12/12/2025
Insights Blog

Background to the Report

On 10 December 2025 the Central Bank of Ireland (CBI) published its roadmap to deliver a more effective and efficient regulatory and supervisory framework.

The initiative, set out in the report Regulating & Supervising well, responds to the increased European focus on competitiveness and simplification, and aims to reduce complexity and regulatory burden, while maintaining robust standards for the Irish financial sector.

Simplification and its Guardrails

The CBI has outlined their view of what simplification means, is engaging with it in a measured way and will use the following guardrails to guide its approach:

  1. Mission First – while some measures will involve compromises, e.g. simplicity vs precision; flexibility vs certainty, the CBI’s mission and safeguarding mandates remain paramount.
  2. Proportionality and Materiality – regulatory burdens should match the scale and risk profile of activities.
  3. Evidence-Based Change – decisions will rely on data, supervisory insights, and cost-benefit analysis.
  4. European Harmonisation – domestic rules should align with the Single Market unless divergence is justified.
  5. Implementation Before Legislation – existing rules should be simplified and applied before new rules are introduced.
  6. Clarity and Transparency – stakeholders must clearly understand the approach.
  7. Adaptability and Supervisory Judgement – regulation must evolve with markets and risks.

The Roadmap

The report sets out a multi-year programme for improvement across the areas of supervision, regulation, gatekeeping, and reporting, with a timeframe spanning from H1 2026 to H1 2028.

Supervision 

Regulation

  • Insurance:
    • Compatibility review of domestic instruments to eliminate duplication with Solvency II reforms and identify opportunities for consolidation (early outputs by H1 2026).
    • 2021 Recovery Planning Regulations to be reviewed in light of the EU Insurance Recovery and Resolution Directive (H1 2027).
  • Banking:
    • Review of legacy codes and policies to check for consistency and continued relevance. Obsolete and unnecessary provisions to be merged or retired (H1 2027).
    • Enhancements to Section 149 processes (fees and charges) (H2 2026).
    • Updates to the Credit Union Handbook and Guidance (H2 2026).
    • Streamlining and harmonisation of resolution reporting (H2 2027).
  • Funds:
    • Changes to the AIF rulebook and UCITS regulation to reduce undue barriers while aligning more closely with the updated EU funds framework.
    • A comprehensive review of the Fund Service Provider (FSP) Framework, which includes AIFMs and UCITS management companies (H1 2026). The review will ensure that the framework remains robust and relevant in a post-AIFMD II environment and will:
      • review the rules governing management companies and service providers, ensuring they reflect the structures and risk profiles of today’s funds industry;
      • update delegation and outsourcing provisions to reflect AIFMD II and EU guidance, balancing operational flexibility with effective oversight; and
      • streamline and consolidate domestic regulations, guidance, and Q&As, reducing duplication and improving consistency (H2 2028).
  • Cross-Sectoral Initiatives:
    • Corporate Governance Codes to be reviewed and revised (H2 2026), with publication of updated texts targeted for H1 2027.
    • SEAR review to be completed by H1 2027.
    • Cross-Industry Guidance on Outsourcing to be updated for clarity, flexibility and to remove duplication (H2 2026).
    • Domestic AML/CFT framework to be reviewed in light of the new EU AML Regulation. Obsolete provisions will be retired (H2 2027).
    • Public consultation on a new Regulatory Impact Assessment (RIA) Framework (H1 2026).
    • Issuance of a modernised and harmonised domestic framework in respect of the Transparency Directive (H1 2027).

Gatekeeping

  • Establishment of a Gatekeeping Division to promote clarity, consistency and efficiency across the CBI’s gatekeeping work.
  • Enhancement of the F&P system, including the establishment of a dedicated F&P Unit (H2 2027).
  • Review of Pre-Approval Controlled Function (PCF) framework (H2 2026).
  • Modernisation of authorisation processes for funds, intermediaries, prospectuses, insurance companies and other market participants (H2 2026).
  • Further measures to increase transparency on timelines and expectations.

Reporting and Data

  • Consolidation of new reporting requests to avoid duplication.
  • Review of existing data collections, merging or retiring reports, maximising the re-use of existing data and making targeted enhancements to existing returns (H2 2026). This will align with the European ‘collect once, use many times’ approach to data reporting.
  • Implementation of “discipline-by-design” tests for new reporting requests, testing necessity, proportionality and potential for re-use (H2 2026).

Key Takeaways

The CBI’s report is clear that this initiative is not about lowering standards. Rather, the engagement with the simplification agenda seeks to enhance the quality of regulation and supervision for the financial services sector in Ireland.

Success will mean a regulatory framework that is easier to navigate, proportionate, risk-based, harmonised, and able to respond to evolving market conditions and emerging risks. Most importantly for the CBI however, it will also be one that continues to ensure resilience and deliver on the CBI’s safeguarding mandates.