1. Government Legislation Programme Autumn 2025 – a financial services perspective
On 17 September 2025, the Government Legislation Programme for Autumn 2025 was published (“Programme”). The Programme identifies 34 bills to be prioritised for publication and 33 bills to be prioritised for drafting, with 75 additional bills listed under “All Other Legislation”.
There are currently 16 bills on the Dáil and Seanad order paper, while 13 bills have been published and 10 enacted, since the Government came to office on 23 January 2025.
Those of direct relevance to financial services are outlined below:
Legislation for Priority Publication
- Conclusion of IBRC Special Liquidation and Dissolution of NAMA Bill aims to effect the conclusion of the Irish Bank Resolution Corporation Special Liquidation and the dissolution of the National Asset Management Agency (“NTMA”) by the end of 2025. Further, it aims to implement appropriate arrangements to manage any remaining residual activity of both entities following the respective conclusion of their work mandates, including through the creation of a new Resolution Unit within the NTMA to manage any remaining residual activity from 2026 onwards. The Programme indicates that Heads of Bill were approved in July 2024 and that work is ongoing.
Legislation for Priority Drafting
Co-operative Societies Bill aims to place the co-operative model on a more favourable and clearer legal basis, thereby creating a level playing field with companies and encouraging the consideration of the cooperative model as an attractive formation option for entrepreneurs. The Programme indicates that work is ongoing
Finance (International Financial Institutions) Bill aims to put in place the legislative authority for the Minister and the Central Bank of Ireland to contribute to the IMF Resilience and Sustainability Trust using a portion of Irelands allocation of IMF Special Drawing Rights. The Bill will also provide a government guarantee to the Central Bank of Ireland for the purpose of contributing to the IMF Trust and make other administrative amendments relating to Ireland’s membership of international financial institutions. The Programme indicates that Heads of Bill were approved in July 2025 and that work is ongoing.
Violation of Restrictive Measures Bill which will transpose EU Directive 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive measures. The Programme indicates that Heads of Bill were approved in March 2025.
All Other Legislation
- Central Bank (Amendment) Bill 2025 which will transpose certain elements of Directive (EU) 2024/1640 (Sixth Anti-Money Laundering Directive) of relevance to the Central Bank of Ireland, through amendment to the Central Bank Reform Act 2011 and / or the Central Bank (Supervision and Enforcement) Act 2013. The Programme indicates that work is ongoing.
- Restrictive Measures Bill 2025 aims to create a mechanism by which persons would be obliged to adhere to the asset freezing requirements of certain UN Security Council Resolutions in the period prior to their incorporation in an EU legislative act, in order to meet Ireland’s international obligations and prevent sanctions evasion. The Programme indicates that work is ongoing.
- Asset Covered Securities (Amendment) Bill aims to amend the Asset Covered Securities Act 2001 to facilitate the issuance of asset covered securities (covered bonds) either by specialist covered bond subsidiary entities under a specialist banking model or from non-specialist credit institutions operating under a universal banking model and related matters. The Programme indicates that Heads of Bill are being prepared.
- Personal Insolvency (Amendment) Bill aims to update aspects of personal insolvency legislation, following statutory review of Personal Insolvency Acts. The Programme indicates that work is ongoing.
Next Steps
The FIG Top 5 at 5 will continue to monitor the progress of the legislative initiatives and update clients when appropriate.
2. Central Bank publishes September 2025 insurance newsletter
On 12 September 2025, the Central Bank of Ireland (“Central Bank”) published its September 2025 Insurance Newsletter (“Newsletter”).
The Newsletter covers areas of relevance and interest to the insurance sector. Some of the matters covered in this edition include:
Insights on asset intensive reinsurance (“AIR”)
In the March 2025 Insurance Newsletter, the Central Bank featured a financial resilience spotlight on the use of AIR, including its intention to issue a data request to a sample of less than 20 life (re)insurance firms in Q2 2025. For more information, see FIG Top 5 at 5 dated 3 April 2025
The data request contained four sections addressing exposure to AIR / collateral / risk management / impact of default. Eleven firms were surveyed and the Newsletter includes insights from the data request, some of which are as follows:
- Exposure to AIR at the life (re)insurance industry level is broadly in line with what the Central Bank expected to see, with the total exposure at year end 2024 at approximately €30 billion, for the firms surveyed;
- Exposure to AIR is expected to increase by around 5% over the course of 2025;
- Generally, AIR exposure is well collateralised with high quality assets;
- As regards default of the main reinsurance counterparty, it was found that some firms would breach 100% solvency capital requirement (“SCR”)
- coverage ratio, before allowing for recovery of collateral - this was found to be prevalent for firms that have a concentration of exposure in a single counterparty;
- The Central bank found that all surveyed firms have governance and controls in place regarding AIR exposure and collateral assets. The Newsletter sets out some good risk management practices that it observed, such as:
- Continual monitoring of reinsurance exposures;
- Investment mandates are in place, with guidelines and rules for the collateral assets;
- The ceding firm carries out regular monitoring of the collateral accounts to ensure that investment guidelines are being followed;
- A range of reinsurers are used to reduce concentration risk to a single counterparty; and
- The impact of default of the main counterparty, and the corresponding recovery actions are included in the firm’s recovery plan and ORSA.
- The Central Bank took the opportunity to remind firms to engage with their supervisor if there is a plan to enter into material AIR transactions, particularly highlighting that a material change to a firm’s business, due to changes in reinsurance and / or retrocession arrangements, requires pre-notification to the Central Bank as a change of business notification. In this regard, the Central Bank also emphasised that if there is a significant change in a firm’s reinsurance recoverable asset as a result of a particular AIR contract or an accumulation of such contracts, it may request further information and carry out a review.
- The Central Bank also detailed some of its key areas of focus when assessing reinsurance proposals, some of which are as follows:
- Impact of the transaction on the regulatory balance sheet;
- Measurement and management of counterparty risk;
- Stress testing, including recapture risk and the impact on the SCR coverage ratio of counterparty default.
- The following matters / areas were also highlighted by the Central Bank, and firms are advised to have regard to them, including:
- Solvency II requirements in articles 208- 214 of Commission Delegated Regulation (EU) 2015/35 as regards risk mitigating techniques for standard formula firms;
- The factors in EIOPA’s July 2021 opinion on the use of risk mitigation techniques by insurance undertakings – with the Central Bank highlighting that this was updated in July 2025 with annexes on mass lapse reinsurance and reinsurance agreements’ termination clauses, for more information, see FIG Top 5 at 5 dated 17 July 2025;
- The Central Bank’s guidance on intragroup transactions and exposures if the counterparty in intragroup.
The Central Bank advises firms to make sure that any proposed reinsurance transaction is in compliance with the forgoing guidance and requirements and to be able to provide evidence of such compliance.
Overall, the Central Bank found that the quality of collateral assets for AIR is high, but there are some firms with collateral asset allocations and credit ratings that may be indicative of increased risk – these firms will be subject to follow-up by the Central Bank.
Finally, the Central Bank advises that it will continue to monitor AIR as part of its ongoing supervision, taking into account the expected growth in this area.
Thematic review on consumer treatment when purchasing or renewing health insurance
The Newsletter highlights that the Central Bank recently completed a thematic review on consumer treatment when purchasing or renewing health insurance (“Review”), stating that this intention was set out in its Regulatory and Supervisory Outlook Report, for more information, see FIG Top 5 at 5 dated 6 March 2025.
The Newsletter states that the Review identified a number of good consumer focused practices but that certain weaknesses and gaps were also evident. In this regard, the Newsletter highlights that the Central Bank issued a “Dear Compliance Officer” letter (“Letter”) in July 2025 which set out the Central Bank’s findings, both good and bad, on foot of the Review together with its expectations.
The Letter requires health insurance providers to complete a gap analysis vis a vis the Central Bank’s expectations and to ensure that a plan is put in place to address any identified gaps and weaknesses. In that regard, the Newsletter sets out the priority expectations which firms are required to assess against – some of these are as follows:
- That firms will always offer a full suitability assessment to consumers who make contact to discuss their existing plan at renewal;
- Utilise their communications with consumers to encourage them to make contact to discuss their existing plan at renewal;
- Websites should include plan comparison tools; and
- There should be sufficient monitoring and oversight of the overall customer support function, including as regards the individual agents.
The Newsletter also highlights its Guidance on Securing Customers’ Interests and urges all insurers to ensure that they are not taking advantage of customer inertia or information asymmetry in the market. The Central Bank expects that health insurance providers will be proactive when it comes to:
- Assessing risks to consumers as regards their products / services; and
- Protecting the best interests of consumers by ensuring they are fully aware and effectively informed of their options and supports available.
Intra-group outsourcing: a review of specialty insurance firms
Continuing with the theme of reviews, the Newsletter highlights a recent Central Bank thematic risk assessment (“Assessment”) across a number of specialty insurance firms during 2025. The Assessment focused on intra-group outsourcing arrangements and the related governance and oversight.
The Newsletters sets out the findings of the Assessment under three headings, as follows:
- Substantive presence and decision making – with the Assessment showing that there is significant reliance on intra-group outsourcing across the specialty firms through the use of a shared services structure or third country branch. The Newsletter emphasises that firms must ensure adequate substance within Ireland with oversight and decision-making taking place at a local level;
- Outsourcing framework – the Assessment found that not all firms had an outsourcing policy and outsourcing strategy that was sufficiently tailored to the local Irish entity and reviewed annually by the local board. In this regard, the Newsletter highlights the 2021 Cross Industry Guidance on Outsourcing, specifically that firms must have a documented firm-wide outsourcing strategy and policy, to be reviewed and approved by the board on, at least, an annual basis; and
- Use of services companies and hybrid arrangements – the Newsletter notes that the Central Bank has observed that firms are increasingly entering into arrangements with the use of separate legal entities for the provision of extensive staffing to the undertaking (usually part of the same group as the undertaking) and goes onto to highlight that the Central Bank is focused on such arrangements, due to their potential to undermine the operational resilience of regulated entities, if not effectively managed.
Under this heading, the Newsletter emphasises the importance of compliance with the Central Bank’s 2022 Guidance on the Use of Service Companies for Staffing Purposes in the Insurance Sector and the 2021 Cross Industry Guidance on Outsourcing for firms with hybrid staffing arrangements.
The Newsletter highlights that, although the Assessment related to speciality insurance firms, the risks, expectations and findings set out in the Newsletter are relevant to all (re)insurance firms with significant intra-group outsourcing arrangements in place.
Additionally, the Newsletter states that the Central bank has issued a “Dear CEO Letter” to all speciality firms setting out the main messages of the Assessment, further stating that individual risk mitigation programmes and recommendations were issued to firms, where relevant.
Finally, the Newsletter sets out that the Central Bank will “incorporate the key messages outlined in the Dear CEO letter into our engagements going forward.”
Solvency II Review and Insurance Recovery and Resolution Directive
The Newsletter contains a section dedicated to EU legislative changes as regards the Solvency II Delegated Acts and the Insurance Recovery and Resolution Directive (“IRRD”).
As regards the amendments to Solvency II, the Newsletter sets out that the Central Bank will be gathering information on the impact on firms of the amendments to Solvency II, particularly focusing on:
- How firms are preparing to implement the changes from January 2027;
- Which firms will be seeking classification as a small and non-complex undertaking; and
- The impact on regulatory balance sheets.
The above information will be collected through supervisory engagement meetings, reviews on reserving, capital and ORSAs and through regulatory transactions with a data request possible in 2026, if considered necessary.
Firms are encouraged to start considering how the changes to Solvency II will affect them.
As regards the IRRD, the Newsletter references the recent closure of the Government’s recent consultation on the national transposition of IRRD – for more information, see FIG Top 5 at 5 dated 17 July 2025.
EIOPA updates
The Newsletter highlights some recent EIOPA updates – much of which has been covered in the FIG Top 5 at 5 over the last three months – such as:
- EIOPA’s report on biodiversity risk management by insurers;
- EIOPA’s public statement on the monitoring exercise on use of climate change scenarios in ORSAs;
- EIOPA’s opinion on artificial intelligence governance and risk management. In this section, the Newsletter highlights the adoption of a distributed model of implementation of the AI Act through statutory instrument no. 366 of 2025, by the Government, which designated the Central Bank as the market surveillance authority for the purposes of article 74(6) of the AI Act.
Remainder of Newsletter
Some of the matters addressed in the remainder of the Newsletter include:
- The authorisations and gatekeeping report, for more information, see FIG Top 5 at 5 dated 22 May 2025;
- The Q2 2025 insurance corporation statistics;
- Upcoming dates; and
- Links to recent Central Bank speeches / publications.
3. Competitiveness Updates: (1) Government's Action Plan on Competitiveness and Productivity – a financial services perspective (2) Commission holds conference reviewing progress on implementation of Draghi report recommendations (3) Matheson LLP hosts EU Summit focused on competitiveness in partnership with Trinity College Dublin
1. Government's Action Plan on Competitiveness and Productivity – a financial services perspective
On 10 September 2025, the Government published an Action Plan on Competitiveness and Productivity ("Action Plan"). The Action Plan articulates clear support for EU policy reforms to revitalise competitiveness within the Single Market while also focusing on "controlling the controllables"—those areas that fall within Ireland's own remit.
From a financial services perspective the following should be noted:
Savings and Investment Union - advancing the Savings and Investment Union is identified as crucial for developing a truly EU single market for financial services to help increase financing for riskier, but potentially highly productive investments, while lowering lending costs. Concrete measures identified include completing the European Single Access Point, harmonising insolvency procedures, greater portability of pensions products, and streamlining cross-border withholding tax procedures.
Single Market – the Action Plan emphasises that Ireland must continue to advocate for EU policy reforms that "reinforce the integrity of the Single Market and address barriers in energy, services, and capital markets" Priority Action 27(P) specifically mentions promoting Ireland's vision for "the Single Market" and advocating for Ireland's national interests at EU level, including "completing the internal market" as one of the key themes Ireland will advocate for at EU level.
Capital Markets and Investment – the Action Plan states that for Ireland, deeper integration, particularly in respect of services and the creation of a Capital Markets Union, offers a pathway to expanding export opportunities for firms in Ireland, and attracting new investment, while supporting the scaling of capital-constrained SMEs . Priority Action 27(P) includes "deepening capital markets" as one of the themes Ireland will advocate for at EU level. Priority Action 40(P) involves developing "policy actions that will incentivise pension fund and institutional investor participation, either directly or indirectly, into scaling equity funds to further enhance the Irish scaling ecosystem, and consider options for the development of incentives for the participation of retail savings in capital markets"
Next Steps
The Action Plan sets out six themes, under which a number of actions are identified with each such action having been given a timeline for implementation and a designated body responsible for oversight.
As regards practical delivery of the Action Plan, an annual progress report on implementation will be prepared for the consideration of Government. In order to support monitoring and oversight as regards the broader aims of the Action Plan, Government will continue to seek the advice of the National Competitiveness and Productivity Council, particularly when it comes to benchmarking Ireland’s performance against international peers.
2. Commission holds conference reviewing progress on implementation of Draghi report recommendations
On 16 September 2025, Ursula von der Leyen, President of the European Commission (“Commission”) and Professor Mario Draghi both delivered speeches at a conference, the focus of which was to review the Commission’s progress as regards the implementation of the recommendations in the Draghi report.
President Von der Leyen’s speech
Amongst other matters, President Von der Leyen highlighted the progress as regards implementation of the Draghi report recommendations some of which, from a financial services perspective, are as follows:
- The provision of €70 billion to support innovative companies through the launch of TechEU - the European Investment Bank Group’s programme which is dedicated to accelerating innovation across Europe through connecting innovators with the appropriate funding and expertise;
- The adoption of the SIU strategy by the Commission, aimed at increasing EU citizens participation in capital markets, fostering their wealth and boosting the EU economy;
- €8.4 billion in savings for European businesses through simplification initiatives, such as February 2025 first omnibus package on sustainability and the second omnibus on investment simplification; and
- The single market strategy - which aims to make the single market simpler and stronger by removing the most harmful barriers, reducing red tape, promoting investment and ensuring fair competition.
This speech follows on from President Von der Leyen 2025 sate of the union address last week where she outlined the next steps in terms of strengthening European competitiveness, for more information, see FIG Top 5 at 5 dated 11 September 2025 .
Professor Draghi’s speech
Professor Draghi emphasised that, over the last year, the challenges that Europe faces, as set out in his September 2024 report, have grown more acute. In that regard, he pointed out that the European Central estimates annual investment requirements at almost €1,200 billion, compared to €800 billion last year.
Professor Draghi recalled the three priorities set out in his report - closing the innovation gap in advanced technologies / a decarbonisation plan that supports growth / strengthening economic security – and proceeded to analyse progress over the last year along those lines. From a financial service perspective, some of the matters raised were as follows:
- the speech considers the challenge of financing Europe's investment needs through capital markets development;
- additionally, the speech considers the role of the single market in the context of Europe’s competitiveness, highlighting that if barriers in the single market are lowered and firms are able to scale up at am increased pace, then the growth of capital markets in Europe will also be accelerated;
- if reforms are actively pushed, Draghi argues that private capital will “step up” and less public money will be needed;
- Professor Draghi also emphasised the need for “28th regime” - allowing innovative firms to operate, trade and raise financing seamlessly across all member states; and
- Draghi referenced Europe's most successful projects—the Single Market and the euro – noting that both had been advanced through clear phases, firm milestones and sustained political commitment and he suggested that this model should be applied to current challenges;
Professor Draghi’s overarching message is that Europe needs to move beyond fragmented national approaches and embrace genuine European-scale solutions to remain competitive in an increasingly challenging global environment. He concluded by stating that “Only unity of intent and urgency of response will show that they are ready to meet extraordinary times with extraordinary action.”
3. Matheson LLP hosts EU Summit focused on competitiveness in partnership with Trinity College Dublin
The Summit explored the increasing complexity of both EU and global regulation and its impact across a variety of sectors, and brought together leading experts from government, academia, industry, and legal practice to examine how businesses can thrive amid rapid regulatory change.
The keynote address was delivered by Michael McGrath, European Commissioner for Democracy, Justice, the Rule of Law and Consumer Protection, who said: “Ireland's legal and academic traditions represented so strongly by Matheson and Trinity are part of what makes Ireland such a trusted base for international business, and I thank you and the broad range of stakeholders here today for your valuable contribution. I am particularly pleased that you've chosen EU Competitiveness as the focal theme for this significant occasion. This topic couldn't be more timely or relevant.”
4. Central Bank of Ireland Moves to Enhance AIF Regime and Revise UCITS Rules
The Central Bank of Ireland (“Central Bank”) has issued two consultation papers relating to proposed changes to its rules for alternative investment funds (“AIFs”) and for UCITS.
CP162 sets out proposed changes to the Central Bank’s AIF Rulebook, the set of requirements applicable to AIFs established in Ireland. The consultation follows a period of constructive engagement with industry aimed at enhancing the framework for the establishment of private funds in Ireland. Read more.
CP161 proposes amendments to the Central Bank UCITS Regulations to align the Irish domestic framework with changes being introduced at EU level through amendments to the UCITS Directive, and to address outstanding updates from previous consultations, incorporate existing guidance and to change the current rules relating to performance fees and the operation of redemption gates for UCITS. Read more.
Both consultations close on 5 November 2025.
5. Parliament adopts report on financing and reforms to boost competitiveness and the creation of CMU
On 10 September 2025, the European Parliament (“Parliament”) voted to adopt a report (“Report”) on facilitating the financing of investments and reforms to boost European competitiveness and the creation of a capital markets union (“CMU”).
A draft of the adopted Report was first published in March 2025 and stemmed from the Draghi report, for more information, see FIG Top 5 at 5 dated 20 March 2025.
The Report calls for financing to be more available and affordable, particularly for SMEs and innovative projects, with the Report further stating that this should be achieved, in part, by channelling personal savings in the EU into investments.
Additionally, the Report addresses the need for start-ups to stay in Europe and proposes a pan EU equity listing and trading environment to achieve this.
The importance of an EU strategy to promote financial literacy in Europe is also highlighted so as empower EU citizens to better protect and mobilise their savings and to build on a more attractive capital market.
SIU, Banking Union & CMU
The adopted Report also calls for the completion of the Banking Union, the CMU and the savings and investment union (“SIU”). As regards the SIU, the Report emphasises that the SIU should:
- incentivise private investment;
- protect financial stability and consumers;
- promote access to venture capital and equity investment to enable SMEs to benefit from greater market integration;
- ensure access to markets for retail investors;
- boost financial literacy; and
- reduce over-reliance on, and complement, bank lending, while also providing incentives for sustainable activities.
The Report highlights the importance of strengthening confidence in the banking system and points to the importance of financial stability and the promotion of an efficient single market as fundamental EU objectives. Further, the Report emphasises that the completion of the Banking Union must be a strategic priority when it comes to deepening economic and monetary union and calls on the European Council to speed up adoption of outstanding legislation such that the Banking Union can be completed.
As regards the CMU, some of the matters highlighted in the Report are as follows:
- the CMU mist be advanced such that private sector investments are leveraged;
- the lack of an integrated CMU results in EU-based entrepreneurs relocating in order to gain easier access to finance and resources;
- increasing financial literacy is fundamental to the creation of a successful CMU; and
- the Report calls on the Commission to engage in early discussions on the CMU and financial services in advance of introducing any new proposals or making changes to existing ones.
Momentum
In a related press release, the Parliament stated that the adoption of the Report aims to “maintain pressure towards reaching the objectives of” the Draghi report. In this regard, the Report highlights that Europe is lagging behind and risks “becoming irrelevant…if no further action is taken.”
Next Steps
Speaking after the vote to adopt the Report, the rapporteur, Aurore Lalucq stated:
"A year ago, the Draghi report painted a bleak picture of our continent’s economic situation. The European Parliament has chosen to respond with this report, which sets out a path towards greater financial independence for the European Union in order to halt its economic and political decline.
It is now up to the Member States to build on the momentum initiated by Parliament by turning these recommendations, such as joint supervision or support for sustainable investment, into concrete action.