2027 Work Programme

 

Overview

On 13 October 2026, the Joint Committee (“JC”) of the European Supervisory Authorities (“ESAs”) published its work programme (“Programme”) for 2027.  The JC’s priorities for 2027 are similar to their 2026 work programme – for more information, see FIG Top 5 at 5 dated 23 October 2025.  In 2027, the JC will focus on areas where cooperation among the three ESAs is key to supporting consumer protection, financial stability, and effective supervision.

Background

The Programme reflects the JC’s commitment to ensuring a coordinated supervisory response to cross-sectoral issues and supporting a resilient and innovative financial system across the EU.  It builds on the European Commission’s (“Commission”) objective to build an efficient Savings and Investment Union.  There is an overarching focus on advancing a simplification agenda and reducing overlapping regulatory and reporting requirements / burdens across the financial sector.

Priorities of the Programme

Some of the JC’s priorities are as follows:

• continued support for the Digital Operational Resilience Act (“DORA”), particularly as regards the effective operation of the oversight framework of critical ICT third-part providers (“CTPPs”), and its work related to supervisory convergence of DORA. The ESAs, through the oversight forum, will update the list of CTPPs, conduct the risk assessment, perform the planned examination activities for each of the designated CTPPs, and follow-up on any potential recommendations issued in 2026. They will also prioritise testing and member capacity-building and strengthen co-ordination between participating authorities in the pan-European systemic cyber incident co-ordination framework;
• work on improving consumer protection and fostering financial innovation, particularly as regards drafting technical standards based on the proposed amendments to the Packaged Retail and Insurance-based Investment Product (“PRIIPs”) Regulation. These will include consumer testing and public consultation with an effort at streamlining and simplifying the content of PRIIPs key information documents.  Work will continue to promote supervisory convergence on PRIIPs rules and give guidance regarding the practical application of PRIIPs rules, taking into account ESAs simplification and burden objectives;
• the JC will continue its prioritisation of sustainable finance. As regards sustainability-related disclosures in the financial services sector, the ESAs will, if required, deliver technical standards or technical advice on the revised SFDR framework. The ESAs will continue to monitor the application of existing obligations under SFDR, to promote supervisory convergence, and to provide any necessary guidance on practical application;
• the JC will continue its work relating to the review of the Securitisation Regulation (“SECR”), with regarding to market monitoring of non-bank financial intermediation involvement in securitisation markets, and monitoring regulatory developments with third countries to identify potential risks of divergence which may have a material impact on cross-border investments and financing to the EU economy. The JC will strengthen efforts in the area of supervisory convergence to ensure consistency in the implementation of SECR and an emphasis on supervision and enforcement activities of national competent authorities;
• the JC will continue to assess key trends and cross-sector risks of financial stability. This work will produce targeted risk-analysis in addition to their respective sectoral risk analysis.  The detailed mapping and listing of identified financial conglomerates and external credit assessment institutions will be within the scope of this work;
• the JC will continue with key initiatives launched in 2026 via the European forum for innovation facilitators, including the third data collection exercise for BigTechs and mixed activity groups providing financial services within the EU, and supporting coordination between financial sector sandboxes and AI regulatory sandboxes mandated by the EU AI Act. They will also work on publishing an innovation trends factsheet with a dedicated focus on artificial intelligence, tokenisation, distributed ledger technology, and smart contracts.

Next steps

The JC will implement its Programme activities, deliverables and coordination mechanisms with a focus on simplification and burden reduction.  The JC will remain attentive to developments in the broader EU simplification agenda and may adjust their priorities, timelines or approaches as necessary to support these developments and objectives.  Where appropriate, joint work may contribute to reducing overlap, supporting greater supervisory convergence and improving the overall usability and consistency of the EU regulatory framework.

 

2. EBA publishes final report on prudential requirements under CSDR

 

On 9 October 2026, the European Banking Authority (“EBA”) published its final report (“Report”) and draft regulatory technical standards (“RTS”) regarding certain prudential requirements for central securities depositaries (“CSDs”) and designated credit institutions offering banking-type ancillary services under the Central Securities Depositaries Regulation (“CSDR”).

Background

Commission delegated regulation (EU) 2017/390 contains RTS that set out the prudential framework for banking CSDs and credit institutions. In December 2025, the EBA consulted on amending the RTS with the aim of making sure that the prudential framework reflects and mitigates the possible extra complexity in CSD arrangements after the introduction of the CSDR refit regulation.

Report

Section 4.2 of the Report contains a summary of the main points raised by those who responded to the consultation, together with relevant analysis and any action taken on foot of matters raised, if thought necessary by the EBA. The main issue raised was around the balance of responsibility in the sharing of information relevant to banking CSDs’ credit and liquidity assessment of clients / participants when providing banking-type ancillary services to the participants of non-banking CSDs. The EBA’s position is that it is the banking CSD’s responsibility to carry out an adequate liquidity and credit assessment when providing this service due to the fact that the service is a contractual arrangement between the participant and banking CSD.

Section 3 of the report contains the draft RTS.

Next steps

The draft RTS will be submitted to the European Commission for endorsement before being published in the official journal of the EU.