The Central Bank of Ireland (CBI) is consulting on a new, more structured framework for assessing the impact of its regulatory actions. The public consultation (CP170), covers both a draft Statement of Approach to Regulatory Impact Assessment (RIA) and a revised approach to public consultation.

The consultation forms part of the CBI’s ongoing work to deliver a more effective and efficient regulatory framework, building on its evolving supervisory approach and roadmap of regulatory initiatives.

 Draft Statement of Approach to RIA

The RIA element sets out how the CBI proposes to assess regulatory interventions, including identifying the problem being addressed, considering available options and evaluating the likely impact of those options. This includes consideration of costs, benefits, risks, proportionality, implementation issues and impacts on consumers, firms and the wider financial system.

When will RIA apply?

 The framework applies where the CBI exercises meaningful national discretion in developing domestic regulatory policy, particularly where the CBI has a genuine policy choice in the design, calibration or implementation of measures that may have material impacts on firms, consumers, customers, market functioning or financial stability.

The framework will not apply in cases where the CBI has no substantive policy discretion (e.g. when implementing binding EU requirements), or in firm-specific supervisory or enforcement actions. It also does not apply to measures that simply restate or clarify existing obligations, or to routine supervisory communications that do not introduce new policy requirements.

Core principles

When an RIA applies, the CBI will assess proposals through a consistent set of principles:

The draft RIA framework also emphasises the importance of clearly defining the baseline (i.e. what would happen in the absence of intervention) and, where appropriate, considering alternative policy options. This is intended to ensure that regulatory action is necessary and proportionate, and that different approaches to achieving the same objective are assessed in a structured way.

 A refreshed consultation approach

 Alongside the draft RIA framework, CP170 sets out a refreshed approach to how the CBI consults.

Key practical points for firms include:

• a standard consultation period of 12 weeks, and where a shorter period is appropriate, the CBI expects this to be no less than 8 weeks, unless specific circumstances require otherwise
• commitment to proportionate, accessible and inclusive consultation design including publication of materials in accessible, clear and structured formats and engagement beyond formal written channels (e.g. workshops and webinars)
• use of consistent consultation coding framework to analyse submissions and feedback, supporting the consistent treatment of feedback and helping to reduce the risk of unconscious bias
• publication of a feedback statement following each consultation to support transparency and accountability. A feedback statement may summarise the key issues raised, set out the CBI’s response and explain how feedback has informed the outcome

 Stronger link between consultation and impact assessment

 A key theme of CP170 is the interdependence between RIA and consultation:

• Consultation is expected to inform the evidence base for impact assessment, including identifying costs and benefits, providing insights into how stakeholders may be affected, and highlighting alternative approaches
• RIA is intended to frame consultations, clarifying the problem, the policy options and the potential impacts under consideration.

The CBI is seeking to ensure that both processes operate in a more coherent and integrated way, supporting more informed stakeholder engagement and policy design.

 What does this mean for firms?

While the proposals do not introduce new regulatory requirements or amend existing rules, they signal a more disciplined and transparent approach to policymaking which is likely to have practical implications:

• More structured consultation materials
• Standardised consultation timelines provide greater predictability for planning internal review and sign-off
• Greater opportunity for evidence-based submissions, particularly on costs, operational impacts and unintended consequences
• Earlier engagement in the policy process, as impact assessment is intended to be integrated from the outset of policy development.

Next steps

The CBI is seeking feedback from all interested parties by 30 September 2026. The CBI will publish a feedback statement after considering all submissions.

Our Financial Regulation Group and Asset Management and Investment Funds Group would be happy to assist clients in preparing a response or to discuss the implications of these proposals for your business. Please reach out to a member of our Financial Regulation or Asset Management and Investment Funds Group or your usual Arthur Cox contact.