Welcome to the FIG Top 5 at 5

1. Deputy Governor Colm Kincaid at the Central Bank of Ireland delivers speech on the role of financial intermediaries

 

On 19 June 2026, Deputy Governor of Consumer and Investor Protection at the Central Bank of Ireland (“Central Bank”), Colm Kincaid,  delivered a speech (“Speech”) focused on the role of financial intermediaries in Europe. While addressing that broader theme, he covered areas such as, the savings and investment union (“SIU”), retail participation, the new consumer protection code (“CPC 2025”), the Central Bank’s simplification agenda and its revised approach to supervision. The Deputy Director also took the opportunity to highlight a number of areas of supervisory focus, in terms of activity in 2026, that were previously identified in the Central Bank’s 2026 Regulatory and Supervisory Outlook Report (“RSO”).

Deputy Director Kincaid highlighted that the vast majority of firms that the Central Bank supervises are retail intermediaries, noting that this “extensive network” ensures that consumers have access to professional advice and the products and services that they need. He also emphasised the fact that retail intermediaries are in a significant position of “influence and responsibility”.  

Mr Kincaid also discussed the risks and challenges faced by consumers due to the digitalisation of consumer financial services, citing the rising level of online frauds and scams as well as digital exclusion. In such a context, the Deputy Director went on to explain, retail intermediaries have a key role to play in helping consumers navigate, what is, an increasingly complex landscape.

SIU and retail participation

Here, the Deputy Director noted the role to be played by intermediaries is supporting consumers’ participation in financial services, some of the matters he highlighted are as follows:

• the provisions in the CPC 2025 aimed at supporting mortgage and insurance switching; and
• the importance of the SIU when it comes to better mobilising Europe’s household savings, emphasising the Central Bank’s support for the SIU. In particular, he discussed investment accounts, expressing his approval of the discussion taking place through the SIU forum to develop a framework for a personal investment account in Ireland.

Regulatory framework and participation in capital markets

Deputy Director Kincaid emphasised the importance of the regulatory framework providing confidence to consumers, in terms of their protection, and being fit for purpose, if greater retail participation in capital markets is to be achieved. He noted the aim of the EU’s retail investment strategy in terms of achieving a “more coherent cross-sectoral framework” as regards retail investment products.

He also highlighted the CPC 2025 and the strengthening of requirements for firms, such as informing effectively / dealing with consumers in vulnerable circumstances, stating that it will be a “core concern of the Central Bank to see that the standards set are indeed met.”

Simplification and gatekeeping 

Emphasising the Central Bank’s commitment to making sure that the regulatory and supervisory framework is fit for purpose, the Deputy Director noted that one of the components of this is having a “simplification mindset.” In this regard, he highlighted:

• the Central Bank’s participation in national and EU measures to simplify regulation;
• the Central Bank’s own simplification roadmap, highlighting that standards will not be lowered but that the Central Bank is open to simpler ways of achieving their objectives – for more information on the roadmap, see FIG Top 5 at 5 dated 11 December 2025;
• the enhancement of gatekeeping by centralising functions, investing in technology and deepening the Central Bank’s understanding of innovation – for more information, see FIG Top 5 at 5 dated 18 June 2026; and
• his belief that firms can do more “to make their own product lines and service delivery simpler for users” – echoing similar comments he made earlier this month – for more information, see FIG Top 5 at 5 dated 11 June 2026.

Integration of supervision

Referencing the January 2025 launch of the Central Bank’s new approach to supervision, the Deputy Governor stated that the new approach has allowed for better risk-based insights and supported “a more joined-up view of firms, markets and consumers.”

Supervisory focus and thematic reviews

The Deputy Governor then proceeded to outline some of the areas that were flagged in the RSO as being of particular relevance to retail intermediaries, aimed at tackling issues having the greatest impact on consumers in their day to day lives – issues that are borne out by consumer complaints. He identified three areas, as follows:

• consumer experience and vulnerability – highlighting that the Central Bank will carry out a cross sectoral thematic review in 2026 which includes a focus on the customer support that firms, including retail intermediaries, have in place. Additionally, a review as to how  firms identify and treat customers in vulnerable circumstances will also be carried out;
• commissions and conflicts of interest – highlighting that the Central Bank will carry out a cross-sectoral review of certain intermediary commission arrangements aimed at understanding how they are designed and managed to secure consumers’ best interests; and
• unregulated financial activities – here, the Deputy Governor discussed the requirements under the CPC 2025 regarding unregulated financial activities aimed at ensuring that “regulated firms are unlikely to be able to offer, under the same or similar branding, unregulated things that resemble regulated things” – Mr Kincaid flagged that the Central Bank will soon commence a review to assess whether this new provision has been properly implemented.

 

2. Government convenes roundtable to discuss new investment account

 

On 22 June 2026, the Department of Finance (“Department”) published a press release (“Press Release”) announcing that the Tánaiste and Minister for Finance, Simon Harris TD, and Minister of State Robert Troy TD, had convened a consumer roundtable to discuss plans regarding a new investment account.

The Press Release highlights that a wide range of views was shared by participants as regards the challenges and opportunities presented by investing, including an emphasis on the importance of simplicity, trust, clear communication and financial literacy.

Speaking at the conclusion of the roundtable, Tánaiste, Simon Harris, stated:

“Ireland has a strong tradition of saving. Our ambition is to build on that by making investing simpler, more accessible and more relevant to ordinary households. We want more people to have the opportunity to grow their savings over the long term and share in the success of our economy.”

Next Steps 

The Press Release highlights that the Tánaiste intends to bring forward legislation, as regards the investment account, as part of the Finance Bill 2026. As the proposal is developed, there will be further engagement with consumers, industry and other stakeholders.

1. Central Bank of Ireland launches consultation on regulatory impact assessments and its approach to consultation

 

On 22 June 2026, the Central Bank of Ireland (“Central Bank”) launched a consultation (“Consultation”) on regulatory impact assessments (“RIA”) and its approach to consultation with stakeholders.

In a related press release, the Central Bank explains that the Consultation is part of its work related to delivering a more effective and efficient regulatory framework, citing the new supervisory approach, applicable since January 2025, and the December 2025 roadmap of regulatory initiatives, as further examples of such work.

The Consultation seeks feedback on:

• a draft statement of approach to RIA (“RIA Statement”); and
• a proposed updated approach to public consultation (“Consultation Approach”).

The Central Bank highlighted that these matters form part of its approach to developing, assessing and communicating regulatory interventions after appropriate engagement with stakeholders.

The Consultation describes the relationship between RIA and consultation as “interconnected elements of the Central Bank’s regulatory process.”

The Consultation highlights that it does not introduce new regulatory requirements or amend existing rules.

Statement of approach to RIA

The RIA Statement sets out how the Central Bank proposes to assess regulatory interventions, including identifying problems, considering options and evaluating potential impacts and aims to:

• support robust, evidence-based decision-making;
• ensure that regulatory interventions are proportionate;
• enhance transparency regarding how decisions are made;
• ensure that the perspectives of stakeholders impacted by the regulatory intervention are fully considered; and
• facilitate appropriate consideration of impacts, including on customers, market functioning and the wider financial system, in line with the Central Bank’s statutory framework.

Particularly, the RIA Statement is intended to apply in the context where the Central Bank introduces new obligations, materially amends existing requirements, or otherwise alters the regulatory framework in a way that may have significant effects.

Material guidance may come within the scope of the RIA Statement but it will not apply to non-binding regulatory tools used by the Central Bank, where those tools explain, clarify or support understanding of existing obligations and do not introduce new obligations or materially alter the regulatory framework.

The Consultation highlights that proportionality is central to the Central Bank’s approach to RIA, highlighting that a proportionate approach may consist of different levels of assessment.

Some further matters highlighted are as follows:

• the Consultation notes that RIA should clearly set out the problem to be addressed, noting that clear articulation supports the identification and assessment of appropriate policy options;
• RIA should take account of the baseline against which proposals are assessed, including the current position and a baseline scenario;
• RIA should consider alternative options where appropriate, including different forms or intensities of intervention and, where relevant, non-regulatory approaches; and
• RIA should include an assessment of the potential impacts of regulatory proposals.

The Consultation emphasises the Central Bank’s commitment to ensuring that RIA is carried out in a timely fashion and to appropriate communication.

Finally, it is highlighted that the RIA Statement is intended to evolve, informed by experience and stakeholder feedback.

Proposed consultation approach

The Consultation Approach, the Central Bank explains, reflects current practices and emerging thinking on how consultation can most effectively support policy development, highlighting that feedback will inform an update of its consultation policy, which will be published in due course.

The Consultation covers matters such as:

• the purpose of public consultation;
• circumstances in which the Central Bank consults, usually on regulatory proposals, where appropriate, having due regard to the nature, scale and potential impact of the proposal;
• the need for consultation design to be proportionate, accessible, relevant and supported by appropriate engagement;
• consultation periods and timing, noting that they will generally be 12 weeks, but subject to the nature, complexity and timing of the proposal; and
• publication of submissions and feedback statements.

Question for consultation

Section 5 of the Consultation sets out the questions on which the Central Bank is seeking feedback from stakeholders.

Next Steps

The Consultation is open for feedback until 30 September 2026. The Central Bank will consider all submissions received and will publish a feedback statement in due course.

The Central Bank has stated that it will publish a consultation policy on its website after the conclusion of the Consultation.

 

 2. Governor of the Central Bank of Ireland publishes blog on importance of good regulation

 

On 22 June 2026, the Governor of the Central Bank of Ireland (“Central Bank”), Gabriel Makhlouf, published a blog post (“Blog”) on the importance of regulation when it comes to delivering the safeguarding outcomes of the Central Bank.

The publication of the Blog coincided with the launch of the Central Bank’s consultation (“Consultation”) on regulatory impact assessments (“RIA”) and its approach to consultation with stakeholders, discussed in the update, above.

In the face of evolving markets, technology advancing, changing business models and consumer expectations, the Governor emphasised the importance of regulators adapting, alongside regulation itself, stating that “…it is essential that we evolve how we develop policy and how we make decisions.”

In that regard, the Governor referenced the Central Bank’s strategy where it set out “to transform regulation and supervision”, pointing to the Consultation as being a component of that ambition. Welcoming the publication of the Consultation, the Governor stated that:

“The consultation represents another milestone in delivering our ambitions and reflects our commitment to continuous improvement in how we develop, assess and implement regulatory policy. It is central to our work on making regulation clearer, more coherent and easier to navigate, while maintaining the protections and resilience that the financial system depends on. That work is not about lowering standards or weakening resilience. It is about ensuring that regulation remains effective, proportionate and responsive as circumstances evolve.”

Governor Makhlouf discussed the central role of evidence, analysis, engagement and judgement as regards the development of policy at the Central Bank, highlighting that the Consultation aims to “more fully deliver on this approach”. The combination of all of these elements supports good policymaking and ensures that decisions are made with the best available information to hand.

Some further matters raised by the Governor are as follows:

• institutions should be willing to challenge themselves, review their approaches and adapt as circumstances change; and
• assessment, consultation, implementation and review should all be seen as part of a continuous process of learning aimed at achieving better regulation via better decisions.

1. Governor of the Central Bank of Ireland delivers speech at annual macroprudential conference

 

On 22 June 2026, Governor of the Central Bank of Ireland (“Central Bank”) delivered a speech (“Speech”) at the 10^th annual macroprudential conference.

Reflecting on the past ten years, the Governor noted how much the financial system has changed but stated that the aim of macroprudential policy remains constant – “to protect society from the wider costs of financial instability.” He highlighted that Ireland’s experience illustrates that when the financial system fails, the consequences are far-reaching, affecting society as a whole. In that vein, the Governor went on to emphasise the importance of being proactive when it comes to building resilience, pointing to the introduction of Ireland’s macroprudential framework ten years ago in the wake of the financial crisis.

The measures, which include borrower-based measures / bank capital buffers / measures for non-bank finance, will not prevent every shock or try to prevent all risk-taking, but should, the Governor explained, reduce amplification effects and ensure that essential services can continue when shocks do occur.

Governor Makhlouf noted how the discipline of macroprudential policy has matured but cautioned that that should not lead to complacency – highlighting that frameworks must continue to evolve in tandem with the financial system.

Risk

The Governor emphasised the importance of being “able to see risks forming before they crystallise, while recognising the limits of our knowledge and the costs of acting under uncertainty.” In this regard, he noted that good data, sound models and effective supervision are needed to achieve this.

Staying on the topic of risk, the Governor noted that identifying risk is not just confined to individual institutions anymore, but rather, we are now in a world where risks move between banks and non-banks, across markets and jurisdictions, and between the traditional financial system and new forms of digital finance. He highlighted that macroprudential research is now focused more and more on this aspect.

Research

Continuing his discussion on research, the Governor highlighted how research is central to ensuring that financial system can adapt and innovate while remaining resilient. In that regard, some of the matters he highlighted are as follows:

• historical research can identify recurring patterns underlying apparently novel developments;
• conceptual work can identify risks before data is sufficient for precise measurement;
• policy evaluation can reveal whether measures are working as intended, where costs are arising and whether frameworks can be simplified without compromising resilience – here, the Governor also addressed the publication of the consultation on regulatory impact assessment and approach to consultation – see the update above for more information; and
• the Central Bank’s research exchange programme – stating that applications are currently open.

 

2. Central Bank of Ireland updates guide to voluntary revocations

 

In the second week of June 2026, the Central Bank of Ireland (“Central Bank”) published an updated version of its guide to voluntary revocations (“Guide”), effective as of 9 June 2026. This is the fourth version of the Guide – it was last updated in April 2025. The Guide sets out the process for voluntarily revoking a firm’s authorisation or registration.

The Guide has been updated to reflect that fact that the Consumer Protection Code 2025 (“CPC 2025”) is now in force. Accordingly, the requirement to provide consumers with a minimum of two months’ prior notice, to inform them that a firm will be revoking its authorisation(s) / registrations(s), in question 10, now refers to the CPC 2025.

Finally, page 2 of the Guide, which deals with the revocation form and highlights the importance of using the most recent version of it, has been amended to refer to the most recent version being that of November 2022 – the previous version of the Guide had referenced April 2025.

On 16 June 2026, the Central Bank of Ireland (“Central Bank”) published the slides (“Slides”) from an insurance industry event, that was held on the same date. The event sought to provide an overview of:

• the Solvency II changes and the implications for industry; and
• the insurance recovery and resolution directive (“IRRD”) and the implications for industry.

In addition, the Central Bank published guidance (“Guidance”) on a pre-application assessment phase for firms that intend to apply for non-small and non-complex undertakings (“SNCU”) proportionality measures – aimed at helping firms prepare for the submission of a formal application in 2027.

Solvency II changes

The Central Bank gave an overview of its supervisory priorities for 2026, highlighting that preparing for the Solvency II changes is one of its key priorities, noting that the changes, which will come into effect in January 2027, will:

• make the rules simpler and less burdensome for most firms without compromising resilience;
• maintain a robust supervisory framework with improved supervisory cooperation on cross-border business; and
• reduce capital requirements in some areas – this will improve EU competitiveness and is also aligned with the savings and investment objectives.

It was highlighted that firms need to complete preparations for the revised regime before the implementation date of 30 January 2027. Some statistics from the Central Bank’s industry survey on the Solvency II review were shared, which indicate that, in general firms are preparing well for the changes. For more information on the survey, see FIG Top 5 at 5 dated 19 March 2026.

In terms of supporting industry implementation, the Central Bank highlighted the following:

• as referenced above, the Central Bank will offer a pre-application assessment phase for firms that intend to apply for non-SNCU proportionality measures – this will open on 1 September 2026.

The Guidance, referenced above, is aimed at firms intending to submit a pre-application for non-SNCU proportionality measures. It sets out how the process will work and also provides a checklist of documents for inclusion in the submission. In addition, the pre-application process will help the Central Bank to form an initial view as to how prepared the requesting undertaking is to submit a formal application for the use of any, or all, of the proportionality measures. The Guidance highlights that formal applications can only be submitted, and the new proportionality measures can only be used, once the transposing legislation comes into effect and the formal application has been approved by the Central Bank.

The Central Bank has stated its intention to hold a webinar in July to answer questions as regards the pre-application process;

• the Central Bank will be open for early engagement as regards technical applications, such as, volatility and matching adjustments;
• there will be further engagement throughout 2026 by way of events and relevant publications, in addition to the usual engagement with firms; and
• the compatibility review of domestic requirements and guidance, which was flagged in the December 2025 simplification roadmap, is underway. Once the review is complete, the amended material will replace existing guidance from 30 January 2027. The Central Bank has stated that substantive changes are proposed as regards the domestic actuarial regime (“DAR”) and related guidance and the guidance on completing and submitting (re)insurance authorisation applications 2025.

Next Steps and engagement

The Central Bank plans to:

• publicly consult on changes to the DAR in Q3 2026;
• hold a technical workshop on reporting changes in October 2026; and
• engage early with firms on technical applications under the revised Solvency II regime in Q4 2026.

In terms of the transition to the revised regulatory regime, the Central Bank has set out the following relevant dates:

• publication, in January 2027, of revised Central Bank instruments, following the compatibility review;
• national transposition of the amended Solvency II directive in January 2027;
• from 30 January 2027, the Central Bank will accept notifications for SNCU classification, applications for non-SNCU proportionality measures and other applications in the amending directive; and
• mid-2027 is indicated as the expected implementation date of the revised DAR and related guidance.

IRRD

The second part of the event covered the IRRD, where the Central Bank gave an introduction to IRRD, highlighting it a framework aimed at managing failing insurance undertakings, ensuring financial stability and protecting policyholders, via its two pillars – recovery planning and resolution planning. It was also stated that the Central Bank expects to be designated as the resolution authority for (re)insurers.

The motivations for, and objectives of, the IRRD were also discussed, which included matters such as incorporating learnings from the 2008 financial crisis and addressing a lack of harmonisation.

As regards the recovery planning framework, some of the matters highlighted are as follows:

• Ireland does not intend to require any rules in addition to the requirements in IRRD, taking a proportionate approach;
• existing recovery plan requirements will be revoked to coincide with the coming into force of national measures transposing IRRD;
• under IRRD, supervisors shall assess the credibility and feasibility of recovery plans and will have powers to require undertakings to address material deficiencies; and
• the Central Bank will engage with group supervisors as regards assessing group plans that include a subsidiary based in Ireland.

The Central Bank also gave an overview of the main differences compared to the existing regime, highlighting the key change as being that not all firms will be subject to mandatory recovery planning requirements. There is currently a requirement for full market coverage, whereas under IRRD, the requirement is minimum 60% market coverage for recovery planning.

An overview of the resolution planning framework was also provided, with it being emphasised that:

• the resolution authority leads resolution planning, but firms are essential partners;
• the aim is to ensure that policyholders are protected; and
• requirements are tailored to each firm’s profile, with a simplified obligations regime for smaller or less complex entities targeted at ensuring proportionality.

The Central Bank also covered resolution objectives and principles, particularly focusing on the public interest assessment and critical functions.

The primary resolution tools in IRRD were also discussed, including:

• write-down and conversion tool (bail-in);
• solvent run-off;
• sale of business;
• bridge undertaking; and
• asset and liability separation tool.

The Central Bank described what it means to be a resolution candidate, covering matters such as, the resolution planning cycle / data readiness and reporting / critical function identification / resolvability assessments / dedicated governance and engagement / cross-border group coordination.

Details as to the “pathway to failure” were also set out starting at “business as usual” and culminating in a position where the firm is “failing or likely to fail”.

The approach of the Central Bank as to scope was also discussed with it being highlighted that the Central Bank is developing its scoping methodology to determine firms in-scope of both recovery and resolution planning. The Central Bank will engage directly with in-scope firms to provide guidance on recovery and resolution planning requirements – anticipating that this engagement will informally commence in Q3-Q4 2026. The list of in-scope firms will be kept under review.

An overview of the selection criteria was provided, addressing market coverage requirements / common criteria for identifying in-scope firms / additional criteria being considered to determine scope.

Finally, the arrangements as to resolution funding were discussed, where it was highlighted that the establishment of a financing arrangement for the resolution of (re)insurers is now mandatory for EU member states to cover no creditor worse off costs with a member state discretion to also use the fund to cover costs associated with the use of resolution tools. In this regard, it was noted that the Department of Finance consulted on the transposition of IRRD – for more information, see FIG Top 5 at 5 dated 17 July 2025.

Next Steps and engagement

The Central Bank set out the following as regards industry engagement on recovery and resolution planning:

• from Q3-Q4 2026, the Central Bank will engage informally with firms on initial considerations. Formal engagement will commence post-transposition in H1 2027;
• the Central Bank will engage with firms on requirements arising from the taxonomy and implementing technical standards for insurance resolution reporting, either by way of a webinar or a workshop in Q4 2026 – however, this timeline is dependent on agreement of the EIOPA taxonomy. The Central Bank plans to contact firms, that are potentially in-scope of resolution planning requirements, on reporting obligations in Q4 2026; and
• engagement with firms on the outcome of decisions around resolution funding arrangements will be communicated in due course.

1. EBA publishes final report on ITS on disclosures on ESG risks, equity exposures and the aggregate exposure to shadow banking entities

 

On 22 June 2026, the European Banking Authority (“EBA”) published a final report (“Report”) on draft implementing technical standards (“ITS”), amending commission implementing regulation (EU) 2024/3172, regarding disclosures on ESG risks, equity exposures and the aggregate exposure to shadow banking entities, under the capital requirements regulation (“CRR3”).

The EBA consulted on the ITS in May 2025 – for more information, see FIG Top 5 at 5 dated 5 June 2025.

The Report highlights that:

• the amending ITS extends the scope of institutions required to disclose ESG information to large non-listed and other institutions, small and non-complex credit institutions and large subsidiaries;
• the EBA has taken a proportionate and streamlined approach to ESG disclosures;
• as noted above, the ITS also cover new requirements regarding exposure to shadow banking exposure and amendments to disclosure requirements on equity exposures, and, in that regard, proportionality and simplification have been incorporated into the ITS; and
• it is confirmed that the guidelines on non-performing and forborne exposures will be repealed. There are also other minor adjustments to instructions and templates, to reflect the answers to questions from industry.

Templates

The EBA has advised that the instructions to templates included in the final draft ITS will not be published in the official journal of the European Union (“OJEU”) but will be part of the binding package as ITS-related IT solutions published on the EBA’s website. This approach is aimed at easier operationalisation of the ITS.

The disclosures should be provided in accordance with these instructions, which will be available in all languages. The instructions will be directly applicable in all member states as part of the ITS once the ITS are adopted by the European Commission (“Commission”) and published in the OJEU.

Next Steps

The draft implementing regulation containing the ITS states that it will enter into force 20 days after publication in the OJEU and will apply from 1 December 2026.

The EBA will submit the final draft ITS to the Commission. It will also provide an updated mapping tool with supervisory reporting during 2026.

 

2. ESMA publishes statement on orderly winding down and safeguarding of client interests as end of MiCA transitional period approaches

 

On 23 June 2026, the European Securities and Markets Authority (“ESMA”) published a statement (“Statement”) calling on unauthorised crypto asset service providers (“CASPs”) to wind down in an orderly manner, while ensuring that they safeguard the interests of clients, as 1 July 2026 approaches – being the end of the transitional period under the markets in crypto assets regulation (“MiCA”).

The Statement aims to set out ESMA’s expectations for winding down and for investor protection. The Statement highlights that, while many CASPs will be authorised by 1 July 2026, other entities may not have such authorisation by that date and in that regard, calls on such entities to:

• immediately stop onboarding new EU clients, refrain from opening new client relationships or accounts, and cease marketing activities and solicitation;
• limit the provision of services to those actions necessary to sell or transfer crypto assets, reallocate assets, or close positions. Custody of clients’ crypto assets can only continue for the period necessary to effect an orderly exit;
• communicate clearly, promptly and repeatedly with all clients about the measures taken to safeguard their assets and the wind-down plans. Clients should know the timeline to dispose of, transfer, reallocate or close their positions. Communications should include a deadline by which any residual positions will be closed automatically, as well as information about client protection requirements;
• wind-down arrangements should be in compliance with all relevant EU or national conduct laws and AML / CFT obligations including customer due diligence measures / transaction monitoring / screening against restrictive measures and sanctions lists / suspicious transaction and activity reporting / record-keeping requirements / compliance with transfer of funds and crypto asset transfer traceability obligations; and
• in the event that clients are transferred to a MiCA authorised CASP, the onboarding CASP must carry out all required onboarding procedures.

CASPs established outside EU

The Statement also reminds CASPs established outside the EU that they may not provide MiCA services to EU clients or solicit EU clients, including in a business-to-business context.

Consumer warning

The Statement highlights that clients of unauthorised CASPs, whether EU or non-EU entities, do not have the protection of MiCA, including protections as regards client assets. ESMA has stated that clients using crypto asset services in the EU should verify their provider’s MiCA authorisation via the ESMA register.