Welcome to the FIG Top 5 at 5

1. Governor Makhlouf of the Central Bank delivers speech focused on independence of central banks

On 18 February 2026, the Governor of the Central Bank of Ireland (“Central Bank”) delivered a speech (“Speech”) to the Blavatnik School of Government at the University of Oxford. The theme of the Speech centred around the idea of central banks as institutions with a focus on their mandates, how their responsibilities are delivered, their accountability and future challenges.

The Governor discussed issues around what he referred to as the “resurfacing of questions” around the independence of central banks, especially in advanced economies. He took this opportunity to consider institutional design, specifically why some arrangements stand the test of time and some fail, ultimately analysing the position whereby independence has “become a defining feature of modern monetary frameworks.”

As regards, institutions in a broad sense, Governor Makhlouf discussed work by researchers in this area, concluding that well designed institutions are the building blocks upon which economic success is built.

Moving on, the Governor then stated that central banking should be understood through an “institutional lens”, further stating that they should serve to support a stable, sustainable macroeconomic framework to the benefit of society. He noted that the independence of central banks is an essential element of such a framework, with credibility being a central bank’s most valuable asset, highlighting that “Credibility also depends on a number of elements including competence, engagement, coherence, and public trust that decisions will be reached consistently and without bias.”

Governor Makhlouf discussed the 1960s and 1970s in terms of monetary policy being subject to short term political pressures, which ultimately resulted in macroeconomic volatility. The Governor continued in this vein, considering this matter from a historical perspective, citing examples from Italy in the 1980s and the UK prior to 1997, when interest rates were set by the chancellor of the exchequer.

The Governor emphasised that independent monetary policy allows interest rates to be set according to economic cycles rather than by political cycles.

Governor Makhlouf addressed central bank mandates and accountability, highlighting that independence is credible when mandates are clear and that accountability enhances trust, ultimately safeguarding independence. He stated: “Independence does not mean isolation. In an interconnected world, credible and effective central bank policies require dialogue with society more broadly and with other institutions responsible for economic governance.”

In terms of challenges for central banks, the Governor pointed to two, in particular:

• the risk of fiscal dominance, highlighting that it is the responsibility of governments to ensure that central banks are not put in a position of having to choose between sovereign solvency and price stability; and
• the responsibility of central banks in terms of supporting their trustworthiness and credibility by keeping pace with the changes happening in the respective communities they serve, emphasising the importance of engagement and a willingness to do things differently, if needed.

In conclusion, Governor Makhlouf stated: “Independence is a means to a public end; it requires continuous maintenance, analysis, engagement and review. As a central banker let me finish by acknowledging that our legitimacy rests on delivering outcomes for the people we serve and being accountable for the decisions we make.”   

2. Central Bank publishes first access to cash report

On 24 February 2026, The Central Bank of Ireland (“Central Bank”) published its first access to cash report (“Report”). The Finance (Provision of Access to Cash Infrastructure) Act 2025 (“Act”) has been in effect since  28 November 2025 – for more information, see FIG Top 5 at 5 dated 27 November 2025.

The Central Bank is responsible for the monitoring and enforcement of the Act by designated entities, with such monitoring to be carried out on a quarterly basis. The Report is the first quarterly report in that regard.

Main findings

The Report shows the number, location and opening hours of ATMs and cash service points across eight geographical regions in Ireland, as at 31 December 2025.

Some of the Report’s main findings are as follows:

• the cash infrastructure in Ireland is largely in line with the criteria set by the Minister for Finance under the Act, with just over 4,000 ATMs in Ireland and just over 1,200 cash service points; and
• there were six instances where the criteria were not met, but the Central Bank has explained that the shortfall, relative to expected levels of the cash infrastructure, is small. The Central Bank has already communicated these shortfalls to the relevant designated entities who will, in turn, submit proposals to address the shortfalls.

Local deficiencies

Deputy Governor Vasileios Madouros highlighted that there may be specific challenges in accessing cash at a more local level and in that regard, members of the public can make a submission to the Central Bank if they are of the view that there is a local deficiency regarding access to cash. In addition, the Deputy Governor emphasised the fact that the Central Bank is currently consulting on its guidelines and proposed approach to assessing local deficiencies and encouraged participation – for more information on the current consultation, see FIG Top 5 at 5 dated 11 December 2025.

Safeguarding access to cash

Welcoming the publication of the Report, Deputy Governor Madouros stated that:

“The Central Bank is committed to ensuring that cash is available and accessible as a means of payment. Today’s publication is an important part of our work to safeguard sufficient and effective access to cash by consumers and businesses across the country.”

1. Central Bank updates DORA webpage on preparation and submission of registers of information

On 20 February 2026, the Central Bank of Ireland (“Central Bank”) updated its dedicated DORA communications and publications webpage.

This most recent update (“Update”) highlights that there have been some developments at the European Banking Authority (“EBA”) which mean that there is an additional step in the collection process for the register of information (“RoI”) under DORA.

The Update states that in the week beginning 16 February 2026, the EBA announced that there will be an extra review step required as regards the content of the data submitted in the RoI, highlighting that the extra step is required to address issues that are identified in terms of the quality of the data content in the files.

Initial collection

The Update states that the initial collection will occur as per the Central Bank’s industry briefing of 4 February 2026 – for more information, see FIG Top 5 at 5 dated 12 February 2026.

Additional step

The Update sets out how, in April 2026, the EBA will run data quality (“DQ”) checks on all RoIs, which will result in extra feedback on data in RoIs. The Central Bank advises that it has not seen these DQ feedback files but that examples of some of the checks that will be performed have been provided by the EBA – these can be viewed here.

Next Steps

The Central Bank has confirmed that it has added the above information to its guidance for submitting registers (“Guidance”), further stating that it will continue to update the Guidance as new information is received.

 

2. Central Bank updates authorisation process for retail intermediaries and publishes template online ‘A Form’

On 19 February 2026, the Central Bank of Ireland (“Central Bank”) published its updated application process for retail intermediaries (“Process”). The Central Bank also published a pdf template online application form for authorisation as a retail intermediary – A Form (“A Form”), dated November 2025.

The Central Bank has previously flagged that, from 1 January 2026, it  will no longer accept Word-based application forms for ‘A Form’ applicants. Consequently, the Central Bank will now only accept online applications via the Central Bank’s Portal. The updates to the Process mainly take account of the fact that the A Form can now only be submitted online.

The Central Bank has advised that the pdf template A Form, linked above, is provided for reference only and is aimed at assisting applicants in submitting an A Form. The online A Form is available on request from RIAuthorisations@centralbank.ie.

The Central Bank has explained that this change is part of its ongoing efforts to make the authorisation process more efficient, user friendly, and consistent for all applicants. The online application is designed to only display questions relevant to the applicant. It also has built-in checks to help applicants to avoid common mistakes / omissions before submitting. Additionally, the Central Bank has advised that it will speed up processing times.

The Central Bank held a webinar on 24 February 2026 to provide applicants with an overview of the new online application form, and to provide some helpful advice for gaining access, completing, and submitting an A Form.

On 25 February 2026, the European Banking Authority (“EBA”) and the European Securities and Markets Authority (“ESMA”) launched a consultation (“Consultation”) on revisions to the joint ESMA and EBA guidelines on the assessment of the suitability of members of the management body and key function holders (“Revised Guidelines”), under Directive 2013/36/EU (“CRD”) and Directive 2014/65/EU (“MiFID II”).

The Revised Guidelines are aimed at improving and harmonising the assessment of suitability within the EU financial sector, and also seek to ensure that there are sound governance arrangements in entities.

The Revised Guidelines take account of new requirements for large institutions under the CRD VI Directive. Some of the proposed revisions address matters such as:

• the use of ex‑ante applications for cases where competent authorities carry out ex‑post assessments;
• mandatory suitability assessments for roles such as heads of control functions and chief financial officers;
• the new requirements under CRD IV for third‑country branches; and
• the provision of guidance for identifying reasonable grounds to suspect money laundering or terrorist financing risks.

The EBA and ESMA have highlighted that the revised Guidelines also take account of simplification and burden reduction.

On 25 February 2026, the EBA also published a consultation (“EBA Consultation”) on draft regulatory technical standards (“RTS”) to specify the minimum content of the suitability questionnaire, curriculum vitae and internal suitability assessment to be submitted to the competent authorities for performing the suitability assessment referred to in article 91(1f) and article 91a(5) for entities listed in article 91(1d) of the CRD IV Directive. The documentation and information requirements contained in the draft RTS are targeted at harmonising the minimum content of the relevant submissions to make sure that they are consistent, complete and comparable across the EU.

Next Steps

The Consultation is open for feedback until 25 May 2026. A public hearing will he held on 15 April 2026 – registration details are available here. The EBA and ESMA have stated that they will finalise the revised Guidelines after the Consultation. It is expected that the revised Guidelines will enter into force six months after the publication of all translations of the revised Guidelines.

The EBA Consultation is also open for feedback until 25 May 2026.

On 23 February 2026, the European Banking Authority (“EBA”) published a follow-up report (“Follow-up Report”) to its 2022 peer review report (“2022 Report”) on the ICT risk assessment under the supervisory review and evaluation process (“SREP”).

The Follow-up Report assesses the progress made by prudential supervisors as regards the implementation of the recommendations set out in the 2022 Report.

It is highlighted that the Follow-up Report comes of foot of some significant regulatory developments, particularly DORA and its fundamental restructuring of ICT risk supervision across the EU financial sector.

Additionally, it is noted that, as per a recommendation in the 2022 Report, ICT risk assessment is being incorporated into the revised SREP guidelines, which will ultimately replace the standalone SREP guidelines.

The Follow-up Report notes that improvements were made as a result of the 2022 Report recommendations. Some of those improvements are as follows:

• supervisors are in the process of strengthening their ICT supervisory capacity and expertise, progressing with the use of horizontal analysis and the systematic use of supervisory tools;
• there were improvements regarding the benchmarks on the use of the list of ICT risk sub-categories and risk scenarios, which have been broadly implemented by nearly all authorities; and
• the use of supervisory tools, for example, self-assessment questionnaires, automated data collection platforms and incident reporting systems, has become more systematic and technologically advanced.

The Follow-up Report encourages competent authorities to fully integrate ICT risk methodologies and ICT risk sub-categories into supervisory processes, along with continued efforts to enhance supervisory convergence and operational resilience across the EU.

Repeal of guidelines

The Follow-up Report states that, due to the introduction of DORA and a recommendation in the 2022 Report, the ICT SREP guidelines will be repealed and integrated into the upcoming revised SREP guidelines to ensure consistency and to foster simplification.

The upcoming revised SREP guidelines will integrate the DORA framework and reflect changes stemming from CRD IV / CRR III, ensuring ICT risk is fully embedded in the supervisory framework and explicitly included within operational risk.

On 23 February 2026, the European Securities and Markets Authority (“ESMA”) announced that it has withdrawn its guidelines on the MiFID II / MiFIR obligations on market data (“Guidelines”), which had been applicable since 1 January 2022. This withdrawal of the Guidelines is effective immediately.

The Guidelines addressed obligations under  MiFID II and MiFIR to make pre-trade and post-trade data available on a reasonable commercial basis.

The Guidelines have been withdrawn on foot of a decision (“Decision”) of the ESMA Board of Supervisors (“BoS”) of 23 February 2026. The Decision explains that the ESMA BoS came to this decision as the clarifications provided by the Guidelines on market data have now been incorporated into Commission Delegated Regulation (EU) 2025/1156 of 12 June 2025, which came into force on 23 November 2025 – for more information, see FIG Top 5 at 5 dated 13 November 2025.

ESMA has stated that the withdrawal of the Guidelines reflects its commitment to simplification of rules and the reduction of compliance burdens.