Welcome to the FIG Top 5 at 5

On 10 June 2026, the Central Bank of Ireland (“Central Bank”) published the third edition of its Authorisations and Gatekeeping Report (“Report”).

The Report provides a summary of the authorisation and gatekeeping activity across all sectors in 2025 and provides some insights regarding common issues that the Central Bank encounters with applications for authorisation.

The Report sets out that the timeline from initial application to authorisation is strongly influenced by:

• the complexity of the proposed application / business model;
• the quality of the application submission and whether changes are made to the submission mid-process; and
• the applicant’s timeliness in responding to the Central Bank’s queries.

Recent High Court judgment

In the foreword to the Report, Deputy Governor, Financial Regulation at the Central Bank, Mary-Elizabeth McMunn, highlighted the inclusion of commentary on the recent High Court judgment (“Judgment”) as regards a prohibition notice. She stated that, although the matter does not come within the Central Bank’s gatekeeping remit, it was considered to be sufficiently important so as to warrant inclusion in the Report. In that regard, some of the matters highlighted are as follows:

• the Central Bank is taking the Judgment “very seriously”, noting the role of the High Court when it comes to protecting individuals from the potentially very serious implications that can stem from investigations and prohibitions;
• since the relevant investigation and prohibition took place, there have been significant legal and procedural changes, such as changes as a result of the Central Bank (Individual Accountability Framework) Act 2023 and the incorporation of the recommendations of the Enria Review, discussed in the update below; and
• bearing in mind that the Central Bank published a consultation of prohibition notes in January 2026, the Report highlights that supplemental guidance will be published over the coming months – for more information, see FIG Top 5 at 5 dated 29 January 2026.

Authorisations Expectations

Chapter 2 of the Report deals with the Central Bank’s authorisations expectations. In particular, it highlights its November 2024 cross-industry “Guidance on expectations for applicants seeking authorisation from the Central Bank of Ireland to operate as a regulated Firm” (“Guidance”), explaining that the Guidance expands on the existing guidance on the Central Bank’s website and gives further details as to how the Central Bank discharges its authorisation mandate. The Report emphasises that the overall aim of the Guidance is provide transparency regarding the authorisation process and to support firms in understanding the Central Bank’s requirements and expectations of applicant firms.

The Report notes that the Guidance sets out principles as regards the Central Bank’s expectations around the clarity, accuracy and completeness of an application and its emphasis on the need for applicants to be well informed on current sectoral and legal requirements.   Additionally, the Report points to the common areas of substantive focus, applicable to all applicants, that are contained in the Guidance, noting that the list contained therein is non exhaustive, some of those areas are as follows:

• the need to have a sufficient substance in the State;
• the need to demonstrate adequate governance in line with the nature and scale of business activities to be undertaken;
• outsourcing;
• capital requirements; and
• compliance monitoring processes.

Authorisations by Sector

Chapter 4 deals with authorisations by sector together with relevant timelines regarding such authorisations, setting out information relating to:

• authorisation activity for each sector for 2025 together with an explanatory narrative; and
• processing times for each sector, including a comparison as to average calendar days in 2023, 2024 and 2025.

This chapter also sets out a list of “characteristics”, that the Central Bank has observed, lead to an efficient authorisation journey, for example, transparent, early and meaningful engagement with the Central Bank / good culture, vision, values and strong “tone from the top” / not making fundamental changes to the business model mid-stream / evidence of strong consumer protection measures / an emphasis on safeguarding client assets, if relevant.

Some points to note, in terms of authorisations in 2025, include:

• in the MiFID sector, the Report shows that the authorisation pipeline for 2026 is strong, with seven firms at the assessment phase and ten at the preliminary engagement stage;
• the retail intermediary authorisation continues to be a high-volume sector, with turnaround times set to decrease even more in 2026 due to the situation that A-Form applications are now a fully online process only – for more information, see FIG Top 5 at 5 dated 26 February 2026;
• the payment institutions and electronic money institutions sector continues to be a growing area with four firms authorised in 2025 bringing the total to 58 with approximately €11.87 billion of safeguarded funds;
• in the crypto asset service providers sector, it was noted that there can be elevated consumer protection, client asset safeguarding, market integrity and financial crime risks; and
• within the Markets in Crypto-Assets Regulation framework, 305 whitepapers were notified to the Central Bank in 2025, with the Report emphasising that the Central Bank does not authorise or approve the products.

Fitness and Probity

Chapter 5 of the Report contains an overview of the Central Bank’s fitness and probity (“F&P”) gatekeeping process as regards the assessment of pre approval controlled function (“PCF”) applications, highlighting that the area underwent significant transformation in 2025 on foot of the Enria Review, particularly with the establishment of the dedicated F&P unit – for more information, see FIG Top 5 at 5 dated 9 January 2025.

The chapter sets out details as to the impact of incomplete applications, the main reasons for their return, the most common issues, how the Central Bank is addressing them and areas for enhancement in 2026.

Some of the matters highlighted in this chapter include the following:

• the four most common issues as to why incomplete applications are returned are: an invalid proposer / insufficient evidence of compliance with the minimum competency code / incorrect company structure selected / unnecessary legal attestation in PSD2 and crowdfunding documentation. This information is included by way of a “Spotlight” on the decrease in the number of incomplete applications;
• the highest number of applications, at 21%, were received for the role of non-executive director;
• in terms of improvements, the Report highlights the Central Bank’s plans to simplify and improve the “user experience and efficiency of our processes”, including continuation of work related to the review of the PCF list with proposed changes expected to be communicated later this year;
• 64% of the total PCF applications received related to two sectors, funds and fund service providers, and retail intermediaries. Insurance applications decreased from 15% in 2024 to 11% in 2025; and
• the F&P unit carried 26 interviews in 2025, compared to 47 in 2024 due to changes introduced after the Enria Review and also because of the use of other tools such as additional information requests to firms for underlying due diligence.

Coinciding with the publication of the Report, the Central Bank also published its Fitness and Probity Review – 2026 Report on Implementation of Recommendations – see update below, for further information.

On 11 June 2026, Deputy Governor, Financial Regulation at the Central Bank of Ireland (“Central Bank”), Mary-Elizabeth McMunn, delivered a speech (“Speech”) at a Financial Services Ireland event. The Speech centred around the unprecedented scale and pace of change that we find ourselves in, including international fragmentation and rapid technological transformation.

The Deputy Governor anchored her Speech in the statement that a strong and well run sector that is operating in a well regulated and robust environment provides an important foundation for firms as they respond to “increasingly complex and challenging world in 2026 and beyond.” She went on to highlight that there are also opportunities for financial services in the midst of these changes, not just risks.

International responsibilities

Acknowledging the international aspect of financial services in Ireland, the Deputy Governor pointed to the Central Bank’s commitment to international engagement, standards, cooperation and, importantly, making sure the sector is resilient. She emphasised the interconnected nature of the global economy and the financial system, describing it as “the primary context in which we continue to operate.”

Convergence

The Deputy Governor also discussed convergence, stating that firms should advocate for, and practice, convergence – advising taking a long term view and applying the best standards internationally, rather than the lowest standards locally.

Expectations of firms that form part of international groups

Ms McMunn discussed the expectations of the Central Bank, particularly in the context of firms that are part of wider international groups. She acknowledged the benefits that come from being part of one of these groups but emphasised the importance of subsidiaries, that are based in Ireland, being part of a well regulated, stable system, subject to high standards and risk-based supervision, stating that it sets firms up for sustainable success.  Some other points, made by the Deputy Governor on this matter, are as follows:

• firms must ensure that the local entity is substantive and sufficiently independent, being resilient from a financial and operational perspective and also in terms of governance and risk management;
• firms should take advantage of their access to global networks and intelligence, especially when it comes to technological change, using this to the benefit of consumers and the economy; and
• leveraging group resources should not occur in such a way that the independence of the local board is compromised, underscoring the importance of “robust boards demonstrating both autonomy and responsibility, understanding and expertise.”

Regulating and supervising well

Deputy Governor McMunn then moved on to discuss robust, effective and efficient supervision – the components of regulating and supervising well. In that regard, some of the areas she covered are as follows:

• the Central Bank’s revised integrated supervisory approach, highlighting the incorporation of European and international supervisory responsibilities;
• gatekeeping – announcing the publication of the Central Bank’s third edition of its Authorisations and Gatekeeping Report (“Report”), discussed in the update, above. Having shared some statistics from the Report, she discussed why gatekeeping is so important – citing the role it plays in contributing to the Central Bank’s safeguarding outcomes. Ms McMunn also restated the Central Bank’s approach to authorisations in that it is: risk-based, proportionate, outcomes focused and robust. In addition to these factors, she highlighted the focus, in recent years, on efficiency – stating that in it is in that context that the Central Bank has endeavoured to enhance its gatekeeping process so that it is clearer, more transparent, more efficient and more predictable; and
• the publication of its Fitness and Probity Review – 2026 Report on Implementation of Recommendations (“F&P Report”), discussed in the update, below. Ms McMunn highlighted some of the achievements set out in the F&P Report.

Future focus

While discussing gatekeeping, the Deputy Governor took the opportunity to highlight three areas of work for the future:

• • the centralisation of the Central Bank’s broader gatekeeping functions to make it more effective, while bringing greater, clarity, consistency and efficiency to this work. This was set out in the Central Bank’s simplification roadmap – for more information, see FIG Top 5 at 5 dated 11 December 2025;
  • investment in, and improvement of, technology, including AI and automation; and
  • a continued focus on deepening an understanding of innovation in the financial sector.

Simplification and update on 2025 roadmap

The Deputy Governor reflected on a speech she delivered last year where she set out her thoughts on simplification – for more information, see FIG Top 5 at 5 dated 11 April 2025. She them went on to highlight where the Central Bank has actively looked for areas to simplify and where it has engaged with stakeholders, some of the matters she addressed are as follows:

• open engagement with stakeholders and consideration of the Central Bank’s frameworks;
• a continued embedding of the new supervisory approach; and
• a broadening and enhancement of evidence-based policy making, incorporating this into the regulatory approach.

Staying on the topic of simplification, the Deputy Governor gave an update on the Central Bank’s December 2025 simplification roadmap, some of the matters she highlighted are as follows:

• the Central Bank’s provision of more detail as to annual supervisory plans – as evidenced in the 2026 Regulatory and Supervisory Outlook Report – for more information, see FIG Top 5 at 5 dated 5 March 2026;
• the completion of a review on the Central Bank’s Cross-Industry Guidance on Outsourcing with the result that the Central Bank has decided to remove the current guidance and replace it – flagging that there will be sector engagement on the new guidance later in the year;
• streamlining new data requests and engaging in a comprehensive review of data collections, flagging that some candidate reports for retirement / consolidation have already been identified – this will be progressed in the second half of 2026;
• as regards the compatibility review of more than 50 domestic instruments in the insurance sector, the Deputy Governor stated that areas affected by the Solvency II reforms have been prioritised. She confirmed that the Central Bank will engage with the insurance sector regarding proposed changes, including a hybrid event for the (re)insurance industry on the Solvency II Review and Insurance Recovery and Resolution Directve that was held on 16 June 2026 to provide insight into what is changing and how to prepare for compliance from January 2027. The slides from the event are available to view here. Some points worth noting include:

• • the Central Bank will offer a pre-application assessment phase for firms that intend to apply for non- small and non-complex undertakings (“SNCU”) proportionality measures to help firms prepare for submitting a formal application in 2027. The pre-application window will be open from 1 -30 September 2026;
  • the Central Bank will publish a guide for firms intending to submit a pre-application in June, explaining how the process will work and provide a checklist of documents for inclusion in the submission;
  • the Central Bank plans to hold a webinar in July to answer questions firms may have on the pre-application process;
  • a technical workshop will be held in October 2026 on reporting changes;
  • it is planned to publicly consult on changes to the Domestic Actuarial Regime in Q3 2026;
  • the Central Bank has stated that it is open to early engagement with firms on technical applications under the revised Solvency II regime, for example, the Volatility Adjustment;
  • in January 2027, the Central Bank will publish revised Central Bank instruments, following its compatibility review and national transposition of the amended Solvency II Directive; and
  • as regards IRRD, key aspects were discussed, including recovery planning changes / new resolution requirements / the approach of the Central Bank on scope / IRRD funding arrangement. Details as to industry engagement were also set out – the Central Bank will commence informal bi-lateral firm engagement from Q3-Q4 2026, engaging with firms on initial considerations. Formal engagement will commence in H1 2027, following transposition.

• the development of a new regulatory impact assessment framework – to be published and consulted on over the coming weeks.

1. Central Bank publishes Fitness and Probity Review – 2026 Report on Implementation of Recommendations

 

On 10 June 2026, the Central Bank of Ireland (“Central Bank”) published its Fitness and Probity Review – 2026 Report on Implementation of Recommendations (“F&P Report”). The F&P Report provides an update regarding progress on the implementation of the recommendations contained in the fitness and probity (“F&P”) review (“Enria Report”) carried out by Mr Andrea Enria in 2024 – for more information, see FIG Top 5 at 5 dated 18 July 2024.

April 2025 review

The Central Bank published a similar implementation report in April 2025 – for more information, see FIG Top 5 at 5 dated 17 April 2025.

Complete

The F&P Report confirms that all 12 of the recommendations in the Enria Report have been successfully implemented, noting that although this will be the last such report, the Central Bank is committed to continuous improvement and will build on the progress it made as it worked on the contents of the Enria Report.

Progress

Some of the matters highlighted in the F&P Review, across the three key areas of review set out in the Enria Report, are as follows:

• guidance, that had been previously fragmented, has been streamlined into user friendly formats, redundant content has been removed, and the Central Bank’s website has been refreshed with improved navigation in mind;
• the publication of the enhanced F&P Standards Guidance, providing more certainty as regards the Central Bank’s expectations for those holding senior roles – for more information, see FIG Top 5 at 5 dated 27 November 2025;
• the establishment of the dedicated F&P unit – for more information, see FIG Top 5 at 5 dated 9 January 2025;
• the establishment of the Gatekeeping Decisions Committee (“GDC”), in March 2025, which provides senior leadership and independence in refusal decisions. The Authorisations and Gatekeeping Report, discussed above, also addresses the Committee highlighting that:

• • since March 2025, the GDC has received three referrals for decision – two proposed authorisation refusals and one proposed involuntary revocation. The GDC refused both authorisations and involuntarily revoked the authorisation of the firm in the other case. There have been no appeals to the Irish Financial Services Appeals Tribunal during the relevant period.
• the publication of the F&P Gatekeeping Process Manual – which sets out details as to what to expect during the assessment process – for more information, see FIG Top 5 at 5 dated 17 April 2025;
• the establishment of a complaints procedure for F&P assessments, including an independent third-party reviewer. So far, no F&P complaints have been made via this procedure; and
• as regards interviews, the Central Bank:

• • forwards detailed invitations to interview;
  • has committed to 90 minute interviews; and
  • provides feedback after interview and withdrawals.

Review of PCF roles

As mentioned in the update on the Authorisations and Gatekeeping Report, above, in 2026 the Central Bank will be focused on the review of its list of pre approval controlled function (“PCF”) roles and expects to communicate the proposed changes by the end of 2026.

Appendix

The F&P Report also contains an appendix that sets out details summarising the recommendations of the Enria Report and the implementation details.

 

2. Governor Makhlouf addresses regulation of financial sector during speech focused on monetary policy and economic outlook

 

On 16 June 2026, Governor of the Central Bank of Ireland (“Central Bank”), Gabriel Makhlouf, delivered a speech (“Speech”) focused on the context for the Governing Council of the European Central Bank’s decision to raise interest rates by 0.25% and on the implications of the energy price shock for the Irish economy. He also spent some time discussing Ireland’s Q1 2026 GDP figures.

However, towards the end of his Speech, the Governor took the opportunity to address the Central Bank’s approach to regulating the financial sector, highlighting that the “volatile and uncertain environment” that he considered when discussing economic developments, has direct implications for how regulation and supervision is approached.

RSO 2026

Governor Makhlouf pointed to the Central Bank’s Regulatory and Supervisory Report 2026 (“RSO”), where the priorities for the year ahead were set out. He restated the three themes that informed those priorities:

• building resilience to geopolitical risk and macro-financial uncertainty;
• protecting consumers and investors in a rapidly changing world; and
• responding to technology-driven transformation across the financial sector.

For more information, on the RSO, see FIG Top 5 at 5  dated 5 March 2026.

Simplification roadmap

The second area that the Governor singled out for mention was the Central Bank’s simplification roadmap – for more information, see FIG Top 5 at 5 dated 11 December 2025. He highlighted that work is progressing in this area, and echoing remarks made by Deputy Governor McMunn, discussed in the update above, flagged the upcoming consultation on a refreshed framework for how the Central Bank assess the impact of its regulatory decisions. The Governor explained that this is aimed at ensuring that the approach is evidence based and transparent – citing the importance of firms and consumers operating in a regulatory environment that is “a source of stability, clear, and proportionate and consistent in its approach to managing evolving risks.”

On 11 June 2026, the European Banking Authority (“EBA”) published a consultation (“Consultation”) on the draft methodology (“Methodology”), templates (“Templates”) and template guidance (“Guidance”) for the 2027 EU-wide stress test (“Stress Test”).

The Stress Test aims to provide supervisors, banks and other market participants with a common analytical framework to compare and assess the resilience of EU banks and the EU banking system to shocks, and also, to challenge the capital position of EU banks. The Stress Test will cover 75% of the EU banking sector, with 63 banks from the EU and Norway participating, including 47 from the euro area.

The Methodology sets out the common approach that defines how banks should calculate the stress impact of the of the common scenarios and sets constraints for their bottom-up calculations.

The Templates are to be used for the collection of data from banks relating to the Stress test.

The Guidance provides technical advice to the banks participating in the Stress Test as regards the population of the Templates.

Simplifications

The EBA explains that the 2027 Stress Test introduces simplification measures targeted at improving efficiency and risk sensitivity, while also preserving the robustness and comparability of the results. In that regard, data points have been reduced by 55% compared to previous EBA EU-wide stress tests. This has been achieved by using regular supervisory reporting – stress test definitions and previous stress test datapoints or templates, which would overlap with supervisory reporting, have either been simplified or removed.

Climate risk

For the first time, climate risk has been included in the Stress Test – consisting of the incorporation of transition and physical risks alongside macro-financial shocks. The EBA has stated that, for now, climate risks will be assessed through a dedicated module and will not affect the core stress test results.

Early publication

The EBA has published the draft package early so that stakeholders are in a position to better assess the combined impact of changes to the Methodology and the proposed revisions to Commission Implementing Regulation (EU) 2024/3117, which contains implementing technical standards on supervisory reporting – for more information, see FIG Top 5 at 5 dated 16 April 2026.

Next Steps

A closing date for responses has not been specified.

On 12 June 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) published its Annual Report for 2025 (“Report”). The Report details EIOPA’s activities over 2025 in the implementation of its mandate, setting out a comprehensive account of the outcomes achieved as regards its objectives, which were detailed in its Annual Work Programme for 2025.

The Report highlights that 2025 saw geopolitical instability, rapid advances in AI, more frequent and intense weather events, and the rise of cyber threats. Acknowledging the challenges presented by such matters, the Report sets out EIOPA’s achievements over the year, some of which are as follows:

Sustainable insurance and pensions

The Report states that sustainable finance has remained a “cornerstone of EIOPA’s strategic priorities”, going on to emphasise that EIOPA is committed to integrating sustainability risks into the risk management practices of (re)insurers and institutions for occupational retirement provision (“IORPs”).

• incorporating sustainability risks into supervisory activities and providing guidance on governance requirements and prudential treatment of sustainability risks;
• as regards natural catastrophe risks, EIOPA proposed calibration adjustments for flood, hail, earthquake, and windstorm risks within the Solvency II standard formula; and
• the promotion of forward-looking climate risk management, urging insurers to integrate climate considerations into strategic planning and capital assessment.

Supporting supervisors and insurers with digital transformation

• monitoring market innovations and digital developments, and raising awareness on the use of digital technologies;
• the publication of an opinion on AI governance and risk management – clarifying the application of existing insurance legislation to AI systems – for more information, see FIG Top 5 at 5 dated 21 August 2025; and
• contributing to the implementation of the Digital Operational Resilience Act (“DORA”) by establishing governance structures, joint oversight teams, and methodologies for oversight activities. EIOPA also commenced oversight activities, designating critical third-party service providers and engaging with them.

Supervision and oversight

• the Report highlights that EIOPA’s oversight activities aimed to ensure high quality and effective supervision, addressing both conduct and prudential matters, particularly in a cross border context;
• the publication of focus areas for 2026 – including digital operational resilience, sustainability risks, and solvency capital requirement calculation related to collective investment undertakings; and
• the Report also points to EIOPA’s focus on consumer protection targeted at improving transparency, fairness, and value for money in financial products.

Advice and policy work

• a focus on simplification and burden reduction, publishing a note on EIOPA’s views for better regulation and supervision – for more information, see FIG Top 5 at 5 dated 10 April 2026;
• implementation of the Solvency II review – developing and publishing various technical standards and guidelines;
• advancing the savings and investments union (“SIU”) agenda – highlighting that work focused on retail investment and smarter saving for retirement will support the SIU and also address pension gaps in the EU; and
• engagement with the co-legislators and the European Commission on the retail investment strategy and the framework for financial data access.

Financial stability and risks

The Report sets out that EIOPA has continued to monitor and assess risks and vulnerabilities that could negatively affect he European insurance and occupational pensions sectors, particularly highlighting the publication of EIOPA’s quarterly risk dashboards on insurers and IORPs, and half-yearly financial stability report.

The Report also addresses EIOPA’s work on the implementation of the Insurance Recovery and Resolution Directive, highlighting that EIOPA is currently drafting legal instruments to incorporate the anticipated framework changes, with a strong focus on simplification and reducing administrative burdens.