Welcome to the FIG Top 5 at 5

On 14 April 2026, the Government Legislation Programme for Summer 2026 was  published (“Programme”), identifying the Government’s priorities for the coming 13 week parliamentary session.

The Programme identifies 38 bills to be prioritised for publication and 26 bills to be prioritised for drafting, with 73 additional bills listed under “All Other Legislation”.

There are currently 25 bills on the Dáil and Seanad order paper, while 39 bills have been published and 29 enacted, since the Government came to office on 23 January 2025.

Those of direct relevance to financial services are outlined below:

Legislation for Priority Publication

• Conclusion of IBRC Special Liquidation and Dissolution of NAMA Billaims to effect the conclusion of the Irish Bank Resolution Corporation Special Liquidation and the dissolution of the National Asset Management Agency (“NTMA”) by the end of 2025. Further, it aims to implement appropriate arrangements to manage any remaining residual activity of both entities following the respective conclusion of their work mandates, including through the creation of a new Resolution Unit within the NTMA to manage any remaining residual activity from 2026 onwards. The Programme indicates that work is ongoing.
• Finance (International Financial Institutions) Bill aims to put in place the legislative authority for the Minister and the Central Bank of Ireland to contribute to the IMF Resilience and Sustainability Trust using a portion of Irelands allocation of IMF Special Drawing Rights. The Bill will also provide a government guarantee to the Central Bank of Ireland for the purpose of contributing to the IMF Trust and make other administrative amendments relating to Ireland’s membership of international financial institutions. The Programme indicates that Heads of Bill were approved in July 2025.

• Violation of Restrictive Measures Bill which will transpose EU Directive 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive measures. The Programme indicates that Heads of Bill were approved in March 2025.

Legislation for Priority Drafting

• Co-operative Societies Bill aims to place the co-operative model on a more favourable and clearer legal basis, thereby creating a level playing field with companies and encouraging the consideration of the cooperative model as an attractive formation option for entrepreneurs. The Programme indicates that work is ongoing.
• Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill – this aims to transpose certain aspects of the EU’s sixth Anti-Money laundering package that require primary legislation. The Programme indicates that Heads are in preparation.

All Other Legislation

• UN Restrictive Measures Bill aims to create a mechanism  by which persons would be obliged to adhere to the asset freezing requirements of certain UN Security Council Resolutions in the period prior to their incorporation in an EU legislative act, in order to meet Ireland’s international obligations and prevent sanctions evasion. The Programme indicates that heads are in preparation.
• Asset Covered Securities (Amendment) Bill aims to amend the Asset Covered Securities Act 2001 to facilitate the issuance of asset covered securities (covered bonds) either by specialist covered bond subsidiary entities under a specialist banking model or from non-specialist credit institutions operating under a universal banking model and related matters. The Programme indicates that Heads of Bill are being prepared.
• Personal Insolvency (Amendment) Bill aims to update aspects of personal insolvency legislation, following statutory review of Personal Insolvency Acts. The Programme indicates that work is ongoing.

Bills currently on the Dáil and Seanad Order paper as of 10 April 2026

• Central Bank (Amendment) Bill 2025 which aims to amend the Central Bank Act 1942 and prohibit financial service providers from discriminating against survivors of cancer from accessing financial services and to provide for related matters. The Programme indicates that the bill is at Committee Stage in Dáil Éireann – for more information, see FIG Top 5 at 5 dated 26 March 2026.

Next Steps

The FIG Top 5 at 5 will continue to monitor the progress of the legislative initiatives and update clients when appropriate.

On 16 April 2026, the Anti-Money Laundering Authority (“AMLA”) launched two consultations, regarding draft regulatory technical standards (“RTS”) and draft guidelines, that set out how obliged entities (“OEs”) should identify, assess and manage money laundering (“ML”) and terrorist financing (“TF”) risks, under regulation (EU) 2024/1624 (“AMLR”).

The consultations are as follows:

Consultation on draft guidelines (“Guidelines”) on business-wide risk assessment under article 10(4) of AMLR

Article 10 of the AMLR requires OEs to carry out a business-wide risk assessment (“BWRA”) that is proportionate to the nature of their business, including its risks and complexity, and their size, in order to identify and assess the risks of ML and TF that they are exposed to, as well as  the risk of non-implementation and evasion of targeted financial sanctions (“TFS”). The AMLA describes the BWRA as a key element of the risk-based approach from an OE’s perspective,  facilitating an understanding of an OE’s  risks arising from their business model, customers, products, services and transactions, delivery channels and geographical exposure.

These Guidelines set out a common framework for conducting a BWRA by all OEs under article 10(4) of the AMLR.

The Guidelines are structured around four main sections:

• an introduction, which outlines the overall scope and purpose of the Guidelines;
• general guidelines which set out the cope principles to be applied, including considerations for group-wide implementation, entities operating multiple business lines, the conduct of the non-implementation and evasion of TFS risk assessment and a focus on proportionality;
• methodology and sources of information, including additional sources of information to be taken into account; and
• the minimum requirements (“MR”) for the BWRA, which is made up of four key components, as follows:
  • MR1- business and operational overview;
  • MR2 – identification, assessment and classification of the OE’s inherent risks;
  • MR3 – assessment of the quality of AML / CFT/ non-implementation and evasion of TFS controls; and
  • MR4 – assessment and classification of the residual risks.

Section 5.2 of the consultation contains an overview of the questions for consultation.

Next Steps

This consultation is open for feedback until 15 July 2026 and the AMLA will hold a public hearing on the draft Guidelines on 28 May 2026 – interested parties can register here.  The AMLA expects to issue the final Guidelines in Q4 2026.

Consultation on draft RTS on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries under articles 16(4) and 17(3) of AMLR

Articles 16 and 17 of the AMLR address the regulatory provisions as regards design and implementation of group-wide AML / CFT frameworks, including their application across cross-border group structures and in situations where branches or subsidiaries operate in third countries. The draft RTS aim to further clarify these provisions.

The draft RTS cover matters such as:

• the minimum requirements regarding group-wide policies, procedures and controls;
• information sharing within a group, within groups whose head office is in the EU and have branches or subsidiaries in third countries and within groups whose head office is located outside of the EU;
• information sharing for supervisory purposes;
• additional measures for branches or subsidiaries in third countries of obliged entities and parent undertakings in the EU, covering matter such as:
  • individual risk assessments;
  • the sharing and processing of customer data within the group or with the OE;
  • the disclosure of information related to the reporting of suspicious transactions; and
  • sharing of customer data for the purposes of supervision.
• the criteria for identifying the parent undertaking in the EU in cases of two or more obliged entities whose head office is located outside of the EU; and
• the conditions for the application of group-wide requirements to structures sharing common ownership, management or compliance control.

An overview of the questions for consultation is set out in section 5.

Next Steps

This consultation is open for feedback until 15 June 2026. The AMLA will hold a public hearing on the draft RTS on 20 May 2026, interested parties can register here. The AMLA will submit the final draft RTS to the European Commission by 30 September 2026.

On 15 April 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) published a consultation (“Consultation”) on the treatment of proportional reinsurance treaties with features that may jeopardise the balance (“commensurateness”) between the solvency capital requirement (“SCR”) relief triggered by the treaty and the effective transfer of risk they provide.

Background

The Consultation refers to EIOPA’s 2021 opinion on the use of risk mitigation techniques by insurance undertakings (“Opinion”) which was published in response to an increase in the use of non-traditional risk mitigation techniques. The Opinion aims to provide guidance on the assessment of risk mitigation techniques, in particular regarding the consistency between the Solvency Capital Requirement (“SCR”) and risk transfer. The position is that if the use of reinsurance would lead to a reduction in the SCR that is not commensurate with the extent of the risk transferred or due to an inappropriate treatment within the SCR of any new risks that are acquired in the process, insurance and reinsurance undertakings should conclude that the risk-mitigating technique does not provide an effective transfer of risk.

New annex

The Consultation presents a new annex (“Annex”) to the Opinion, addressing proportional reinsurance, and follows the publication of two annexes in July 2025 on mass lapse reinsurance and on termination clauses – for more information, see FIG Top at 5 dated 17 July 2025.

The Consultation sets out the proposed guidance on the treatment of proportional reinsurance treaties with features, for example loss limits, loss corridors or sliding-scale commissions, that may upset that balance between the SCR relief triggered by a treaty and the effective transfer of risk.

The Consultation aims to ensure that the effect of such features is properly considered when assessing the effectiveness of the risk transfer.

Reinsurance commissions

The Consultation also clarifies the treatment of reinsurance commissions under the standard formula’s premium risk, setting out that any reinsurance commission representing a volume measure for risk exposure for the cedent is equivalent to premiums and therefore should increase the standard formula premium risk.

Next Steps

The Consultation is open for feedback until 17 July 2026.

1. EIOPA updates guidance on exchange of information within colleges under Solvency II

On 20 April 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) published a final report (“Report”) containing revised guidelines (“Guidelines”) on the exchange of information on a systematic basis within colleges under the Solvency II directive.

The revised Guidelines aim to strengthen supervisory cooperation by establishing a consistent and systematic approach to the exchange of information among national competent authorities that are involved in the supervision of cross-border insurance groups in the EEA.

The Guidelines supplement the 2015 guidelines on operational functioning of colleges and are addressed to supervisory authorities within the colleges of EEA groups. EIOPA consulted on the Guidelines in July 2025 – for more information, see FIG Top 5 at 5 dated 17 July 2025.

The Report outlines that two stakeholders provided feedback on foot of the July 2025 consultation, with a high level summary of the comments received set out in a feedback statement in an annex to the Report. The Report confirms that EIOPA’s assessment of the feedback received did not result in any changes to the revised Guidelines.

EIOPA has highlighted that the Guidelines do not introduce any new reporting requirements, rather, they leverage data that has already been reported to improve the supervision of cross-border groups.

Next Steps

A consolidated version of the Guidelines will be published on EIOPA’s website. The Guidelines will apply from 30 January 2027.

2. EIOPA launches consultation on proposal to shorten 13 sets of guidelines under Solvency II

On 15 April 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) launched a consultation (“Consultation”) regarding its proposal to shorten 13 sets of guidelines under Solvency II with the aim of supporting the goal of simplifying regulation and reducing administrative burden in the EU.

The Consultation paper highlights EIOPA’s duty to review existing EIOPA guidelines with a view to ensuring that any such guidelines are up to date, and in line with, the revised Solvency II Directive. In addition, the Consultation is aimed at simplifying and shortening the guidelines, particularly in cases where the guidelines are relevant for insurance and reinsurance undertakings.

The Consultation also highlights the April 2025 publication of EIOPA’s note setting out its approach regarding simplifying regulation and reducing administrative burdens to help boost European competitiveness – for more information, see FIG Top 5 at 5 dated 10 April 2025.

With the proposal set out in the Consultation, EIOPA hopes to streamline 13 sets of guidelines by at least 25%, allowing room for some flexibility depending on the nature and length of the document.

Some of the EIOPA guidelines coming within the scope of this current shortening exercise, across Pillar 1 and Pillar 2 topics, are as follows:

Pillar 1

• guidelines on the use of internal models;
• guidelines on application of the life underwriting risk module;
• guidelines on the implementation of the long-term guarantee measures;
• guidelines on classification of own funds;
• guidelines on recognition / valuation of assets and liabilities other than technical provisions.

Pillar 2

• guidelines on own risk and solvency assessment; and
• guidelines on system of governance.

The Consultation sets out each set of guidelines within the scope of the exercise  and also provides an accompanying explanatory text for each set of guidelines.

Limited scope

EIOPA explains that the Consultation has a limited scope, focused only on shortening. It is also highlighted that proposals for new or amended guidelines were considered, but that EIOPA did not identify major gaps that would have required immediate action. However, EIOPA also stated that it may discuss the possible review of guidelines, at some point in the future, as part of the ongoing fitness check of the rulebook.

National frameworks

After the shortening exercise has been finalised, NCAs are expected to review and update their national frameworks to eliminate the deleted guidelines and ensuring a level playing field and a single rule book.

Next Steps

The Consultation is open for feedback until 8 July 2026, following which, EIOPA will publish a report on the Consultation including the revised proposal and the resolution of stakeholder comments.

The revised guidelines will be applicable as of 30 January 2027.

On 20 April 2026, the legislative package regarding the crisis management and deposit insurance (“CMDI”) framework was published in the official journal of the European Union (“OJEU”).

The legislative package amends the Bank Recovery and Resolution Directive (“BRRD”), the Single Resolution Mechanism (“SRM”) and the Deposit Guarantee Schemes Directive (“DGSD”). The European Parliament and the European Council adopted the  legislative proposals in March 2026 – for more information, see FIG Top 5 at 5 dated 12 March 2026.

The following were published in the OJEU:

• Directive (EU) 2026/804 amending the DGSD as regards the scope of deposit protection, the use of deposit guarantee schemes funds, cross-border cooperation, and transparency;
• Directive (EU) 2026/806 amending the BRRD as regards early intervention measures, conditions for resolution and funding of resolution action and Directive 2014/24/EU as regards valuation services in resolution; and
• Regulation (EU) 2026/808 amending the SRM as regards early intervention measures, conditions for resolution and funding of resolution action.

SRB response

The Single Resolution Board (“SRB”) published a statement on 20 April 2026, welcoming the publication of the CMDI legislation in the OJEU, stating that:

“The reform enhances the existing toolkit by providing more options for addressing smaller and mid-sized banks in crisis, while also refining important technical elements of the framework based on lessons learned over the first decade of the Single Resolution Mechanism. The SRB is working to implement the new rules once they become applicable.

The publication of the CMDI reform in the OJ is a step forward in unlocking the pending reforms for the completion of the Banking Union, which is essential to strengthen Europe’s resilience and competitiveness.”

Next Steps

The legislation amending the DGSD and the BRRD  will enter into force on 10 May 2026, being 20 days following publication in the OJEU. The legislation amending the SRM will enter into force on 11 May 2028, with some exceptions that will apply from 11 June 2026.