The Central Bank of Ireland (“Central Bank”) is continuing its review of the supervisory framework for fund management companies (“FMCs”).
Following the publication of its report on delegation in the funds sector in July 2026 (see our earlier briefing note), the Central Bank is hosting a series of workshops with industry to discuss revisions to the framework, with the first workshop taking place on 14 September 2026.
Discussions to date have suggested that the Central Bank will move towards a more principles-based and outcomes-focused supervisory approach, with continued focus on substance, seniority, delegation oversight and evidencing effective challenge.
The review is not limited to considering the Central Bank’s Guidance on Fund Management Company Effectiveness (known as CP86), but will also consider related frameworks such as the potential extension of the Senior Executive Accountability Regime to the funds industry, the application of the Consumer Protection Code and the introduction of an errors framework. The review is expected to consider governance and oversight of delegated arrangements, substance requirements for FMCs, the performance of portfolio management and risk management functions in both delegated and retained models. The review is expected to continue into 2027, with consultations anticipated as part of the process.
Following on from the publication of the feedback report on delegation in the funds sector earlier this year, FMCs are expected to consider the contents of the report with input from the FMC board, conduct a gap analysis against the supervisory expectations set out therein, and put in place a time-bound plan by year end to address any deficiencies identified in their operational, resourcing and governance arrangements in respect of delegation.
Please get in touch with your usual Asset Management and Investment Funds Department contact or any of the contacts listed in this publication should you require further information in relation to the material referred to in this briefing note.
