Welcome to the FIG Top 5 at 5

On 1 December 2025, the Central Bank of Ireland (“Central Bank”) published the latest edition of its Investment Firm and Intermediary Newsletter (“Newsletter”). The Newsletter covers topics of interest, significant work and regulatory issues that retail intermediary firms, MiFID firms and crowdfunding service providers need to be aware of.

Some key highlights from this edition include:

Intermediary Insights

• Review of retail intermediaries operating on the basis of a fair or limited analysis of the market

As set out in the May 2025 Investment Firm and Intermediary Newsletter, the Central Bank concluded its thematic review (”Review”) on whether retail intermediaries provide services to consumers on the basis of a “fair” or “limited” analysis of the market, as per the definition of these terms in Chapter 12 of the consumer protection code (“CPC”). The Newsletter refers to the Central Bank’s recent publication of the findings of the Review and contains a summary of those key findings – for more information, see FIG Top 5 at 5 dated 20 November 2025.

• Reporting requirement for IIA tied agency appointments 

The Newsletter refers to the recent confirmation from the Central Bank that firms proposing to enter into a tied agency arrangement under the Investment Intermediaries Act are no longer required to comply with the six month reporting rule. The Newsletter highlights the fact that firms must ensure that all other regulatory obligations in respect of tied agency appointments continue to be fully met.

• New approval process for sole traders transitioning to single director companies

The Newsletter details that the Central Bank is currently working on a streamlined authorisation process for sole traders proposing to become single director companies with further details on how to complete the new form and, the exact requirements for the new process, to be provided at a later date. This development was referred to by Director Gerry Cross in a recent speech where he addressed, amongst other matters, the Central Bank’s enhancement of its proportionate supervisory approach for intermediaries – for more information, see FIG Top 5 at 5 dated 20 November 2025.

• The Newsletter also contains a number of reminders in relation to various matters, some of which are as follows:
• from 1 January 2026, word-based application forms for ‘A Form’ applicants, will no longer be accepted and again, reminds interested parties that it will hold a webinar on this matter on 10 December 2025;
• a reminder as to the process to be followed for amendments to the register of investment product intermediaries; and
• firms are reminded to ensure their contact details remain up to date with the Central Bank at all times.

MiFID Insights

• MiFID Industry Event

The Newsletter contains details as to a MiFID industry event that was  held by the Central Bank on 1 July 2025, focused on the regulatory and supervisory outlook for 2025 and also addressing the Central Bank’s new supervisory framework and its impact on the investment firms sector.

The Newsletter highlights key risks for investment firms such as governance / risk management and culture / client assets / strategic risks and adapting to structural change / operational risks and resilience / conflicts of interest / financial resilience and financial integrity.

The Newsletter goes on to outline the Central Bank’s supervisory plans to address the forgoing risks by way of thematic reviews of investment firms’ compliance functions / operational resilience frameworks / fitness and probity practices / liquidity risk management. The Newsletter also sets out the Central Bank’s intention to carry out internal capital adequacy and risk assessment process assessments for category 1 and 2 investment firms in line with the firm’s supervisory review and evaluation process cycle.

Finally, the Newsletter highlights that the Central Bank is currently working on the next regulatory and supervisory outlook report, which will be published in February 2026.

• Operational Resilience Thematic Risk Assessment

The Newsletter reminds industry that enhancing operational resilience across the financial sector is a key priority for the Central Bank for 2025/2026, as set out in the February 2025 regulatory and supervisory outlook report – for more information, see FIG Top 5 at 5 dated 6 March 2025. As per that priority, the Newsletter details a recently conducted thematic assessment on operational resilience on a cohort of MiFID investment firms.

The overall results will be published soon by the Central Bank. Some of the matters highlighted in the Newsletter are as follows:

• many of the firms that were assessed could demonstrate that they had operational resilience frameworks that are largely in line with the principles set out in the Central Bank Cross Industry Guidance on Operational Resilience and that are broadly in line with supervisory expectations;
• in most cases, it was found that firms’ boards are ultimately responsible for operational resilience with delegation to appropriate committees of the board. Additionally, it was found that functional responsibility for operational resilience was at senior management level within firms;
• there has been a maturing of operational resilience frameworks across the MiFID investment firm sector as a whole. However, improvements are needed as regards some firms identifying their critical or important business services and mapping of how their critical or important business services are delivered; and
• MiFID investment firms, and their boards, are encouraged to revisit the Cross Industry Guidance on Operational Resilience, particularly ensuring that regard is had to the July 2025 updates – for more information, see FIG Top 5 at 5 dated 24 July 2025.

Central Bank Insights

Under this heading, the Newsletter addresses other relevant matters, some of which are as follows:

• an update on the Central Bank’s consultation paper on amendments to the fitness and probity regime (“CP160”), referring to the recent publication of the feedback statement and directing interested parties to the fitness and probity section of the Central Bank’s website in order to access the updated guidance on the standards of fitness and probity. For more information on the updated guidance, see FIG Top 5 at 5 dated 27 November 2025.

The Newsletter highlights that the Central Bank will hold a webinar on the revised guidance on 9 December 2025;

• an update on the implementation of the Individual Accountability Framework (“IAF”), highlighting that industry feedback in relation to the implementation of the framework has been consistently positive, with industry representatives acknowledging the benefits of the regime. Further, it is stated that the Central Bank has seen positive internal changes made in firms on foot of the IAF framework.

It is also highlighted that extending the senior executive accountability regime to non-executive directors, including to independent non-executive directors (“(I)NEDs”), requires firms to allocate applicable prescribed responsibilities to (I)NEDs, and to ensure that each (I)NED has a documented statement of responsibilities.

The Newsletter states the Central Bank is of the view that the expectations of (I)NEDs under the new framework are fully consistent with their existing responsibilities under the corporate governance framework and that the standards to be met relate purely to non-executive oversight functions and are limited to what should reasonably be expected of individuals in that context;

• an update on the recent IOSCO world investor week and the Central Bank’s involvement in that event;
• a feature on financial frauds and scams, including that Coimisiún na Meán has awarded ‘trusted flagger’ status to the Central Bank under the Digital Services Act;
• an update on the CPC 2025, reminding readers that it will take effect in March 2026, and referencing Deputy Governor Colm Kinkaid’s speech on the CPC and protecting consumers in vulnerable circumstances – for more information, see FIG Top 5 at 5 dated 6 November 2025. Some other matters highlighted include:
• in the lead up to March 2026, the topic of firms’ preparedness for the CPC implementation will be a part of ongoing supervisory engagements between the Central Bank and firms; and
• the discussions around the CPC at the recent retail intermediaries roadshow – for more information, see FIG Top 5 at 5 dated 27 November 2025.

On 1 December 2025, the Central Bank of Ireland (“Central Bank”) published its consumer research and analysis of retail investment participation in Ireland (“Report”).

The Report focuses on opportunities for Irish households to secure their long-term financial well-being and aims to establish a clearer understanding of the drivers of, and barriers to, retail investor participation in Ireland. In so doing, the Report sets out that it explores international examples of successful capital markets ecosystems.

The Report is comprised of six sections as follows:

1. Irish Household Wealth, Assets and Investments

This section looks at the Irish historical context and its influence on consumer attitudes to investment in capital markets, noting factors such as the rapid growth of the economy from the mid-1900s until the early 2000s and periods of financial instability and crisis. Some of the matters highlighted are as follows:

• the net wealth of Irish households has more than doubled in the last decade to €1,288 billion;
• in Ireland, 38% of financial assets are held in cash and deposits, which is above the EU average of 30%;
• Irish households hold just 2.3% of their financial assets in direct investments such as listed equity and debt securities, compared to the EU average of 7.5%;
• overall, Irish households have relatively high indirect exposure to capital markets through life insurance and pension products; and
• direct and indirect participation in capital markets is concentrated in households in the top 10% of the net wealth distribution.

2. Profile and Characteristics of Retail Investors

This section considers the profile of retail investors in Ireland, the types of investments made and also looks at some key characteristics that distinguish investors from non-investors. Some of the matters highlighted include:

• 36% of the Irish population report that they hold or own at least one investment product while 53% of the population report that they do not currently invest;
• investors are more likely to be male, aged between 35-54, be working, have higher gross household income, have a higher level of educational attainment and live in Greater Dublin;
• women are less likely to invest than men, with women only representing 34% of investors. The Report notes that this may reflect notable attitudinal differences between genders in relation to investing; and
• the Report found that the types of investments held are stocks and shares at 55% / Irish State savings products at 38% / crypto-assets at 30% / collectibles at 22%. Given the relatively high proportion of investors who hold crypto-assets, the Report contains further analysis on crypto-asset investment activity by way of a dedicated ‘spotlight’;

3. Attitudes and Behaviours towards Investment

Some key findings in this section include:

• investment participation is shaped and influenced by a complex interplay of factors and influences;
• identified barriers to investment were lack of financial resources / psychological barriers, including fear and lack of trust / issues around lack of knowledge and understanding about investment / lack of supports and advice;
• facilitating increased retail investor participation requires the necessary drivers to be in place and for identified barriers to be removed; and
• enabling retail participation requires the building of greater knowledge and understanding of the role investment can play in securing long-term financial wellbeing, through education to uplift financial literacy and by having accessible information, advice and support.

4. Key Factors for Success

This section considers the conditions that have led to Australia and Sweden having higher levels of retail participation, and also aims to identify key success factors and considers those factors in an Irish context. Some of the matters highlighted are as follows:

• consumers in both Australia and Sweden have been encouraged to invest rather than holding their savings in bank deposits through various public and private sector initiatives. Government initiatives, including mandatory pension schemes, have increased retail participation and contributed to broader awareness and understanding of investment products;
• tax incentivised savings schemes have helped to embed widespread awareness of investing as a means of achieving financial goals and ensuring long-term financial wellbeing;
• both Sweden and Australia have well-developed pension frameworks, comprised of both mandatory and voluntary elements, providing opportunities for pension holders to participate in investment decisions concerning their own pension funds;
• in Australia is there is a capital gains tax reduction of 50% for gains on assets held for more than 12 months;
• Australia and Sweden have robust investor protection frameworks focused on the resilience and stability of the financial system and protection of consumers;
• Australian investors can access information and guidance from multiple sources; and
• Sweden has one of the deepest capital markets in Europe, with more than 500 initial public offerings over the past ten years, demonstrating good availability and choice.

5. Irish Retail Investment Ecosystem

This section looks at the Irish retail investment ecosystem and considers whether the ‘key factors for success’ are evident and if there are gaps in an Irish context. Some of the matters highlighted include:

• there is a relatively broad range of products available in the Irish retail investment market, however, significant asset types, including investment funds, are not widely held by Irish retail investors;
• direct and indirect participation in capital markets is concentrated in wealthier households;
• Ireland does not currently have a tax incentivised investment savings account available to investors to help bridge the gap between savings and investment, and in this regard the Report refers to the European Commission recommendation for member states to apply simplified and advantageous tax treatments to savings and investment accounts;
• as regards availability and choice, the main providers of retail investment in Ireland are investment firms, retail intermediaries, insurance undertakings, credit institutions and fund managers. It was also noted that digitalisation is transforming investment products and how they are delivered which can offer benefit for consumers by enhancing availability and choice;
• investors access advice through multiple channels including, independent financial advisors (39%), friends / family working in the financial services sector (35%), brokers (27%) and bank managers / advisers (26%);
• the Report raises the question as to whether there is a gap in readily available independent advice in Ireland, particularly for less wealthy consumers with smaller amounts to invest;
• trust in the providers of investment products and services plays an important role in the decision to invest and can influence an individual’s willingness to engage in risk-taking activities, including investing in capital markets;
• low levels of financial literacy can act as a barrier to investment participation and in this regard the Report notes that the National Financial Literacy Strategy recognises that financial literacy helps provide savers with the knowledge they need to confidently connect their savings with investment opportunities.

6. Key Conclusions

This section summarises the findings of the Report, taking account of the forgoing five sections.

Welcoming the publication of the Report, Deputy Governor Colm Kincaid  stated that:

“A properly functioning financial market must reflect and serve the needs and preferences of all consumers and investors. This research provides a comprehensive society-wide insight into those needs and preferences which can inform public policy at an important juncture, as we look to improve access to capital markets for retail investors.

In particular the research shows that, as things stand, financial services is not effective in reaching the full population of potential investors. This means Irish households may not be getting the full benefit of what financial services could do to help them provide for their future.”

1. Deputy Director at the Central Bank, Colm Kinkaid, delivers speech on strengthening consumer protection and supervision in a digitalised world

On 28 November 2025, Colm Kinkaid, Deputy Governor, Consumer and Investor Protection at the Central Bank of Ireland (“Central Bank”) delivered a speech (“Speech”) at a joint FinCoNet and Central Bank seminar.

The Deputy Director’s Speech focused on financial consumer protection and he emphasised that cooperation in this area is more important than ever to solve problems that are “increasingly complex interconnected and transcend national borders.”

Recognising that digitalisation brings benefits to consumers, the Deputy Director highlighted the potential associated risks. He went on to point out that international standards have a role to play in this area, referencing:

• the G20 / OECD High Level Principles on Financial Consumer Protection, stating that they provide a roadmap for countries to improve existing approaches and develop new ones as regards digital transformation. The Deputy Director also took the opportunity to state again that the Central Bank is implementing the OECD’s recommendations on foot of its review of the Central Bank’s consumer protection supervisory functions – for more information, see FIG Top 5 at 5 dated 19 December 2024; and
• the fact that such standards, as those of the OECD, are implemented and supported by a mix of European and national initiatives, including the EU digital finance package, including the regulation on markets in crypto-assets. DORA and the AI Act, stating that these frameworks are targeted at responding effectively to emerging innovations and risk while supporting the potential consumer benefits.

The Deputy Director also drew attention to the entry into force of the revised Consumer Protection Code in March 2026, highlighting that it includes provisions to ensure that financial services providers are required to design and deploy technology in a way that is customer focused.

The Deputy Director also welcomed the working definition of ‘financial well-being’ published in the 2024 G20 policy note and stated that the Central Bank will support the work of the OECD working party on financial consumer protection, education and inclusion “to further develop and measure this concept.” In that regard, the Deputy Director also stated that there will be a joint meeting of that working party and FinCoNet to further develop thinking on this definition together with other aspects related to financial consumer protection, education and inclusion.

2. Deputy Governor Madouros at the Central bank delivers speech on macro-financial effects of climate change in Ireland

On 25 November 2025, Vasileios Madouros, Deputy Governor, Monetary and Financial Stability at the Central Bank of Ireland (“Central Bank”), delivered a speech (“Speech”) at the Climate Finance Week 2025. The Speech explored the macro-financial effects of climate change in Ireland.

Deputy Governor Madouros noted that the risks from climate change have intensified over the past 20 years, with regulators, including the Central Bank, making efforts to improve their understanding of the macro-financial effects of climate change.

The Deputy Governor included some detailed relevant statistics regarding climate change, more generally noting that:

• progress towards decarbonisation has been slower than intended by the Paris Agreement;
• rising temperatures, more frequent and severe weather events, and disruptions to communities, economies and financial systems remain pressing concerns;
• the Climate Change Advisory Council’s latest assessment shows that Ireland is not on track to meet its EU and national emissions reduction targets by 2030; and
• Ireland will exceed the carbon budget allocation for 2021-2025.

Deputy Governor Madouros highlighted the work of the  Network for Greening the Financial System (“NGFS”). The NGFS has developed a set of macroeconomic scenarios that assess the potential economic impacts of climate-related physical and transition risks. The Deputy Governor specifically emphasised the following insights from the NGFS’s work:

• the global macroeconomic costs of climate change are material;
• the NGFS scenarios show a stark increase as to the estimated impact of climate change on economic activity; and
• the macroeconomic costs of taking action to reduce greenhouse emissions are much smaller than the costs associated with inaction.

The Deputy Governor went on to note:

• the main impact on economic activity stems from physical risks;
• the transition to climate neutrality will require additional investment;
• the exposure to rising physical risks requires adaptation investment – noting that the main source of physical risk for Ireland stems from an increased likelihood of flooding, severe storms and rising sea levels and referring to the work of the Central Bank, in conjunction with the Office of Public Works (“OPW”), as regards a national dataset mapping every property in Ireland to current and future flood risks;
• analysis by the OPW shows a potential risk of a higher risk of underinsurance; and
• work by the Central Bank on the flood protection gap has shown that approximately 1 in 20 buildings already face difficulties accessing flood insurance, with the potential risk of uninsured losses increasing in tandem with the increase of flood risk – for more information, see FIG Top 5 at 5 dated 17 October 2024.

More to be done in the financial sector

Acknowleding that climate change poses risks for the financial system, Deputy Governor Madouros highlighted that one of the Central Bank’s key supervisory activities has been to strengthen the financial sector’s ability to manage climate related financial risks. He went on to point out that there has been meaningful progress, such as improvements regarding:

• governance around climate change and sustainable finance;
• the approach to monitoring of climate-related risks; and
• the deployment of scenario and stress testing analysis by regulated financial institutions.

However, the Deputy Governor did emphasise that there is more work to be done, giving the example that the Central Bank is still seeing inconsistencies across firms and sectors and also stating that risk management practices are not applied consistently across all relevant portfolios and exposures. Accordingly, he stated that the effective management of climate-related financial risks across the financial system remains one of the Central Bank’s key supervisory priorities.

No reduction in Central Bank’s focus on climate change 

The Deputy Governor was very clear in his messaging as to the priority afforded to climate change by the Central Bank, stating, in the context of questions as to whether the shifting geopolitical environment means the Central Bank is reducing its focus on climate change, that:

“The simple answer to that is no. We are staying the course. Our focus is – and has always been – on delivering our mandate, and we have been approaching climate change through that lens. If anything, further delays in climate change mitigation would mean that the macrofinancial risks from climate change would become more pressing.”

On 28 November 2025, the European Securities and Markets Authority (“ESMA”) issued a public statement (“Statement”) regarding technical specifications as to the implementation of  the following standards and format requirements under  the regulation on markets in crypto-assets (“MiCA”):

• the format of order book records for crypto asset service providers (“CASPs”) operating a trading platform for crypto-assets as defined by Commission Delegated Regulation (EU) 2025/416 (“Order-Book RTS”);
• the data standards requirements for all CASPs under Commission Delegated Regulation (EU) 2025/1140 as regards records to be kept of all crypto-asset services, activities, orders and transactions undertaken (“Record-Keeping RTS”);
• how CASPs operating a trading platform for crypto-assets are to present transparency data as defined by Commission Delegated Regulation (EU) 2025/417 (“Transparency RTS”);
• the format and data standards requirements for the MiCA white papers as defined by Commission Implementing Regulation (EU) 2024/2984 (“White Papers ITS”); and
• the data necessary for the classification of crypto-asset white papers as defined by Commission Delegated Regulation (EU) 2025/421 (“White Papers Classification RTS”).

The purpose of the Statement is to provide further practical guidance to market participants.

The Statement highlights that the requirements, set out above, are essential for ensuring transparency, facilitating market surveillance and for allowing for the comparability of information across crypto-asset market participants.

The Statement goes on to set out the legal background to each of the requirements listed above and also contains links to various related file formats / standardised messages.

The Statement also contains a reminder that the implementing technical standards as regards the form, format and templates to be used for the crypto-asset white papers will apply as of 23 December 2025 and includes an Excel-based example of an iXBRL white paper.

Finally, the Statement contains links with further information as to:

• the legal entity identifier;
• the  digital token identifier; and
• iXBRL

On 28 November 2025, the Eurosystem announced that it will launch a call for expressions of interest to invite European payment service providers (“PSPs”) to participate in a digital euro pilot (“Pilot”) in 2026. The Pilot will take place during the second half of 2027 and will run for 12 months.

This latest development follows the November 2025 decision of the European Central Bank’s (“ECB”) governing council to move to the next phase of the digital euro project which will see the advancement of its technical readiness and the launch of pilot exercises.

The Eurosystem describes the possible issuance of the digital euro as a major forward looking initiative that could shape the future of digital payments in Europe.

Scope

The Pilot activities are designed to validate the technical, functional and operational readiness of the digital euro with a selected number of PSPs, involving real world transactions in a controlled environment. A digital form of payment issued by the Eurosystem will be used, but will not have the status of legal tender.

Four use cases will be covered by the pilot as follows:

• online person-to-person (“P2P”) transactions using an alias or digital means of payment access number;
• offline P2P transactions with near-field communication (“NFC”);
• online person-to-business (“P2B”) transactions with NFC at software point of sale (“SoftPOS”); and
• online e and m-commerce transactions.

Selection of PSPs

PSPs will be selected based on a set of eligibility requirements and on a set of evaluation criteria, with the aim of covering all euro area countries and ensuring a good representation of PSPs operating in the euro area.

The number of selected PSPs will depend on several factors, including the total number of eligible applications received, the roles specified by the applying PSPs, and the use cases selected for the pilot.

Four phases

The Pilot will consist of four phases:

• assessment – PSP applications will be evaluated by the Eurosystem based on eligibility and weighted evaluation criteria;
• preparation – it is envisaged that the selected PSPs will receive additional and updated documentation aimed at helping them to make an informed decision as to participation in the Pilot;
• implementation – having completed the preparatory phase, selected PSPs will develop the system enhancements required in close cooperation with the Eurosystem; and
• execution – the PSPs’ tasks in the execution phase will include onboarding end users, operational transaction processing for defined use cases, and collecting feedback from end users.

Opportunity

The Eurosystem has stated that taking part in the Pilot is a “unique opportunity for PSPs to help shape the next generation of digital payments in Europe. Participating PSPs will gain first-hand experience of the technical specifications of the digital euro and will have the chance to provide feedback to the Eurosystem.”

Next Steps

As stated above, the call for expression of interest is due to take place in the first quarter of 2026. The Eurosystem has stated that it will hold online information sessions aimed at providing an opportunity to engage directly with the Eurosystem and to ask questions. Further details will be shared over the coming weeks.