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

Some annual compliance deadlines

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.

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 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.   

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. Confirmation of commencement of new fund metadata return pending.

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.

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.

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

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 - 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).

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 roadmap to a more effective and efficient regulatory and supervisory framework

The CBI published a roadmap setting out how it will enhance the effectiveness and efficiency of its supervision and the domestic regulatory framework, improve gatekeeping processes, and deliver a more integrated and less burdensome reporting and data framework, without compromising resilience or protections. The CBI’s roadmap aligns with European competitiveness and simplification initiatives.

The CBI’s decision making on simplification will proceed with the following guardrails:

• No compromise of CBI’s mission and safeguarding outcomes of financial stability, consumer and investor protection, safety and soundness, and system integrity.
• Proportionality and materiality whereby regulatory burdens should align with the scale, complexity, and risk profile of the activity.
• Evidence-based change, relying on data, supervisory insights, and cost-benefit analysis.
• EU harmonisation and convergence whereby domestic regulations should align with the single market and divergence only if the risk landscape or statutory mandate requires.
• Simplify application and supervision of existing rules before amending legislation.
• Clarity and transparency on what’s changed, what remains the same, and why.
• Adaptability and supervisory judgment. Regulation and supervision should adapt to evolving markets, and supervisors and firms must be able to respond to emerging risks.

Supervision

The CBI will continue to refine and deliver on its integrated approach to supervision introduced in January 2025.

Funds regulation

• update AIF rulebook and UCITS regulation to reduce undue barriers and align with AIFMD II
• comprehensive review of the fund service provider framework (H1 2026 to H2 2027)
• review rules governing fund management companies and service providers, ensuring they reflect current funds industry structures and risk profiles
• update delegation and outsourcing provisions to reflect AIFMD II and EU guidance, balancing operational flexibility with effective oversight
• streamline and consolidate domestic regulations, and Q&As, reducing duplication and improving consistency (H1 2028)
• SEAR three-year review, including scope (H1 2027)
• updating cross-industry guidance on outsourcing to make expectations clearer and remove duplication where EU requirements apply (H2 2026)
• retire domestic AML/CFT publications (e.g. AML guidelines and ‘Dear CEO Letters’) that will no longer be applicable or relevant in light of the new EU AML Regulation (H2 2027)
• consult on new Regulatory Impact Assessment (RIA) Framework (H1 2026)
• implement streamlined authorisation processes (H2 2026)

Gatekeeping

• establishing a gatekeeping division (including authorisations)
• review pre-approval controlled function (PCF) framework to align with SEAR review in 2027 (H2 2026)
• improved technology, systems, and processes for authorisations
• further standardisation of authorisation processes (H2 2026)
• continue to increase transparency on timelines and expectations

Reporting and data

• improve internal governance for data collections
• consolidate new reporting requests to avoid duplication
• further integrate approach to data to be more effective, efficient and streamlined
• comprehensive review of data collections using “discipline-by-design” approach

CBI thematic review of operational resilience in MiFID investment firms

The CBI published the results of its thematic review of operational resilience in MiFID investment firms. The review assessed whether firms:

1. Have operational resilience frameworks aligned with the CBI’s Cross Industry Guidance on Operational Resilience (guidance).
2. Can demonstrate board and senior management accountability for the design and operating effectiveness of operational resilience frameworks and strategy.

While the CBI noted a maturing of operational resilience frameworks, it identified varying degrees of maturity across firms’ frameworks. Enhancements are required in relation to some firms identifying their critical or important business services and mapping of how their critical or important business services are delivered. There were also instances where firms’ operational resilience frameworks were not aligned with existing risk management frameworks.

The CBI expects all MiFID investment firms and their boards and senior management to revisit the guidance to consider their adherence to it, including DORA updates, with particular focus on:

• Guideline 4 - A firm should identify its critical or important business services.
• Guideline 7 - A firm should understand and map out how its critical or important business services are delivered.
• Guideline 8 - A firm should capture third party dependencies in the mapping of critical or important business services.

Read more here.

CBI portal enhancements to cross-border distribution of funds passporting functionality

The CBI has updated cross-border distribution of funds (CBDF) passporting functionality on the CBI portal and published updated guidance on submitting applications. Updates include a new section to capture share class information, a revised layout of the common document upload page, and amendments to the process for issuing and receiving acknowledgement messages. The CBI also hosted online workshops.

CBI speech on themes for a time of change: Gerry Cross, Director of Capital Markets & Funds

Gerry Cross, Director of Capital Markets & Funds at the CBI, outlined the CBI’s regulatory priorities, emphasising that the CBI is a risk-based, outcomes-focused regulator continuing to ensure it can continue to ever more effectively deliver in a changing world. Key themes relevant for compliance professionals and regulators:

• securing Customers’ Interests and revised Consumer Protection Code (CPC), effective 24 March 2026
• Individual Accountability Framework (IAF)
• simplification agenda (supervision, reporting, regulation and gatekeeping) linked to EU priorities as highlighted in the Draghi and Letta reports on innovation and productivity
• operational and financial resilience (including DORA and MiFID operational resilience review findings)
• leveraging technology and AI governance
• CBI’s revised supervisory approach with 2025-2026 rollout

CBI Markets Update

The CBI published Issue 8 of its Markets Update, covering:

• Postponement of EMIR 3.0 December reporting. On 11 December ESMA issued a statement that it is expected that the first reporting under Article 7d of EMIR (reporting of clearing activity at recognised third-country CCPs) on 2025 data will be submitted together with the 2026 reporting cycle, following the implementation of the necessary Level 2 measures.  The CBI will align its expectations with ESMA and the other EU NCAs.

The CBI published Issue 9 of its Markets Update, covering:

• Notice of Intention: Amendments to the Central Bank (Investment Market Conduct) Rules 2019

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

Date published: 27 January 2026