Page Contents
Deadlines
Domestic
Related areas
Some annual compliance deadlines
20 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 Central Bank of Ireland (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 - Fitness & Probity - The annual PCF confirmation return submission facility is available on the CBI portal from 1 January 2026 until 28 February 2026. PCF annual confirmation and CF certification guidance was last updated in December 2024.
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.
31 May 2026 - 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 a submission deadline of 31 May 2026. The CBI updated its Guidance for Fund Profile Return Vol 2.3 May 2025 in May 2025. Confirmation of commencement of new fund metadata return pending.
The above list does not cover all compliance deadlines. Reporting obligations may vary on a firm-by-firm basis.
Other key dates
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.
12 March 2026 - Consultation on EU Venture Capital and Growth Capital Funds Reform - European Commission consultation closes.
24 March 2026 - Consumer Protection Code - The CBI’s revised Consumer Protection Code (incorporating Business Standards Regulations) begins to apply.
Q1 2026 - Tokenisation - The CBI’s is expected to publish a discussion paper.
16 April 2026 - AIFMD II - Deadline for the transposition of the majority of AIFMD II provisions into national law.
16 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. AIFM’s managing loan originating AIFs must update their AIFM authorisation by this date.
16 April 2026 - AIFMD II - Date of application of ESMA’s regulatory technical standards and guidelines on liquidity management tools for UCITS and open-ended AIFs (further information in December update).
6 May 2026 - Call for evidence and consultation on the evaluation and review of the Shareholder Rights Directive - Closes on 6 May 2026.
8 May 2026 - Consultations on draft RTS’ for implementation of the new European AML/CFT package - Closes on 8 May 2026 (other than draft RTS on pecuniary sanctions which closes on 9 March 2026).
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.
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 streamlined authorisation process for AIFMs managing loan originating AIFs
The CBI has introduced a streamlined authorisation process for Irish alternative investment fund managers (AIFMs) that manage AIFs that originate loans and will need approval to carry out the new loan origination function under AIFMD II. This follows the introduction of loan origination as a function that AIFMs can additionally perform under the revised Alternative Investment Managers Directive (AIFMD). The CBI’s process is designed to enable AIFMs engaging in loan origination to meet the requirements of AIFMD II by the implementation deadline of 16 April 2026.
By way of background, AIFMD II introduces a harmonised EU framework governing loan origination by AIFs and AIFMs. The new regime applies to AIFs that originate loans and imposes additional requirements on “loan originating AIFs” (LO AIFs) whose main strategy is lending or whose originated loans represent at least 50% of NAV.
AIFMs managing such funds, as well as those managing AIFs which intend to originate loans (but do not meet the criteria for LO AIFs) must implement effective policies, procedures and processes for the granting of loans, for assessing credit and for monitoring credit portfolios. A five-year transitional period will apply to certain product level rules, but AIFM authorisation must be in place by the 16 April 2026 deadline.
New authorisation requirement
Under AIFMD II, loan origination becomes an Annex I activity. As there are no grandfathering provisions, AIFMs currently managing loan-originating funds must update their AIFM permissions in order to continue performing this activity after April 2026.
The CBI notes that AIFMs managing loan origination qualifying investor AIFs (LO-QIAIFs) are already subject to high governance and oversight standards which are more prescriptive than those that will be in place following the introduction of AIFMD II and confirms that it will take a proportionate approach to enable such AIFMs to achieve authorisation to engage in this function by 16 April 2026.
CBI’s streamlined process
AIFMs seeking approval should submit an application to the fund service providers authorisations team as soon as possible. The submission should include:
Following receipt of the application, the CBI will engage with the AIFM on any queries concerning, with a view to authorising this additional function on 16 April 2026.
CBI consultation on prohibition notices under the Fitness and Probity regime
The CBI has published a consultation paper (CP166) seeking stakeholder feedback on new supplemental guidance on prohibition notices under the Fitness and Probity regime.
Under the Central Bank Reform Act 2010, the CBI may investigate individuals performing (or who previously performed) controlled function (CF) or pre-approval controlled function (PCF) roles. Following an investigation, an independent decision maker may issue a prohibition notice, restricting the individual from carrying out CF or PCF roles either permanently or for a defined period. The CBI may publish such notices.
The proposed guidance aims to provide additional clarity on the CBI’s approach to prohibition notices and should be read alongside the existing guidance on ‘Fitness and Probity, Investigations, Suspensions and Prohibitions’, published in 2023 following the introduction of the Central Bank (Individual Accountability Framework) Act 2023.
Key areas of clarification include:
The consultation closes for feedback on 25 March 2026.
CBI Markets Update
The CBI published Issue 1 of its Markets Update, covering:
For more information on these topics please contact any member of A&L Goodbody's Asset Management & Investment Funds team.
Date published: 24 February 2026