On 11 June 2026, the Central Bank of Ireland (CBI) published two significant reports: the Authorisations and Gatekeeping Report 2025 (Authorisations Report) and Fitness and Probity Review 2026 – Implementation Report (F&P Report), alongside a policy speech delivered by Deputy Governor Mary-Elizabeth McMunn.

Taken together, these publications underscore the continued evolution of the CBI’s gatekeeping framework and reinforce its central role in safeguarding key outcomes, including financial stability, the safety and soundness of firms, the protection of consumer and investor interests, and the integrity of the financial system.

The Authorisations Report provides a comprehensive overview of authorisation and F&P activity across all regulated sectors, while the F&P Report confirms the completion of the CBI’s significant reform programme. Across both publications, the CBI emphasises a more structured, transparent and outcomes-focussed approach to entry into the Irish financial system.

The reform backdrop

Both reports are grounded in Andrea Enria’s 2024 independent review of the F&P gatekeeping framework (the Enria Review).

Following an initial implementation phase in April 2025, the CBI has now confirmed that all twelve recommendations in the Enria Review have been fully implemented. These reforms reflect extensive engagement with industry and other stakeholders and have been met with a broadly positive response.

The firm and the individual: a unified standard

The two reports collectively address the dual dimensions of the CBI’s gatekeeping mandate: firm-level authorisation and individual-level pre-approval. Increasingly, the CBI is treating these as elements of a single, integrated framework, with consistent expectations applied across both.

Firm authorisation

The 2025 data reinforces a clear theme from the Deputy Governor’s speech: Ireland continues to strengthen its position as a leading European hub for international banking, insurance and asset management firms, while also growing in importance as a centre for fintech and payments.

Notable data points include:

• Strong growth in fund authorisations: 654 UCITS, 26 RIAIFs and six Retail ELTIFs were authorised in 2025, a 40% increase on 2024, along with 7 fund service providers
• Continued momentum in alternative funds: 281 QIAIFs and eight Professional ELTIFs were authorised in 2025, volumes 32% higher than 2024
• Renewed activity in the banking sector: 1 credit institution was authorised in 2025 – the first Irish domiciled authorisation since 2019
• Expansion in digital assets: as a new category of regulated entity, 10 Crypto Asset Service Providers were authorised in 2025 (8 of which were previously registered as Virtual Asset Service Providers). The report also highlights the CBI’s use of the Payment Institution (PI) authorisation process to assist firms navigate the interaction between MiCAR and PSD2
• Payments & Electronic Money Institutions: while 4 firms were authorised (down from 6 in 2024), average assessment timelines increased to 763 days (from 688 days), reflecting ongoing challenges including incomplete or low-quality applications, fundamental changes to business models mid-application and applicants pausing submissions.

Individual gatekeeping

The Enria Review has acted as a catalyst for significant change in the CBI’s approach to individual gatekeeping.

From January 2025, the CBI established a dedicated F&P Unit, creating a single centre of expertise with responsibility for all pre-approval assessments across sectors.

In parallel, the CBI introduced a Gatekeeping Decisions Committee (GDC), chaired by the Deputy Governor and operational from March 2025. The GDC provides senior oversight and independence in key gatekeeping decisions, particularly in relation to refusals. Its remit includes refusal of firm authorisation applications, involuntary revocation of authorisations, and opposition to acquiring transactions. Since its establishment, the GDC has considered three referrals, resulting in two authorisation refusals and one decision to involuntarily revoke a firm’s registration and authorisation.

Looking ahead, the F&P Report identifies the CBI’s ongoing review of pre-approval roles as a key priority for 2026, with proposed changes expected by year end.

Looking ahead: priorities for the future

The Deputy Governor highlights the following three priority areas:

• Centralisation of gatekeeping: building on the success of the F&P Unit, the CBI is further centralising its gatekeeping functions to enhance effectiveness and drive greater clarity, consistency and efficiency.
• Technology and data: continued investment in automation and AI to improve the efficiency, transparency and consistency of the authorisation process across sectors and products.
• Engagement with innovation: deepening understanding of innovation in the financial sector through its hub and sandbox, and through engagement with increasingly innovative business models at the point of entry.

Taken together, the reports and policy speech point to a more integrated and consistent gatekeeping regime, where firms can expect increased scrutiny on governance, risk management and substance at authorisation stage, complemented by deeper and more standardised assessment of senior individuals.

We have extensive experience advising clients across all sectors of the Central Bank’s authorisation process, from initial application through to ongoing regulatory compliance once established. If you require further information, please contact a member of the Financial Regulation Group, Asset Management and Investment Funds Group or your usual Arthur Cox contact.