On 30 April 2025, Governor of the Central Bank of Ireland (“Central Bank”), Gabriel Makhlouf, delivered a speech (“Speech”) at a Dublin Chamber event. The theme of the Speech centred around recent global developments and their potential impact on the economic outlook, followed by a consideration as to how Ireland and Europe should respond in an economic sense. 

The Governor noted the high volume of announcements and policy changes, including the imposition, removal and pausing of tariffs, emanating from the US Administration. He further noted the increase in policy uncertainty and the challenges to the multilateral institutional framework that “has underpinned global economic relationships for much of the last 80 years.”

Governor Makhlouf referred to reports published by the IMF, specifically the following matters:

• imposition of the announced tariffs and other trade barriers will have a significant negative effect on the global growth outlook;
• policy uncertainty is affecting the growth outlook and slowing consumer spending and business investment;
• the prospect of worsening trade tensions, higher public and private debt levels and complex interconnections within the financial system, could amplify negative shocks; and
• matters could improve quickly if countries took a more cooperative approach regarding issues underpinning their trading relationships.

Governor Makhlouf stated that:

“…we in Europe need to articulate a clear perspective on the benefits being foregone when trading partners adopt more protectionist stances.  We also need to work with trading partners to inform a clear approach to address the underlying drivers that motivate those protectionist stances. And, we need to invest more in working with new trading partners who also believe in the benefits of barrier-free trade.”  

A Macro Perspective

The Governor went on to consider matters from a macro perspective, specifically as regards the apparent aim of the US Administration to reduce or eliminate persistent US trade deficits. Developing that thought, some of the matters discussed by the Governor included:

• the effect of large trade surpluses, particularly more sustainable approaches for addressing them;
• the key drivers of protectionism, particularly focusing on the different income, wealth and opportunity experiences within countries that have resulted due to greater openness to trade and investment;
• the need to maintain supply chain security for critical good and services, reiterating the need for resilience in economies in order to withstand shocks to their flow. The Governor further highlighted the need for the adoption of the digital euro and a wholesale central bank digital currency as a European owned universal digital payment system.

Impact on Ireland

The Governor then moved to consider the potential impact on Ireland of a more fragmented trade and investment dynamic between the EU and the US, noting its effect as considerable, particularly taking into account the large number of US owned multinational enterprises operating here, with much of our exports intrinsically linked to US investment and the inflow of US services. Some of the potential consequences noted by the Governor included:

• a reduction in the public finances, given that corporation tax accounts for a quarter of all tax revenue; and
• less investment and activity in Ireland.

In this context, the Governor reiterated his previously stated key priorities for Irish economic policy, as set out in his letter to the Minister for Finance in February this year, noting that progress across those priorities would increase productivity in Ireland.

Opportunities

Governor Makhlouf also discussed the potential opportunities that might arise, maintaining that “…policymakers should use this transition to look for opportunities and ensure that the economic impact of any tariff measures are lessened. I do believe that there is opportunity for both Ireland and the EU in this transition.”

To identify and avail of potential opportunities, the Governor highlighted a number of actions that should be pursued, such as:

• examine where supply constraints can  be removed, and consider where redirected demand can be used to stimulate domestic markets;
• policies that seek to boost productivity and innovation should be pursued; and
• the completion of the EU single market, including the single banking union and the savings and investment union;

The Governor highlighted the need for mobilising private savings across the EU, unlocking the €11.5 trillion held by Europeans in deposits and cash and channelling it to drive European innovation. Finally, as regards opportunities, the Governor emphasised the need to be ready to work with new trading partners with similar approaches. 

On 7 May 2025, Director of the Horizontal Supervision Directorate at the Central Bank of Ireland (“Central Bank”), Patricia Dunne delivered a speech (“Speech”) at the European anti-financial crime summit 2025. The theme of the speech centred around anti-money laundering (“AML”) and innovation and the associated opportunities and challenges. 

Director Dunne noted the way in which technological developments have reshaped financial services, both in the way they are delivered and the manner in which consumers engage with them. She highlighted the fact that technology has brought many benefits and advantages across the financial system, citing speed and connectivity as enabling more convenience and ease of payments together with access to services. However, in this context, Director Dunne also noted the potential for risks, particularly when technological advancements are abused by those with harmful intentions.

Supervision and Regulation

Pointing to generative AI as one of the new technologies shaping financial services, the Director emphasised the importance of regulators, firms and the wider financial system, adapting to and keeping pace with such new technologies. She highlighted the need to increase the focus on identification of risks and their mitigation.

The Director then went to state that this was one of the motivating factors in the Central Bank’s new approach to supervision and regulation, with a view to a more integrated approach to supervision such that the Central Bank would be well positioned to deal with increasingly complex risks.  For more information on this, see FIG Top 5 at 5 dated 8 August 2024 and FIG Top 5 at 5 dated 6 March 2025.

Innovation and AML

Director Dunne highlighted that it is not the Central Bank’s role to eliminate risks or to hamper innovation. Rather, she stated that the Central Bank is supportive of the use of SupTech and RegTech where it can increase effectiveness, once it is used and implemented in a responsible manner.

The Director went on to note the potential for such technologies to make AML / CFT measures efficient, cheaper and more effective. However, she cautioned that such solutions must be proportionate and ensure financial inclusion. Additionally, she noted, the use of such technologies must be compatible with international standards of data protection, privacy, and cybersecurity. The Director highlighted the continued need for human input and manual checks alongside the use of new technologies.

Innovation Sandbox

The Director then gave an update on the Central Bank’s innovation sandbox programme (“Programme”), highlighting its theme of “Combatting Financial Crime”. For more information, see FIG Top 5 at 5 dated 6 June 2024,  FIG Top 5 at 5 dated 3 October 2024 and FIG Top 5 at 5 dated 23 January 2025.

She highlighted a number of matters that are being considered over the course of the Programme, as follows:

• what technological solutions can deliver positive outcomes for consumers and firms by supporting them in combatting financial crime and fraud;
• how can technology be better deployed to detect patterns or other indicators of consumer behaviour that may indicate financial crime;
• the impacts of the changing trends and emerging technologies in financial crime on the regulatory framework; and
• to what extent do current frameworks enable or hinder the use of technology to combat financial crime.

She stated that there is a showcase planned for June this year where participants in the Programme will present their innovative solutions, the progress made, share learnings, and highlight innovative outcomes developed through the programme. Further, the Director stated that the Central Bank will share the final outcomes and findings of the Programme, which it hopes will further strengthen and enhance the effectiveness of AML / CFT systems.

Conclusion

The Director reiterated the importance of innovation but, in that context, took the opportunity to underline the importance of the role of senior management, good governance and effective risk management frameworks within firms that deliver for consumers and investors. 

1. Central Bank updates DORA communications and publications page on RoI

On 28 April 2025, the Central Bank of Ireland (“Central Bank”) updated its dedicated DORA communications and publications webpage.

This particular update (“Update”) addresses the correction of validation issues identified by the European Banking Authority (“EBA”). The Central Bank explains that as part of the transmission, by the Central Bank, of the registers of information (“RoI”) to the European Supervisory Authorities (“ESAs”), the ESAs are carrying out additional validation checks on the uploaded RoI.

Communication

The Central Bank has stated that it will communicate the results of these validation checks to firms by way of secure message on the Central Bank portal. Links to the relevant EBA guidance will also be included and firms are advised to reference such guidance so as to address the issues identified.

How to Guide

The Central Bank has also updated its system how to guide with links to relevant EBA guidance which includes some common errors noted by the EBA during testing carried out by the EBA.

Next Steps

Firms are advised that there may be several rounds of corrections. The Central Bank has requested that firms remediate any feedback errors received and resubmit the RoI as soon as possible, bearing in mind that all corrections and resubmissions are required to be completed before 30 May 2025.

2. Central Bank publishes NCID report  for mid-year private motor premium data 2024

On 7 May 2025, the Central Bank of Ireland (“Central Bank”) published its mid-year private motor insurance data report (“Report”) of the National Claims Information Database (“NCID”). The Report is based on data up to and including the first half of 2024 – 1 January to 30 June 2024 (“H1 2024”).

The Report sets out key findings and emerging trends regarding premiums. An included data annex provides an update to the underlying data. A number of appendices contain supporting documentation, market coverage and a list of participating insurers.

Some of the key findings of the Report are as follows:

• the average written premium increased by 9% in H1 2024 when compared to 2023. The Report notes that the average written premium reflects premium trends faster than the average earned premium;
• since the second half of 2022, the average written premium has increased by 12% to €616 in H1 2024;
• the proportion of policies providing comprehensive cover increased by 1% in H1 2024, to 93% of all policies, up from 80% in 2009; and
• the average earned premium increased by 4% in HI 2024 compared to 2023 with the average earned premium now 18% lower than its highest point in 2018;
  

3. Central Bank updates implementation notice for competent authority discretions in CRR and CRD

On 1 May 2025, the Central Bank of Ireland (“Central Bank”) updated its Implementation Notice (“Notice”) for competent authority discretions in the capital requirements regulation (“CRR”) and the capital requirements directive (“CRD IV”).

The Notice outlines the Central Bank’s requirements and guidance regarding the implementation of certain competent authority options and discretions arising under:

• the European Union (Capital Requirements) Regulations 2014, transposing CRD IV;
• CRR; and
• The liquidity coverage requirement regulation.

The updated Notice has been amended to include revised guidance and template agreement for capital contributions. These matters are addressed, particularly, in paragraphs 1.7 and 3.8 of the Notice. 

On 2 May 2025, the Financial Services and Pensions Ombudsman (“FSPO”) launched its strategic plan for 2025 – 2027 (“Plan”). This is the third strategic plan since the FSPO was established in 2018 and this Plan is focused on delivering for customers.

The FSPO has stated that the Plan reflects the FSPO’s current strategic challenges and the evolution of the office of the FSPO, particularly as regards the increase in the amount of complaints received, together with an increase in the complexity of complaints. The Plan has also taken account of consultation feedback  received from customers and stakeholders. 

The FSPO anticipates that complaints may increase even more, both in number and complexity, owing to a number of factors such as:

• a challenging and uncertain international and policy context;
• the development of new regulatory requirements, such as the revised Consumer Protection Code (“CPC”);
• demographic changes;
• the introduction of pension auto enrolment; and
• increasing consumer awareness and heightened awareness.

Strategic Priorities

The Plan sets out three strategic priorities as follows:

• Delivering for our customers – with a continued focus on the provision of an accessible, inclusive and easy to use service to resolve complaints and reduce waiting times through the optimisation of systems and processes.
• Sharing and influencing – the focus here is on raising consumer awareness regarding options and rights and also on influencing industry standards through the sharing of insights with regulators, policymakers and providers with the aim of creating a more progressive financial services and pensions environment.
• Strengthening our team and innovating for better services – the Plan sets out that in order to deliver on its mission, it will continue to strengthen and develop its team, innovate through the use of technology and data. A further area of focus here is on improving the FSPO’s business processes, operating model and governance.

Each of the strategic priorities are further broken down into categories setting out strategic goals, expected outcomes, strategic initiatives and key performance indicators (“KPIs).

Implementation

The FSPO has stated that it is developing a strategy framework to monitor and track expected outcomes, KPIs and initiatives. It has further been stated that the FSPO will develop annual work programmes which will underpin the Plan with progress being measured by way of quarterly KPI reviews and progress against strategy will be reported in annual reports.

1. ESMA publishes final report on technical advice on Listing Act amendments to MAR and MiFID II

On 7 May 2025, the European Securities and Markets Authority (“ESMA”) published its final report (“Report”) containing its technical advice to the European Commission (“Commission”) regarding the legislative changes brought about by the Listing Act, including the delegated acts to be adopted under the Market Abuse Regulation (“MAR”) and the Markets in Financial Instruments Directive II (“MiFID II”).

ESMA consulted on draft technical advice in December 2024, for more information, see FIG Top 5 at 5 dated 19 December 2024.

Contents of the Report

The Report contains ESMA’s assessment and feedback, received on foot of the above mentioned consultation.

The MAR technical advice is contained in section 4 and addresses:

• an introduction dealing with the changes to MAR;
• the disclosure of inside information in a protracted process;
• the conditions for delaying disclosure of inside information, including cases of conflict with previous public announcements; and
• the methodology and preliminary findings for identifying trading venues with significant cross-border activity for cross market order book (“CMOB”) implementation.

The technical advice in relation to MiFID II is set out in section 5 and deal with the conditions for multilateral trading facilities (“MTFs”) or their segments to qualify as small and medium enterprise growth markets (“SME GM”). Relevant legal provisions are reviewed and targeted adjustments to MiFID II are suggested.

Next Steps

ESMA submitted the Report to the Commission on 6 May 2025. The Commission is required to adopt the delegated acts, which are the subject of the Report, by July 2026.

2. Commission adopts delegated regulation extending procedural rules for penalties imposed on DRSPs to CTPs under MiFIR

On 7 May 2025, the European Commission (“Commission”) adopted delegated regulation (C (2025) 2691) (“Delegated Regulation”). The Delegated Regulation amends delegated regulation (EU) 2022 / 803 as regards the rules of procedure for the exercise of the power to impose fines or periodic penalty payments by the European Securities Markets Authority (“ESMA”) with respect to consolidated tape providers (“CTPs”).

The Commission consulted on a draft of the Delegated Regulation in February 2025, for more information, see FIG Top 5 at 5 dated 13 February 2025.

The aim of the Delegated Regulation is to ensure that, in view of the upcoming CTP authorisation process, the scope of application of the procedural rules for ESMA's supervision of all types of  data-reporting-services providers (“DRSPs”) under delegated regulation (EU) 2022 / 803 includes CTPs. 

Next Steps

The Delegated Regulation will be published in the Official Journal of the European Union (“OJEU”) and enter into force if the European Parliament or the European Council do not object to it. The Delegated Regulation will enter into force 20 days after its publication in the OJEU and will be directly applicable.

3. Commission adopts delegated regulation amending delegated regulation on fees relating to the supervision by ESMA of CTPs

On 7 May 2025, the Commission adopted delegated regulation (C (2025) 2687) (“Delegated Regulation”). The Delegated Regulation amends commission delegated regulation (EU) 2022 / 930 as regards the  supervisory fees charged by the ESMA to DRSPs in order to extend it to include CTPs.

The Commission consulted on a draft of the Delegated Regulation in February 2025, for more information, see FIG Top 5 at 5 dated 13 February 2025.

Next Steps

The Delegated Regulation will be published in the Official Journal of the European Union (“OJEU”) and enter into force if the European Parliament or the European Council do not object to it. The Delegated Regulation will enter into force 20 days after its publication in the OJEU and will be directly applicable.