Asset Management & Investment Funds: Irish Practice Developments – December 2025

Some annual compliance deadlines

31 December 2025 - Individual Accountability Framework - RFSPs should provide appropriate training on an ongoing basis to ensure that individuals are clear on their obligations in respect of the conduct standards and specifically what is expected of them in the context of their role. Firms should evidence that individuals have completed the relevant training and maintain up to date records.

31 December 2025 - Corporate Governance - 2025 reviews of board and individual director performance and matters reserved to the board should be completed by year end. Once every three years a formal documented review and a review of the chairperson must take place. Director time commitments and confirmation of other directorships as well as compliance with procedures for dealing with conflicts of interest and terms of reference of any board committees should be reviewed at least on an annual basis.

31 December 2025 - Anti-money laundering/combatting the financing of terrorism - Designated persons should offer training to their boards on the law relating to AML/CFT on an annual basis (and at such other times as may be appropriate). The annual review of AML/CFT policies, including AML/CFT business risk assessments should be completed and an AML/CFT report considered.

1 January 2026 - Fitness & Probity - The annual pre-approval controlled functions (PCF) confirmation return submission facility will likely be available on the Central Bank of Ireland (CBI) portal from 1 January 2026. PCF annual confirmation and CF certification guidance was last updated in December 2024.   

31 January 2026 - UCITS ManCo, AIFM ownership confirmation - UCITS ManCos and AIFMs must file their annual ownership confirmation by 31 January 2026, as discussed here for UCITS ManCos and here for AIFMs.

17 February 2026 - UCITS KIID/PRIIPs KID - All UCITS made available to "retail investors" in the EEA are required to provide such investors with a PRIIPs KID prior to their investment. A UCITS which is not made available to retail investors in the EEA is not obliged to provide a PRIIPs KID and may continue to produce a UCITS KID. A UCITS producing a UCITS KIID must update its KIID on an annual basis for each sub-fund/standalone fund within 35 business days of the end of each calendar year. The annual update of the UCITS KIID must be filed with the CBI. Unlike the UCITS KIID, there is no annual refresh deadline for the PRIIPs KID. The PRIIPs KID must be reviewed regularly and revised when there is a significant change, and at least annually. PRIIPs KIDs (and PRIIPs KID updates) must also be filed with the CBI.

28 February 2026 (expected deadline) - Fund profile return - The annual CBI fund profile return is required for all Irish authorised sub-funds. It is to be prepared for the period up to 31 December 2025, with an anticipated submission deadline of 28 February 2026. The CBI updated its Guidance for Fund Profile Return Vol 2.3 May 2025 in May 2025.

31 March 2026 - ICCL Report - For the purposes of the Investor Compensation Company DAC’s compensation scheme, authorised UCITS/AIFM management companies authorised to perform individual portfolio management are required to file the ICCL report.

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

Other key dates

1 January 2026 - EU Benchmarks Regulation - Regulation (EU) 2025/914 amending the Benchmarks Regulation applies. The scope of the existing regime will be significantly reduced so that only those fund management companies and corporate funds which use benchmarks deemed “critical” or “significant” under the new framework, EU Paris-aligned benchmarks, EU Climate Transition benchmarks and certain commodity benchmarks will be in-scope. Fund management companies and corporate funds which “use” (as defined) benchmarks will need to review their use of benchmarks (including ensuring that any relevant benchmark is officially approved for use by checking the ESMA Register), decide whether any updates are required to prospectus disclosures and ensure that contingency plans are up to date.

1 January 2026 - Updated AEOI individual and entity SRS and FATCA self certification forms - Updated AEOI individual and entity SRS and FATCA self certification forms (see below) should be used from 1 January 2026 with first reporting to Revenue being 30 June 2027. 

Q1 2026 - European Commission consultations aimed at EU growth capital fund managers - Consultations (discussed below) are expected to issue.

2 February 2026 - IOSCO consultation on updated recommendations on valuing collective investment schemes - Consultation closes on 2 February 2026.

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.

24 March 2026 - Consumer Protection Code - The CBI’s revised Consumer Protection Code (incorporating Business Standards Regulations) begins to apply.

April 2026 - AIFMD II - Irish authorised UCITS management companies and Irish authorised AIFMs may want to consider the additional permissions which will be available, subject to the prior approval of the CBI, from April 2026 in the context of their existing and proposed business lines, discussed here.

16 April 2026 - AIFMD II - Deadline for the transposition of the majority of AIFMD II provisions into national law.

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.

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.

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.

2 July 2026 - ESG Ratings - The 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.

CBI timeframes for applications with a year-end effective date

Read here for CBI timeframes for receipt of applications that are seeking a Christmas or year-end effective date.

Fitness and Probity

The CBI published Guidance on the Standards of Fitness and Probity 2025 (revised guidance) alongside a feedback statement following its April 2025 consultation. The public consultation responded to recommendations by Mr Andrea Enria, former Chair of the European Central Bank’s Supervisory Board, following his independent review of the CBI’s F&P assessment process to assess its transparency, efficiency and effectiveness (see our previous client insight). The draft guidance and proposed changes to the PCF list addressed several recommendations calling for increased clarity and transparency of supervisory expectations in relation to the F&P assessment process. 

The revised guidance came into effect on 25 November 2025 and consolidates existing CBI F&P guidance and correspondence (including FAQs) and implements targeted enhancements in a broad range of areas, such as:

• inherent responsibilities
• board independence
• knowledge and experience
• time commitments
• job sharing
• conflicts of interest
• role of company secretary as CF-1
• expectations for PCF-52 (Head of AML/CFT)

The CBI also implemented a small number of changes to the list of prescribed PCFs, including the removal of PCF-24 (Head of Traded Markets) and PCF-25 (Head of International Primary Markets).

The CBI has indicated that it will conduct a more substantive review of the PCF list to coincide with its planned review of SEAR in 2027 to make the PCF list clearer and more manageable for firms.

The Fitness and Probity Standards have also been updated to a November 2025 version, which consolidates the previous Fitness and Probity Standards 2023 and the Fitness and Probity Standards for Credit Unions 2024 into one set of standards, without making substantive changes to the text.

Read more about the revised F&P Guidance here.

CBI guidance notes for the daily investment fund return

The CBI published updated Guidance Notes for the Daily Investment Fund Return (DIFR).

This reporting requirement applies to every Irish-resident non-money market investment fund (all trading frequencies including ad-hoc) that issues its own shares/units/interests, has a non-zero net asset value and is authorised by the CBI. Money market funds are out of scope for this return and continue to report the daily money market fund return.

See also information on the new IF & MMF return here.

Updated AEOI individual & entity SRS and FATCA self certification forms

The Irish Funds AEOI working group has updated the Irish Funds individual and entity self-certification forms to reflect changes under CRS 2.0, effective from 1 January 2026. These revised forms act as industry templates for Irish financial institutions to meet local AEOI account-opening due diligence requirements and should be used from 1 January 2026.

Please speak with your usual contact on our  Asset Management & Investment Funds team for more information.

CBI Markets Update

The CBI published Issue 7 2025 of its Markets Update, covering:

• The EU T+1 Industry Committee has launched a comprehensive survey to assess progress on High-Level Roadmap
• The EBA calls on counterparties to seek authorisation for initial margin model based on ISDA SIMM
• Commission Notice re European Green Bonds

AML/CFT/FS - CBI financial crime bulletin

The CBI published the first edition of its biannual financial crime bulletin with key regulatory developments in AML/CFT/FS, and fraud.

This year, CBI moved to an integrated supervisory approach where CBI consider risks and supervisory activities more holistically. This is also true for financial crime risks where CBI consider AML/CFT/FS and fraud across the financial system and how best to address them.

At European level, AMLA is now operational, work is continuing to implement the EU AML Package, and MiCAR entered full force.

In this bulletin, CBI provide updates on the following:

• Risk assessment
• Crypto and payments
• Fraud and scams
• Financial sanctions
• EU AML developments

 Some points of interest for funds and fund service providers are detailed below.

 Risk assessment

• CBI’s sectoral and firm specific risk assessment. The CBI identifies and assesses money laundering/terrorist financing/proliferation financing (ML/TF/PF) risks across all sectors and firms within its AML/CFT regulatory population. CBI considers inherent risks (threats/vulnerabilities) and mitigation measures (controls) to arrive at a residual risk score for each sector and each individual firm. This rating then drives the level and extent of supervisory activity on a given sector/firm (along with trigger events and intelligence).
• CBI Risk Evaluation Questionnaires (REQs). The CBI is replacing the current AML/CFT REQ. Revised REQs have been introduced for credit institutions and payment institutions/electronic money institutions. Further sector specific REQs will be introduced between now and early-2027. The updated REQs will inform CBI decision-making and supervisory strategy both at firm and sector level, will assist in identifying emerging and thematic trends and will meet new EU AML/CFT requirements.
• Monitoring and review of risk assessments. A firm must apply its business risk assessment when determining the extent of customer due diligence required for a particular customer or transaction. Firms need to have an up-to-date understanding of a customer’s business and professional activities. Significant changes to customer activity and behaviour should prompt further review of the customer’s business and professional activities to ensure that the firm has a comprehensive understanding of that customer and any potential ML/TF risks that it may present.

Crypto and payments

To date, six firms have been authorised as Crypto Asset Service Providers (CASPs) by the CBI, with more anticipated in the coming months. The EBA provides guidance to regulated firms on risks to consider when engaging in a business relationship with a CASP or otherwise exposed to crypto assets.

Fraud and scams

It is a priority for the CBI that measures are taken to prevent fraud and scams occurring through the financial system.

Financial sanctions

The CBI referenced the EBA Guidelines on internal policies, procedures and controls to ensure the implementation of EU and national restrictive measures (addressed to all institutions within the EBA’s supervisory remit), effective 30 December 2025 and the value of a restrictive measures exposure assessment.

The measures to comply with EU and national restrictive measures may be part of future CBI supervisory engagements.

Thematic review of financial sanctions screening system. The CBI assessed the efficacy of financial sanctions screening systems of 40 firms across a wide range of sectors in a thematic review completed in 2024. Some of the key findings included:

• While all firms had client screening systems, just under half of those sampled did not have transaction screening systems, which potentially exposes them to a greater risk of breaching sanctions requirements. In such cases, a firm needs to ensure that decision is subject to robust governance and clearly documented.
• Many firms’ screening systems were of a satisfactory standard in terms of identifying sanctioned names when undertaking customer and transaction screening. Some firms’ screening systems were well below a satisfactory standard. This highlights the importance of ongoing, regular and appropriate testing of systems to ensure they are operating effectively and to identify any areas for improvement. Additionally, where firms have outsourced their screening systems, they must ensure that they have appropriate oversight of the outsourced service providers and the screening tool.
• When the test data was manipulated to reflect common data quality issues, the effectiveness of customer and transaction screening systems decreased. This highlights the need to test and assess the effectiveness of fuzzy logic rules on an ongoing basis. Where an issue (or a breach of EU sanctions) arises, immediate action should be taken to address it.
• Firms should identify and assess which areas of their business are particularly vulnerable or exposed to restrictive measures and to potential circumvention of restrictive measures. On this basis, they should put in place, implement and maintain up-to-date policies, procedures and controls to ensure that they can comply effectively with restrictive measures regimes. Sanction compliance policies, procedures and controls should be effective and proportionate to the size, nature and complexity of the financial institution, and to its restrictive measures exposure. These policies should be kept under regular review by each firm. There may be significant risk in relying solely on third-party schemes or networks to manage sanctions risks. Ultimate responsibility for compliance with EU sanctions rests fully with EU institutions. Institution-specific controls and due diligence are essential to ensure that no funds or financial services are provided, directly or indirectly, to designated persons or entities.

EU AML package

In advance of the AML package implementation deadline of mid-2027, firms should familiarise themselves with the AMLR, to ensure they are in a position to successfully implement the required changes once the AMLR becomes applicable. In terms of delivering on the necessary regulatory technical standards, implementing standards and guidelines, AMLA’s priorities include guidelines on minimum requirements on business-wide risk assessment (Article 10(4) AMLR.

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

Date published: 16 December 2025