Welcome to the FIG Top 5 at 5

On 10 December 2025, the Central Bank of Ireland (“Central Bank”) published a document entitled “Regulating & Supervising well – a more effective and efficient framework” (“Roadmap”). The Roadmap sets out the Central Bank’s simplification agenda, describing it as a multi-year, disciplined programme.

The Roadmap refers to the Draghi and Letta reports and the renewed focus on competitiveness and resilience, with the European simplification agenda forming part of this. Further, the Roadmap sets out that the Central Bank, as part of the European framework, has been engaged in examining how to enhance its regulatory and supervisory frameworks, reduce unnecessary burdens, strengthen supervisory convergence, and improve the clarity of its requirements without compromising resilience and protections.

The Central Bank has carried out an assessment of areas for simplification and improvement, with the Roadmap setting out its current and intended direction of travel.

The Roadmap is comprised of four sections, the following is a high-level overview of each:

Our approach

Amongst other matters, this section discusses the Central Bank’s new supervisory approach to supervision, noting that the new approach includes a commitment to improving regulation and a willingness to reviewing existing frameworks to see whether the same outcomes can be achieved in simpler and different ways.

This section also sets out how the Central Bank views simplification, for example, as ensuring that supervisory judgement is supported via clearer frameworks  and supervisory effectiveness is supported by way of clearer communications.

Also under this heading, the Roadmap addresses what the Central Bank refers to as “Guardrails for Simplification”, stating that it is engaging with simplification, subject to the following guardrails for decision making:

• simplification should not compromise the ultimate delivery of the Central Bank’s mission and safeguarding outcomes;
• regulatory burdens should align with the scale, complexity, and risk profile of the activity;
• change should be evidence based;
• domestic regulations should promote coherence within the Single Market;
• simplify the application and supervision of existing rules before amending the legislation;
• there should be clarity and transparency around what has changed; and
• regulation and supervision should continue to adapt as markets evolve, and supervisors and firms must retain the ability to respond appropriately to emerging risks.

Simplification in Europe

In this section, the Roadmap provides a summary of the work of the various European institutions when it comes to simplification, including:

• the European Commission;
• the European Central Bank (“ECB”) – noting its establishment of a high-level task force on simplification to develop proposals for simplifying the European prudential regulatory, supervisory, and reporting framework, while still maintaining a strong banking sector in Europe;
• ECB banking supervision via the single supervisory mechanism, noting the publication of its multi-year programme to make supervision more effective, consistent and proportionate;
• the European Supervisory Authorities (“ESAs”), outlining work / initiatives on the part of the three ESAs related to proportionality and framework modernisation; and
• the European Systemic Risk Board (“ESRB”), highlighting work on rationalising macroprudential tasks.

The Central Bank’s plan for a more effective and efficient regulatory framework

This section sets out what the Central Bank has done and work it is currently engaged in, as regards simplification, across the Central Bank’s remit regarding supervision, regulation, gatekeeping and reporting.

As regards supervision, some of the matters highlighted are as follows:

• the move to a new supervisory approach as of January 2025 – for more information, see FIG Top 5 at 5 dated 6 March 2025;
• the provision of more clarity and visibility in the Central Bank’s supervisory communications – including setting out its key planned sectoral thematic engagements for the year; and
• delivering a sectoral approach to supervision, focusing on the most material risks for each sector, complemented by additional supervision for the most significant firms.

When it comes to regulation, some matter highlighted by the Roadmap are as follows:

• in the insurance sector, the Central Bank is carrying out a compatibility review of more than 50 domestic instruments to identify overlap, underlap, and opportunities for consolidation;
• also as regards insurance, the 2021 Recovery Planning Regulations will be reviewed in light of the EU Insurance Recovery and Resolution Directive which is set to take effect in 2027; and
• in the banking sector, the Code of Practice on Lending to Related Parties, the Policy on the Management of Country Risk by Credit Institutions and the Impairment Provisions for Credit Exposures are being reviewed in light of updated EU standards to ensure consistency and relevance.

The Roadmap also sets out cross sectoral initiatives in the regulation sphere, some of which are as follows:

• the consolidation of the guidance on the fitness and probity (“F&P”) standards, for more information, see FIG Top 5 at 5 dated 27 November 2025;
• on foot of the DORA implementation, the Cross-Industry Guidance in respect of IT and Cyber Security Risks has been reviewed and removed. Additionally, the Cross-Industry Guidance on Operational Resilience has been updated to ensure it aligns with DORA – for more information, see FIG Top 5 at 5 dated 24 July 2025;
• a three year review of the Senior Executive Accountability Regime (“SEAR”) in 2027;
• a 2026 public consultation on new regulatory impact assessment framework; and
• the retiring of any domestic publications that are no longer applicable due to the new EU AML Regulation and their replacement with a single, directly applicable EU rulebook.

When it comes to gatekeeping, the Roadmap restates the Central Bank’s commitment to efficiency and takes account of feedback received that clarity and responsiveness to incoming applications could be improved. Some of the Central Bank initiatives set out in the Roadmap are as follows:

• enhanced guidance, expectations, and engagement, including the Central Bank’s Authorisations and Gatekeeping report, and its consolidated F&P guidance;
• the establishment of a dedicated F&P unit;
• the streamlining of authorisation and change of business requirements for the insurance sector;
• the Central Bank will establish a gatekeeping division to ensure clarity, consistency and efficiency across its wider gatekeeping work, including authorisation; and
• in H2 2026, the Central Bank will review the pre-approval controlled function framework to reduce administrative load while maintaining clarity around responsibility, with this review proposing changes that will align with the 2027 SEAR review.

The Roadmap also highlights initiatives in the area of reporting and data, some of which are as follows:

• a comprehensive review of data collections and the implementation of a “discipline-by-design” approach to ensure that every domestic reporting requirement has a clear purpose; and
• the Central Bank has consolidated new reporting requests to avoid duplication and has improved internal governance regarding data collections.

Conclusion and Roadmap

This section sets out what the Central Bank’s view of success is, generally, and also specifically as regards simplification. The Roadmap highlights that the simplification measures set out will, amongst other things, contribute to:

• maintaining and strengthening resilience;
• a regulatory framework that is clearer, simpler, and more coherent, aligned with the evolving European system;
• greater and better demonstrated proportionality;
• improved effectiveness and efficiency of supervision; and
• more predictable processes and procedures for firms, including for initial authorisations.

1. Central Bank launches Access to Cash consultations

On 5 December 2025, the Central Bank of Ireland (“Central Bank”) launched two public consultations on the implementation of its responsibilities under the Finance (Provision of Access to Cash Infrastructure) Act 2025 (“Act”).

The Act, which has been effective since 30 June 2025, grants new powers to the Central Bank and provides for the continued provision of sufficient access to cash infrastructure. For more information on the Act, see FIG Top 5 at 5 dated 22 May 2025.

Central Bank powers

Under the Act, certain credit institutions, referred to as ‘designated entities’, are required to maintain the cash infrastructure network at certain minimum levels. This is aimed at  ensuring that any further evolution of the cash infrastructure is managed in a fair, orderly, transparent and equitable manner for all stakeholders.

The new powers, conferred on the Central Bank under the Act, relate to overseeing compliance by the designated entities with their obligations under the Act and to requiring remediation as regards any instances of non-compliance.

Where a member of the public believes that there is, or is likely to be, a deficiency in access to cash in their locality, they can make a submission to the Central Bank. The Central Bank will determine if there is a local deficiency, and designated entities will be responsible for addressing identified deficiencies.

The Central Bank will also set service standards applicable to ATM operators and will also oversee the registration of ATM deployers and cash-in-transit (CIT) providers.

Consultation Paper CP163 Access to Cash Local Deficiency Guidelines (“CP163”)

The Act recognises that certain geographical areas could experience particular difficulties as regards access to cash for SMEs or individuals, even if the criteria under the Act are being met.

CP163 seeks views on the Central Bank’s proposed guidelines for notifying, assessing, and making determinations as to whether local deficiencies in access to cash infrastructure exist within the State and whether it is appropriate and proportionate that they are remedied.

The local deficiency guidelines in annex 1 of CP163 supplement the framework for local deficiencies that is provided in the Act. They detail how the Central Bank will implement its responsibilities with respect to the operation of the local deficiency framework and how individuals and SMEs that wish to rely on this framework must engage with the Central Bank. In particular, the draft guidelines set out the Central Bank’s processes in relation to notifications, assessments, and determinations in respect of local deficiencies in access to cash infrastructure.

Consultation Paper 164 Access to Cash: Requirements for ATM Operators (“CP164”)

Under Section 31 of the Act, the Central Bank is mandated to introduce regulations (“Regulations”) setting out the requirements for ATM operators in relation to notifications and appropriate service standards (“Requirements”).

CP164 contains the Requirements that the Central Bank is proposing to implement through the Regulations – a draft of which is set out in annex 1 to CP164.

The Central Bank has stated that, in 2026, it will publish the Regulations setting out the ATM service standards relating to the hours of ATM availability, cash withdrawal limits, banknote denomination stocking, maximum ATM unavailability periods, and signage and information requirements.

Next Steps

CP163 and CP164 are both open for feedback until 4 March 2026, with the Central Bank stating that it welcomes feedback on one or both consultations.

Additionally, the Central Bank has stated that it will engage directly with consumers, people with disabilities, older people and SMEs during Q1 2026.

2. Governor of the Central Bank publishes blog post on digital euro

On 5 December 2025, the Central Bank of Ireland (“Central Bank”) published a blog (“Blog”) authored by the Governor of the Central Bank, Gabriel Makhlouf.

The theme of the Blog centres around the digital euro and how we now pay for goods and services, in the context of an increasingly digitalised economy. The Governor states that money is built on trust, from the issuer to the institutions that oversee the system, and that this trust must not be eroded despite the rapid changes. However, the Governor recognises that central banks “need to keep pace and innovate”.

The Blog sets out that more than 85% of money held by people in the euro area is made up of digital private money issued by commercial banks, as opposed to physical central bank money. Acknowledging that technological developments have facilitated the advancement of alternative forms of money, such as tokenised deposits and stablecoins, the Governor states that different forms of money can coexist for different purposes if safely designed and supervised.

However, the Governor cautions that the “economic fundamentals” do not change and that new technologies are subject to traditional risks such as liquidity mismatch, excessive leverage or asset quality issues. The Governor goes on to explain that, through supervision and regulation of the banking sector, such risks are addressed by the Central Bank to ensure that money issued by regulated private banks can be used seamlessly by households and businesses.

In light of the evolution of private sector money issuance and increasing digitalisation, the Governor explains that the eurosystem has concluded that public central bank money must also evolve, citing the Central Bank’s task as one of ensuring, and reassuring markets and the public, that central bank money “remains available, safe and efficient in this new environment, and that it will continue to fulfil its role in serving as the foundation of trust in our currency. The digital euro will be that central bank money or, in effect, digital cash.”

Stating that the digital euro is expected to launch in 2029, the Governor also highlights some matters regarding the digital euro and the payments landscape in general, some of which are as follows:

• the Central Bank is committed to ensuring cash is readily available as a means of payment. This commitment is supported by the Access to Cash legislation and the consultations launched by the Central Bank in this regard, for more information, see the update above;
• the Central Bank plans to carry the properties of cash into the digital era so that it can be used both on and offline, in person-to-person transfers and at points of sale across the euro area. This will ensure that everyone in the euro area can keep using a public, universally accepted, and trusted means of payment for day-to-day payments, both on and offline;
• the digital euro will sit alongside private sector payment offerings increasing choice and supporting the National Payments Strategy – for more information, see FIG Top 5 at 5 dated 24 October 2024;
• the digital euro will contribute to a stronger and more integrated Europe in terms of reducing Europe’s reliance on a small number of non-European providers. Here, the Governor also refers to the fact that wide adoption of non-Euro denominated stablecoins presents risks to euro area macroeconomic stability hindering Europe’s ability to respond to shocks and maintain inflation at target; and
• the Governor states that Ireland’s Presidency of the European Council will “likely see a major step in the digital euro’s creation and in the modernisation of Europe’s payment systems.”

On 8 December 2025, the Governor of the Central Bank of Ireland (“Central Bank”), Gabriel Makhlouf, delivered a speech (“Speech”) at the climate risk and sustainable finance forum.

The Governor highlighted some statistics as regards climate change and emissions and also noted that the availability of financing will be crucial for success as regards transitioning to net zero. In this context the Governor stated that legal frameworks have been developed over the last number of years to support this transition but that such frameworks are complex. Additionally, financial flows to sustainable activities are estimated to be approximately a quarter of what they need to be by 2030.

Progress

Governor Makhlouf summarised progress to date around sustainable finance and concluded that sustainable finance now needs to be more about action and outcomes rather that statements of commitment. To achieve this, he stated that trust in sustainable finance needs to be built and secondly, that a focus on the management of climate risk needs to be maintained alongside an increase in the focus on climate change mitigation and adaptation.

Momentum

The Governor emphasised the importance of maintaining momentum and in that context, highlighted that the Central Bank has updated its climate and sustainable finance strategy, focusing on three key areas:

• building financial resilience, both at a microprudential and macroprudential level;
• in line with the Central Bank’s economic advice mandate, informing national climate policy through data, research and greater collaboration on the macro-financial aspects of climate change and the transition to net zero; and
• enabling the financial system to play its role in the transition.

Supervisory expectations and November 2021 Dear CEO letter

The Governor highlighted that the Central Bank is continuing to embed climate risk management and supervision of sustainable finance into all aspects of its supervisory work. Further, Governor Makhlouf emphasised the importance of the 2021 Central Bank letter to chairs and CEOs of regulated financial service providers where the Central Bank’s supervisory expectations regarding climate change and other ESG matters were set out. In that regard, the Governor stated that those expectations have not changed and that firms are expected to:

• demonstrate clear ownership of climate risks affecting the firm, and promote a culture that places emphasis on climate and other ESG matters;
• understand the impact of climate change on their risk profile, and embed it in risk management frameworks;
• carry out scenario analysis to understand potential impacts of climate change;
• determine the impact of climate risk, and opportunities, on their risk profile, business strategy and long-term sustainability. This should inform strategic planning; and
• transparency around what firms are doing, including not engaging in greenwashing.

The Governor highlighted progress in this area, noting that firms have enhanced board oversight, gradually incorporating climate factors into risk frameworks and strategies. However, progress has been uneven with maturity varying across sectors and firms.

Governor Makhlouf stated that he expects firms to build on progress made, particularly highlighting that firms should deepen their understanding of the potential impacts on the long term sustainability of their business model. Further, he emphasised that firms should “continue to deliver sustainable products in a clear and transparent way that meets the needs of investors and consumers.”

Sustainable finance regulatory framework

The Governor expressed his support for the efforts in the EU regarding the removal of unnecessary complexity from the sustainable finance regulatory framework, noting that, currently, it is complex and presents challenges for financial market participants who wish to support the transition away from unsustainable activities. He expressed his hope that “the review of the Sustainable Finance Disclosure Regulation will deliver something that is less complex and more user-friendly for investors.”

Flood insurance protection gap

Here, the Governor stressed the importance of collaboration domestically, referring to the Central Bank’s 2024 flood protection gap report – for more information, see FIG Top 5 at 5 dated 17 October 2025. He noted that there is quite an amount of work to be done in this area but highlighted that he is “encouraged by initial discussions with the Department of Finance and the insurance industry on this topic.”

On 4 December 2025, the European Commission (“Commission”) published its market integration package (“Package”) aimed at removing barriers to, and unlocking the full potential of, the EU single market for financial services.

The Package is a key part of the savings and investment union (“SIU”) strategy – for more information on the SIU strategy, see FIG Top 5 at 5 dated 27 March 2025.

The Commission has stated that more integrated capital markets are essential for the EU’s economic strength, further highlighting that simplified access to capital markets will reduce costs and will also make the markets more attractive for investors and companies across all member states.

Elimination of barriers to integration

The Package seeks to remove barriers to integration in trading, post-trading, and asset management, ultimately aiming to enable market participants to operate seamlessly across member states. This will reduce cost differences between domestic and cross border transactions. Proposed measures include:

• enhancing passporting opportunities for regulated markets and central securities depositories; and

 

• the introduction of ‘pan-European market operator’ status for operators of trading venues to streamline corporate structures and licenses into a single entity or single license format.

Innovation

The Package also focuses on the removal of regulatory barriers to innovation regarding distributed ledger technology (“DLT”), adapting the regulatory framework to support DLT. Further, the Package amends  the DLT Pilot Regulation with the aim of encouraging the adoption of new technologies in the financial sector.

Supervision

The Package includes proposals aimed at improving the supervisory framework, addressing inconsistencies and complexities stemming from fragmented national supervisory approaches. Some of the measures proposed include:

• enhancing supervision by assigning direct oversight of significant market infrastructures and crypto-asset service providers to the European Securities and Markets Authority (“ESMA”); and
• improving regulatory consistency and strengthening ESMA’s decision-making with a new executive board.

Affected legislation

The Package consists of one Commission communication and three legislative proposals, as follows:

A proposal for a regulation, which will amend a number of pieces of  legislation, some of which include:

• the ESMA Regulation;
• the Markets in Financial Instruments Regulation;
• the Central Securities Depositories Regulation; and
• the Markets in crypto-asset Regulation.

The proposal for a regulation will also include targeted amendments to other EU regulations, in line with the changes proposed to the ESMA Regulation, aimed at more efficient EU supervision.

There is also a proposal for a directive which will amend:

• the Markets in Financial Instruments Directive;
• the Alternative Investment Fund Managers Directive; and
• the Undertakings for Collective Investment in Transferable Securities Directive.

Finally, the Package includes a proposal for a regulation replacing the Settlement Finality Directive and amending the Financial Collateral Directive.

Next Steps

The Package must now be negotiated and approved by the European Parliament and the European Council.

1. EIOPA launches consultations on revised guidelines on group solvency calculations and reporting

On 5 December 2025, the European Insurance and Occupational Pensions Authority (“EIOPA”) launched two consultations on draft revised guidelines on group solvency and on supervisory reporting and public disclosure.

EIOPA explains that the consultations come on foot of the review of the Solvency II directive and, in that regard, EIOPA is examining all existing guidelines in the interests of consistency with the amended regulatory framework. The consultations also take account of streaming and simplification, where possible, without compromising effective supervision.

The consultations also take account of the amendments to the Commission Delegated Regulation that the European Commission adopted on 29 October 2025 – for more information, see FIG Top 5 at 5 dated 6 November 2025.

The consultations are as follows:

Consultation on draft revised guidelines on group solvency – Solvency II review

This consultation (“Group Solvency Consultation”) contains draft revised guidelines on group solvency (“Guidelines”). The current guidelines have been applicable since 2015.  The Guidelines have been updated as follows:

• guidelines 1, 4, 5, 9, 12, 15, 16 and 23 and the technical annex have amended to take account of the amended legal framework and to improve the clarity of the text;
• guidelines 2, 3, 6, 7, 11, 13, 14, 17, 18, 19, 20, 21, 22 and 24 to 27 have been deleted in the interests of simplification, with EIOPA explaining that these are no longer applicable due to their redundancy or their inconsistency with the revised legal framework; and
• guidelines 8 and 10 have not been changed.

Consultation on draft revised guidelines on reporting and public disclosure – Solvency II review

This consultation (“Reporting Consultation”) contains the draft revised guidelines (“Guidelines”) on reporting and public disclosure. The current guidelines have been applicable since 2015. EIOPA explains that these Guidelines particularly required updating due to the introduction of a new solvency and financial condition reports structure as a result of the Solvency II review.  Some of the amendments are as follows:

• the reference to reporting in case of predefined events in the introductory section has been removed;
• guidelines 3, 6, 8, 9, 11, 12, 18, 19, 21, 30, 31,32, 33, 34, 36, 38, 39 have been deleted; and
• guidelines 5 and 20 have been amended.

Streamlining

EIOPA has stated that the amendments to the both sets of guidelines are mostly for clarification and streamlining purposes. There is no intention to reduce supervisory expectations. The amendments do not provide new guidance for the application of the legal framework. Accordingly, EIOPA explains that the revisions are not expected to have a material impact on the insurance industry or supervisory authorities.

Next Steps

Both consultations are open for feedback until 27 February 2026. The final guidelines will be applicable when the amended Solvency II Directive becomes applicable.

2. EIOPA publishes new and updated guidance on group supervision, related undertakings and assessment of internal models

On 5 December 2025, the European Insurance and Occupational Pensions Authority (“EIOPA”) published new guidelines on exclusions from group supervision, revised guidelines on the treatment of related undertakings and an updated opinion on internal models with dynamic volatility adjustments (“DVA”).

EIOPA consulted on all three publications in April 2025 – for more information, see FIG Top 5 at 5 dated 10 April 2025.

The following is an overview of each publication:

Final report on guidelines on exclusions from scope of group supervision

On 3 April 2025, EIOPA launched a consultation on draft guidelines on the exclusion of undertakings from the scope of group supervision (“Group Supervision Guidelines”). The final report, published by EIOPA, contains the final text of the guidelines.

EIOPA explains that the Group Supervision Guidelines have been drafted in the context of the review of the Solvency II Directive.

The amended article 214(3) of the Solvency II Directive requires the group supervisor to consult with EIOPA, and the other supervisory authorities concerned, before deciding to exclude one or more undertakings from the scope of group supervision where that would not trigger the application of group supervision under article 213(2)(a) to (c) of the Solvency II Directive and when deciding to exclude the ultimate parent undertaking from group supervision. In light of feedback received, among other things, EIOPA has clarified the relevance of dividends payments to the ultimate parent undertaking in case of application of group supervision at the level of an intermediate participating undertaking.

Final report on revised guidelines on treatment of related undertakings

This final report contains the final text of the revised guidelines on the treatment of related undertakings, including participations (“Related Undertakings Guidelines”). The original guidelines have been applicable since 2015 and have been updated to include amendments to update legal references and to clarify and streamline the text. Some of the amendments are as follows:

• three guidelines have been deleted with EIOPA stating that their content is sufficiently clear from the provisions of Solvency II;
• four guidelines have been amended to reflect changes to the Solvency II Directive; and
• the explanatory text on guideline 3, which deals with the identification of a strategic participation, was amended to clarify the proportionate application of that guideline.

Final Report on revised opinion on internal models with DVA (“Opinion”)

EIOPA’s 2017 opinion on the supervisory assessment of internal models including a DVA has been updated following the review of the volatility adjustment framework in Solvency II with EIOPA explaining that the Opinion has been updated to reflect the revised prudency principle and to add further clarifications.

Next Steps

The Group Supervision Guidelines, the Related Undertakings Guidelines and the Opinion will all be published on EIOPA’s website and will be applicable from 30 January 2027, which is when national measures to transpose the amended Solvency II Directive will apply.