02/03/2026
Insights Blog

The Central Bank of Ireland’s (CBI) Regulatory & Supervisory Outlook Report 2026 (the Report) is published at a time of accelerating change. Geopolitical fragmentation, macro-financial uncertainty, rapid technological transformation, and evolving consumer expectations are reshaping the financial system and the risks it faces. Despite Ireland’s financial sector showing resilience, the CBI is clear that there is “no cause for complacency”, emphasising that firms must keep pace with a complex external environment and that resilience, adaptability, and trustworthiness must be central to their response.

The Report identifies ten key risk areas across three broad themes:

  • macroeconomic and geopolitical risks, covering operational, cyber and financial risks;
  • risks arising from how firms are responding to change, including consumer detriment, data, AI, financial crime and risk management; and
  • longer-term structural forces, including climate risk, and business model and strategic risks.

Operational risks remain at an elevated level, and asset valuation and market risks have increased, as have the risks associated with data, models and AI.

The CBI’s five supervisory priorities for 2026 are:

  • maintaining and building resilience to geopolitical and macro-financial risks;
  • securing consumer and investor interests;
  • responding to technology-driven transformation, including AI, digital money and tokenisation;
  • addressing environmental and societal transitions; and
  • enhancing how the CBI regulates and supervises.

There is new supervisory focus on AI, digital money, tokenisation, and crypto-asset service providers (CASPs) under MiCA. Cyber resilience is elevated via DORA implementation, while climate risk expands to broader environmental and societal transitions. Additionally, IAF is fully embedded, reinforcing governance and personal responsibility. Other notable points include:

Banks

The sector is evolving rapidly, driven by digitalisation, innovation and increased competition. Supervisory focus includes how banks navigate their business model and strategy (including the impact of Article 21c of CRD VI), treatment of customers, financial resilience and financial crime.

Payment and E-Money Firms

Also evolving rapidly, particularly in the crypto-asset space, with challenges around business model viability and strategy. Supervisory focus includes safeguarding arrangements (noting the new PCF Head of Safeguarding role), financial crime, business models and wind down plans, and culture, governance and risk management, with emphasis on promoting a consumer-focused approach.

Retail Credit Firms

Firms are operating in an increasingly complex, interconnected environment. Supervisory focus will be on the treatment of customers, short term lending practices and their impact on over-indebtedness, and how firms navigate business model viability and strategy.

Credit Unions

Recent legislative and regulatory change is facilitating sector growth, which must be matched by a maturation in operational, organisational and risk management capabilities. Supervisory focus will be on financial resilience, development of a coordinated sector strategy for growth, and culture, governance and risk management.

Insurance and Reinsurance

Firms are operating in a challenging macroeconomic and geopolitical environment while preparing for significant legislative change, including the Solvency II reforms and the Insurance Recovery and Resolution Directive (IRRD). Supervisory focus will be on the treatment of customers, financial resilience, digitalisation and AI, and climate and sustainability risks.

Securities Markets

The sector faces increased uncertainty and geopolitical risk. CASPs represent a new regulated category with elevated consumer protection, safeguarding and financial crime risks. Supervisory focus includes the treatment of customers (particularly in relation to crypto), custody of crypto-assets, financial crime, market abuse and surveillance, conflicts of interest and controls, and AI.

Investment Firms

A diverse sector in terms of products, services and the size and scale of firms. Supervisory focus includes conflicts of interest, treatment of investors, AI, and financial crime. The CBI will also assess governance, risk management and culture, and the 2025 priorities of financial resilience and safeguarding.

Retail Intermediaries

Firms play a key client-facing distribution role. Supervisory focus includes the treatment of customers, risks of unregulated products and services, commission and remuneration arrangements, and the impact of ongoing M&A activity.

For an analysis on how the Report relates to the Funds sector, please see our insights post: Central Bank’s Regulatory & Supervisory Outlook 2026: Funds Sector Impact

Legal and regulatory backdrop

Key regulatory initiatives include: the continued roll out of the AML legislative package; the AI Act (with the CBI designated as the Market Surveillance Authority for high-risk AI use cases in financial services); Basel III/CRR III/CRD VI; the revised Consumer Protection Code (effective 24 March 2026); the upcoming review of the PCF framework; the review of the Corporate Governance Codes, and Solvency II and IRRD planning.

Overall, the Report signals an intensifying supervisory environment across multiple fronts. Firms are expected to maintain strong governance, risk management and operational resilience, and to act in the best interests of customers. To discuss the Report in more detail, please get in touch with your usual contact in our Financial Regulation and Asset Management and Investment Funds groups.