Welcome to the FIG Top 5 at 5

On 1 May 2026, Governor of the Central Bank (“Central Bank”), Gabriel Makhlouf, published a blog post (“Blog”) discussing key highlights from his recent attendance at an International Monetary Fund (“IMF”) meeting and a meeting of the governing council of the European Central Bank (“ECB”).

The Governor highlighted that the war in the Middle East “cast a shadow” over both meetings with uncertainty around the global outlook being a dominant theme. In addition to this broad theme, the Director also pointed to two further areas that were quite topical – the impact of AI on cyber security and operational resilience and innovation in digital finance.

Some of the key points / areas that the Governor drew attention to, following the IMF meeting are as follows:

• downside risks dominate the growth outlook;
• the IMF called on policymakers to strengthen resilience – ensuring that liquidity and funding facilities are ready accessible and operationally ready;
• the importance of internation cooperation in the context of building resilience, highlighting particularly the need to:
  • complete implementation of the Basel framework;
  • close data gaps, improve cross-jurisdictional data sharing and enhance oversight in the non-bank financial intermediation sector (“NBFI”). Here, the Governor took the opportunity to restate the Central Bank’s priority as regards “strengthening the financial stability lens in the regulation of the non-bank sector”;
• the implications of rapid developments in AI capabilities as regards cyber threats, together with cyber defences, particularly highlighting the importance of continued investment to protect against these threats and also to strengthen abilities to respond to an attack; and
• as regards digital finance, the Governor highlighted that this was widely discussed, particularly in the area of payments. Stablecoins, tokenised deposits, central bank digital currencies and the implications for public policy outcomes, as well as the cross-border elements and the regulatory approaches by different authorities were considered. In this regard, Governor Makhlouf referenced the Central Bank’s discussion paper on DLT and tokenisation in financial services – for more information, see FIG Top 5 at 5 dated 12 March 2026.

The Governor summarised the discussions and considerations at the ECB meeting, where ultimately, it was decided to keep the main policy interest rate (the deposit facility rate) unchanged at 2%.

1. Central Bank publishes notice on upcoming change in submission of schedule 2 registrations via portal

On 30 April 2026, the Central Bank of Ireland (“Central Bank”) updated (“Update”) its anti-money laundering / countering the financing of terrorism (“AML / CFT”) communications and publications webpage stating that schedule 2 firms seeking registration for AML / CFT purposes will be required to submit the registration, and all related post-registration submissions, through the Central Bank portal (“Portal”).

The Update advises that a system guide will be published at the end of Q2 2026, the aim of which is to allow firms to become familiar with the Portal and the new schedule 2 registration submission, together with all other post registration submissions, before the launch date.

The benefits of the Portal are highlighted, such as, a streamlined submission process / improved transparency / secure messaging / registration and document retrieval.

Next Steps

The Update states that the Central bank will provide further information on its Registration – Schedule 2 Firms webpage.

 

2. Central Bank publishes NCID report on deductions of State support payments from business interruption claim awards

On 28 April 2026, the Central Bank of Ireland (“Central Bank”) published a report (“Report“) on deductions of State support payments from business interruption claim awards 2020-2024 of the national claims information database (“NCID”).

The Report provides an analysis of settled business interruption claims for Covid and non-Covid related events settled between 1 January 2020 and 31 December 2024.

The Report examines the way in which State support payments received by claimants impacted business interruption claims and the extent to which compensation awards were reduced. In this regard, the Report highlights the concept of indemnity in insurance, highlighting that reductions in compensation align with the concept and restored claimants to their financial position before the claim event occurred.

Some of the key findings are as follows:

• 6,832 business interruption claims were settled between 2020 and 2024. Of these, 2,787 claimants had their award reduced because the claimant had received a COVID-19 state support payment. This represented 41% of all business interruption claims in this period;
• the total cost of the 6,832 business interruption claims settled from 2020 to 2024 was approximately €257 million;
• between 2020 and 2024 the total cost to insurers of settling the 2,787 business interruption claims that had deductions to claim awards was approximately €128 million; and
• total deductions from claim awards, due to state support payments received, by claimants was approximately €50 million.

Next Steps

The Report highlights that there are some outstanding business interruption claims which had not been settled by the reporting date of 31 December 2024 and, in that regard, the NCID will assess the materiality of the open cases to see whether further data collection is needed.

On 5 May 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) launched a consultation (“Consultation”) on draft technical advice (“Advice”) on minimum common standards for insurance guarantee schemes (“IGS”) in the EU.

Background

The European Commission (“Commission”) requested this Advice from EIOPA in August 2025. Under section 98 of the Insurance Recovery and Resolution Directive (“IRRD”),  the Commission is required to submit a report to the European Parliament and the Council assessing the appropriateness of minimum common standards for IGS in the EU, following consultation with EIOPA, by January 2027 – for more information, see FIG Top 5 at 5 dated 16 October 2025.

Advice

EIOPA highlights that, in the EU, there are different levels of protection for policyholders when an insurer fails, due to the existence of varying national schemes. Recognising that Solvency II and the IRRD reduce the likelihood and impact of an insurance failure, nonetheless, they cannot prevent all failures nor do they address the unequal protection of policyholders in the EU.

It is in this context that the Advice is published, with the Advice containing proposals across four main policy areas, as follows:

• general questions about the impact of minimum harmonised IGSs;
• the operational functioning of IGSs;
• the conditions for effective funding of IGSs; and
• the interaction between the IRRD and harmonised IGSs.

The Advice explains that each of those policy areas have been assessed against four policy objectives – effective and efficient policyholder protection / level playing field and harmonisation / transparency and comparability / simplification and burden reduction.

EIOPA sets out that for each of the policy areas, and the related objectives, it analysed several policy options and, where possible, put forward a preferred option.

EIOPA also published an annex (“Annex”), accompanying the Consultation, which analyses the four areas in the Advice in greater detail, looking at all of the options explored by EIOPA when drafting the Advice.

Proportionate

EIOPA has stated that, in its opinion, the Advice regarding minimum harmonisation represents a balanced, proportionate and effective approach that is in line with broader efforts to simplify regulation and reduce administrative burdens. In addition, EIOPA explains that its approach retains national flexibility where appropriate.

Next Steps

The Consultation is open for feedback until 26 June 2026, by way of an online survey.

Report on influence of harmonised IGS on consumer behaviour 

On 5 May 2026, EIOPA also published a  related report (“Report”) assessing how introducing IGS with minimum common standards influences consumer behaviour in the European insurance market. The Report looked at five member states – Czechia, France, Germany, Spain and Sweden – focusing on three types of insurance products – household insurance, supplementary health insurance, and life insurance.

The Report discusses the findings for each of the three categories of insurance, with some of the key findings as follows:

• introducing IGS within minimum common standards reduces consumers’ indecision and helps them to choose an insurance provider;
• when consumers are shown that domestic and cross-border insurance providers are equally protected under minimum common standards, they are more willing to consider cross-border providers – this is particularly the case where the cross-border option is cheaper;
• across both domestic and cross-border providers, consumer confidence that a valid claim would be paid if an insurer fails is increased where consumers have information on IGS with minimum common standards; and
• where there are harmonised standards for IGS, consumers are more willing to compare offers on price and are less likely to accept a higher premium for a domestic insurer when cheaper, equally protected options are available.

On 4 May 2026, the European Securities and Markets Authority (“ESMA”) published an interim report (“Report”) on its call for evidence (“CfE”) on a comprehensive approach for the simplification of financial transaction reporting.

The CfE, which covered financial transaction reporting under the Markets in Financial Instruments Regulation (“MiFIR”), the European Market Infrastructure Regulation (“EMIR”) and the Securities Financing Transactions Regulation (“SFTR”),  was launched in June 2025 – for more information, see FIG Top 5 at 5 dated 26 June 2025.

The Report contains a summary of the feedback received on foot of the CfE, with ESMA explaining that this Report comes in advance of the final recommendations for policymakers, which will be set out in the forthcoming final report. In the meantime, the Report aims to provide clear insights into the type of responses received and to highlight the principal elements identified during the CfE.

The Report highlights that most respondents indicated that overlapping and inconsistent reporting requirements, frequent and unsynchronised regulatory changes, fragmented reporting channels and dual reporting are major drivers of cost and complexity.

Some of the matters highlighted / addressed by the Report are as follows:

• the feedback shows that the main issues identified in the CfE correctly reflect the current landscape;
• there is broad support for the core principles guiding simplification measures, especially those regarding preserving information scope and making cost-benefit-based decisions;
• two simplification options have been identified as deserving of further assessment, namely, scenario 1a – delineation by type of instrument and scenario 2a – the “report once” model;
• section 4.8 of the Report considers supplementary measures to reduce the reporting burden as intermediate steps to be implemented in the medium term;
• the review of reporting channels is addressed in section 5 with further measures such as alternative technologies, reduced reporting frequency, and proportionality also considered;
• feedback emphasised that simplification efforts should maintain supervisory capabilities, preserve data quality, and ensure alignment with international standards; and
• stakeholders also welcomed the pause in the imminent developments under MiFIR regarding transaction and reference data.

Next Steps

ESMA has stated that it will engage further with market participants, including holding an open hearing on 28 May 2026 – registration is via this link. ESMA expects to publish the final report by mid 2026.

On 4 May 2026, the European Parliament’s committee on economic and monetary affairs (“ECON”) published a draft report (“Report”) on the 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.

The Report was authored by rapporteur Gerben-Jan Gerbrandy who welcomes the European Commission’s (“Commission”) proposal (“Proposal”) regarding a review of the SFDR which, he highlights, creates more meaningful categories for investors while providing burden relief to financial market participants.

Noting that the Proposal is an “excellent starting point” to create a better sustainable finance framework in the EU, the Report does point out that the Proposal could be improved when it comes to transparency, effectiveness and burden relief.

Accordingly, the Report sets out a number of suggested amendments to the Proposal, some of which are as follows:

• as regards transparency, it is recommended that the comparability of categorised products should be enhanced by requiring a limited set of mandatory principal adverse impact indicators to be disclosed. Additionally, it is put forward that financial market participants offering products that are categorised under the SFDR should disclose a description of the sustainability-related engagement strategy pursued by the financial market participant and how it has been implemented in alignment with the objectives of the product or a clear and reasoned explanation of why it does not pursue one;
• when it comes to effectiveness, the Report explains that the suggested amendments aim to create a more meaningful impact on sustainable investment, suggesting that:
  • the ‘ESG basics’ can be enhanced by requiring investments to outperform the average investment universe, reference benchmark, or average rating, after eliminating at least 20% of the lowest values for the chosen indicators or ratings; and
  • the safe harbour for products offering investments in taxonomy-aligned economic activities should be increased from 15 to 20%.
• addressing burden relief, the Report supports the Commission’s proposal on the removal of entity level reporting. In anticipation of the entry into force of the reviewed regulation, the Report suggests that those elements dealing with burden relief should start applying immediately upon entry into force.

The Commission adopted the proposed regulation in November 2025.