Asset Management & Investment Funds: Irish Practice Developments – April 2026

Forthcoming annual compliance deadlines

31 May 2026 - Fund metadata return - the Central Bank of Ireland (CBI) fund metadata return went live on the ONR portal on 24  April 2026, replacing the fund profile return (V3). From this date, Irish newly authorised funds are required to submit fund metadata via the new return. Existing funds must complete the annual fund metadata return, for the period up to 31 December 2025, by 31 May 2026. The CBI published new Guidance for the fund metadata return.

The above list does not cover all compliance deadlines. Reporting obligations may vary on a firm-by-firm basis.

Other key dates

2026 - ESMA CSA on MiFID II conflicts of interest requirements - ESMA (and NCAs) will carry out a CSA on MiFID II conflicts of interest in the distribution of financial instruments in 2026.

30 April 2026 - ESMA consultation on guarantees as CCP collateral and on certain aspects of CCP investment policy under EMIR - the deadline for responses is 30 April 2026.

6 May 2026 - Shareholder Rights Directive - deadline to respond to European Commission call for evidence and public consultation on the evaluation and review of the SRD. Read more here.

8 May 2026 - AMLA consultation on draft RTS on criteria for identifying business relationships, occasional and linked transactions and lower thresholds - deadline to respond to consultation.

8 May 2026 - AMLA consultation on draft RTS on customer due diligence - deadline to respond.

26 May 2026 - ESMA guidelines on stress test scenarios MMF Regulation - updated calibration sections of 2025 guidelines apply.

5 June 2026 - DLT & tokenisation - deadline to respond to CBI Discussion Paper 12 on the future role of DLT and tokenisation.

5 June 2026 - Market Abuse Regulation - changes made to the EU market abuse framework introduced under the EU Listing Act begin to apply. Funds with listed or traded securities should review and update their MAR compliance frameworks by this date.

15 June 2026 - AMLA consultation on draft RTS on group-wide minimum requirements and additional measures for subsidiaries and third country branches - deadline to respond to consultation.

30 June 2026 - SFDR PAI statement - fund management companies that are either in scope due to their size or that have opted into Article 4 SFDR reporting must publish their full PAI statement on their website, including year on year comparisons with the previous PAI report.

30 June 2026 - Gender balance on boards of certain listed companies - in-scope listed companies have until 30 June 2026 to satisfy specific gender quotas. Such companies will also have to report annually on their performance from 30 November 2026 as discussed here.

H1 2026 - Fund management company (FMC) delegation - the CBI is due to issue its initial communication in H1 2026 following its review of delegation practices of Irish authorised FMCs.

H1 2026 - CBI review of the Fund Service Provider (FSP) Framework - the CBI will launch a comprehensive review of the FSP Framework. This will include a review of the rules governing management companies and service providers and an update to delegation and outsourcing provisions.

H1 2026 - Hedge funds deep dive - CBI report, following its review of hedge fund firms, is due to issue in H1 2026.

H1 2026 - Liquidity management tool thematic review - CBI communication, following its liquidity management tool thematic review, is expected H1 2026.

2 July 2026 - ESG ratings - new EU ESG Ratings Provider regime begins to apply under which marketing communications referencing some ESG ratings will be required to include a weblink to detailed information relating to that ESG rating. Read more here and here.

15 July 2026 - AMLA consultation on draft guidelines on business-wide risk assessment - deadline to respond to consultation.

2 August 2026 - EU AI Act - core EU AI Act high-risk AI systems obligations and transparency rules apply.

H2 2026 - ESMA planned consultations - ESMA’s table of planned consultations for 2026, includes AIFMD and UCITS RTS and ITS on reporting, MiFIR, investor protection, the Listing Act, EMIR 3 and the CSDR review. H2 will also see consultations for the retail investment strategy - technical advice to the EC on investor protection topics (review of MiFID II delegated acts) as well as technical standards on investor protection.

CBI board effectiveness thematic review - diversity and inclusion

The CBI has published its feedback report on its thematic review of board effectiveness through the lens of diversity and inclusion (D&I) in the fund management company sector. While the review applies directly to UCITS management companies and AIFMs, the CBI has indicated that the findings are relevant more broadly across all regulated firms.

While the CBI has previously addressed elements of D&I, such as gender balance and independent non-executive director (INED) tenure in earlier thematic reviews of fund management company effectiveness, this is the first standalone, D&I focused assessment in the sector. The report reiterates that diversity of thought and inclusion, where differences are valued and integrated into board processes, are key components of board effectiveness and contribute to improved decision‑making, governance and oversight.

The CBI expects fund management companies, and regulated firms more generally to:

• review and consider the findings of the report
• assess governance frameworks through a D&I lens, benchmarked against the practices outlined
• address identified gaps or weaknesses
• keep arrangements under ongoing review to ensure they remain fit for purpose

Scope and overarching themes

The review examined board effectiveness across a range of governance processes, including board, senior management team (SMT) and committee composition (including the role of the organisational effectiveness director), INED appointments, board evaluations, strategic decision‑making, succession planning and broader D&I practices such as policies, reporting and training.

The CBI emphasises that diversity extends beyond any single characteristic and includes, among others gender, age, ethnicity and educational and professional background. Central to its analysis is diversity of thought and independence of mind, supported by inclusive practices that ensure different perspectives are actively considered in decision‑making.

While examples of good practices were identified, the CBI concluded that further enhancement is required across the sector, with varying levels of understanding and inconsistent embedding of D&I within governance frameworks.

Board, SMT and board committee composition

Good practices included boards and SMTs with diverse professional and educational backgrounds, structured integration of D&I considerations into governance frameworks, board D&I sponsorship and proactive recruitment measures to mitigate bias.

Weaker practices included a narrow focus on observable characteristics (particularly gender) without sufficient consideration of diversity of thought, gender imbalances, limited use of D&I metrics or targets and insufficient board‑level training, reporting or sponsorship.

Independent non‑executive directors (INEDs)

In most firms, INEDs acted as board chair, which the CBI considers consistent with good governance practice. However, the report highlights inconsistent approaches to the role and value of the independence of mind of INEDs.

Prolonged INED tenure, sometimes exceeding ten years, was observed. Where tenure is prolonged, the CBI expects annual, formal comprehensive assessments of independence and consideration of whether continued use of the INED designation remains appropriate.

Board evaluation

All firms reviewed conducted annual board evaluations, to varying degrees of detail. Good practices demonstrated a more structured and comprehensive approach using a board skills matrix with director self-assessments with supporting rationale and the inclusion of gender diversity within the matrix.

Weaker practices included over reliance on self‑assessment questionnaires without broader assessment of e.g. skills gaps and attendance, and D&I considerations, particularly inclusivity being absent from board evaluations.

Succession planning

Good practices included comprehensive succession plans with named successors, defined time horizons, detailed skills matrices, assessment of successor readiness, identification of which skills were missing within the skills matrix and (in one case) a named panel of potential INED successors.

Weaker practices included succession policies that lacked clarity on how succession plans influenced board and executive appointments, lack of D&I consideration (even in firms with diversity targets), outdated plans, poor version control and no assigned responsibility.

Strategic decision‑making

Good practices included diverse project teams advising the board, well documented strategic-decision procedures and clear minutes demonstrating challenge and discussion.

Weaker practices included:

• the absence of standalone decision‑making policies and documentation of the strategic decision-making process
• key decisions taken outside formal forums without clear summaries or records documented
• insufficient documentation of rationale or challenge
• minutes recording approvals without evidencing discussion, challenge or voting process
• limited use of formal post‑decision reviews or “lessons learned” exercises

Read more here.

CBI thematic review of outsourcing risk for fund administrators and depositaries

The CBI published a “Dear CEO” letter setting out the findings of its thematic inspection of outsourcing risk on fund administrators and depositaries, collectively referred to as FSPs.

The thematic inspection, conducted in 2025, assessed the outsourcing oversight frameworks established by FSPs taking into consideration the good practices for the effective management of outsourcing risk, as outlined in the CBI’s cross-industry guidance on outsourcing. For fund administrators, the review also considered the Outsourcing Regulations set out in Part 4 Chapter 2 of the Investment Firms Regulations 2023 and the CBI’s related guidance.

The inspection sought to assess FSPs’ governance, risk management, and operational processes across three key areas:

• Outsourcing lifecycle. Risk identification and assessment processes (including risk assessments, criticality assessments, due diligence, contracts and SLAs and outsourcing reporting e.g. KPIs and KRIs).
• Governance. Monitoring and reporting of outsourcing risks to the board and / or its committees and assessing the roles of compliance, risk and internal audit.
• Operational oversight. Management of day-to-day operational oversight of outsourced activities (e.g. NAV calculation and sub-custodian oversight).

The CBI found that deficiencies continue to exist in FSPs' outsourcing oversight frameworks. The letter sets out a number of non-exhaustive examples of observed good practices, including:

• establishment of dedicated outsourcing forums or committees
• appointment of a dedicated outsourcing manager
• formal second line of defence sign-off on outsourcing proposals and initial and ongoing risk assessments, as well as independent compliance due diligence and assurance testing
• defined internal outsourcing risk appetite limits and thresholds
• multi-layered risk metrics to monitor e.g. concentration risks, outsourcing incidents, outsourcing engagement, vendor performance and ongoing monitoring. Additionally, FSPs received performance self-certifications / attestations from OSPs
• due diligence and risk assessments completed periodically, on a proportional basis for all OSPs and outsourcing arrangements (not just those deemed critical or important). For depositaries, good practice included sample testing of due diligence reports of the sub-custody network and legal advice obtained and reviewed by network management
• for depositaries, recording prime brokers on outsourcing registers thereby applying the CBI’s cross-industry guidance on outsourcing to prime brokers
• for fund administrators, appropriate seniority of the checker and correct sequencing of reviews. Importance of automated maker-checker controls for NAV oversight

The CBI requires the letter to be brought to the attention of each FSP's board or management body. FSPs should review their existing outsourcing frameworks against the good practices identified and consider what enhancements may be required.

CBI financial stability assessments of the non-banking sector

Irish hedge funds

The CBI’s financial stability assessment of the Irish hedge funds sector, which manages approximately €400bn in assets, found that the sector is unlikely to pose systemic risk on its own, given its diversity and relatively limited market footprint in core global markets.

However, the analysis reveals vulnerabilities in certain hedge strategies that could generate financial stability risks, if correlated with hedge funds in other jurisdictions that follow similar strategies and have similar exposures. The CBI will engage with overseas authorities and strengthen surveillance to monitor evolving risks.

Availability and use of liquidity management tools by open-ended funds

A separate analysis of Irish domiciled open‑ended funds found that circa 85% now have at least one liquidity management tool (LMT) available, a significant increase over the last five years but actual use lags availability. The CBI has published good‑practice guidance (on incorporating implicit costs into the calibration of price-based LMTs to promote greater and more consistent deployment of LMTs and is shifting focus from policy design to implementation and enhanced supervision to bolster collective resilience.

Amendments to Irish MiFID client asset provisions

European Union (Markets in Financial Instruments) (Amendment) No.2) Regulations 2026 [S.I. No.81 of 2026] introduces targeted amendments to the European Union (Markets in Financial Instruments) Regulations 2017 (MiFID Regulations).

The changes address situations where third country laws prevent full compliance with Irish client asset segregation requirements and impose enhanced conditions and client disclosure obligations in those cases.

The amendments will apply from 31 August 2026.

Fitness and Probity

The High Court published its written judgment relating to the CBI’s application under the fitness and probity regime to confirm a one-year prohibition issued to a senior executive on 2 February 2022 concerning the individual’s role in a regulated firm in the investment fund and asset management sector. The High Court refused the application.

Under the fitness & probity regime, the CBI is required to apply to the High Court to confirm a prohibition if the individual concerned does not agree to comply with a prohibition notice imposed by the CBI. The application to the High Court was made in March 2022 and the matter was heard in December 2022. The parties were notified, on a confidential basis, of the court’s decision in May 2025.

The High Court found that the senior executive’s entitlement to natural and constitutional justice and basic fairness of procedures was not observed by the CBI in this case.

CBI markets update

The CBI published Issue 4 of its markets update, covering:

• ESMA publishes templates and instructions for Active Account Requirement (AAR) reporting (discussed in February bulletin here).
• ESMA Supervisory Briefing on Algorithmic Trading in the EU (discussed in March bulletin here).

For more information on these topics please contact any member of A&L Goodbody's Asset Management & Investment Funds team.

Date published: 30 April 2026