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

Key deadlines

5 August 2025 - EU list of third countries with strategic deficiencies in their AML/CFT regimes - Updated EU list of third countries with strategic deficiencies in their AML/CFT regimes is effective from 5 August 2025.

H2 2025 - Liquidity management tools (LMTs) available to AIFMs managing open-ended AIFs and to UCITS – The European Commission must decide whether or not to adopt ESMA’s draft Regulatory Technical Standards (RTS) on LMTs by 15 August 2025 as discussed here. The draft RTS provide that the RTS shall enter into force on the twentieth day following publication in the Official Journal of the European Union. ESMA will translate its accompanying guidelines after the adoption of the draft RTS by the European Commission. The guidelines will apply from the date of entry into force of the RTS. Funds existing before the entry into force of the RTS will have twelve months to comply with the guidelines.

18 September 2025 - Financial transaction reporting - ESMA’s  call for evidence on a comprehensive approach for the simplification of financial transaction reporting (primarily MiFIR, EMIR, SFTR) closes.

21 September 2025 - Financial transaction reporting - ESMA’s discussion paper (primarily AIFMD and the UCITS Directive) requests feedback on the approaches presented in the discussion paper until 21 September 2025.

Q4 2025 - Beneficial ownership register for certain financial vehicles (CFV) - The CBI is progressing a project to implement a new reporting mechanism from Q4 2025, simplifying and enhancing the means through which the beneficial ownership details of CFV are reported to the CBI central register.

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. If they fail to do so, they will be required to adjust their selection and recruitment policies for board positions. Such companies will also have to report annually on their performance from 30 November 2026 as discussed here.

1 July 2026 - UK OFR - Final OFR’s landing slots open for fund operators of umbrella EEA UCITS whose name begins with the letter “W-Z and firms with digits in the title” (in the TMPR) until 30 September 2026.

11 October 2027 - T+1 – Likely date for the transition to T+1 in the EU as detailed in the EU T+1 industry committee’s road map and discussed by ESMA here and here.

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

• tax, FATCA or CRS filings, director's compliance statement obligations, which apply to listed UCITS VCCs
• diversity reporting obligations, which may apply to listed AIF and UCITS VCCs
• ad hoc filings, such as regulatory reports, or filings of annual accounts (and related documents which include annual FDI returns) and semi-annual accounts or other similar returns (which deadlines vary to reflect the particular entity's year-end)

By way of example, the Companies (Accounting) Act 2017 obliges UCITS investment companies and AIF investment companies to file annual accounts with the CRO within 11 months of their financial year-end.

CBI regulatory reporting

The Money Market and Investment Fund Return Update section of the Central Bank of Ireland (CBI) website has been updated.

The first reporting under the European Central Bank Regulation on statistics on investment funds, including money market funds, will have a reference date of December 2025.

Phase 2 of the CBI’s Daily Investment Funds Return (DIFR) will go live on 18 August. Updated documents will be loaded onto the CBI’s new webpage.   

Sustainability reporting

Amendments to corporate sustainability reporting obligations were announced at both national and European levels. In Ireland, the European Union (Corporate Reporting) Regulations 2025 (the Regulations) were published. At a European level, the European Commission announced the adoption of a delegated act which introduces “quick fix” amendments to the European Sustainability Reporting Standards (ESRS). These amendments will apply to those companies that had to start reporting sustainability information under the Corporate Sustainability Reporting Directive for the 2024 financial year (“wave one” companies).

You can read more detail here.

Registers of beneficial ownership

The CBI maintains the central Beneficial Ownership Register for CFV. CFV include Irish Collective Asset-management Vehicles (ICAVs), Unit Trusts, Investment Limited Partnerships, and Common Contractual Funds. The CBI will be implementing a new reporting mechanism from Q4 2025, updating the means through which the beneficial ownership details of CFV are reported to the central register. Guidance and supporting information will be provided to all CFV in advance. Importantly:

• The new reporting mechanism will be facilitated entirely via the Central Bank Portal.
• There will be no change to the Verification of Identity Process and applicable return(s) where a beneficial owner neither holds an Irish PPS number nor an active CBI Reference Number.
• There will be no change to the PPSN validation protocol between the CBI and the Department of Social Protection.
• No immediate action is required by CFV. Further information updates and guidance will be provided in Q3 2025.

The European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) (Amendment) Regulations 2025 (S.I. No. 311/2025) came into force on 10 July 2025. These new Regulations amend provisions of the European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021 (S.I. No. 194/2021) to comply with AMLD 6. The new Regulations amend the 2021 Regulations by deleting paragraph (6) of regulation 27 concerning restricted access to beneficial ownership information in the central register of beneficial ownership of trusts.

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