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

Key deadlines

30 June 2025 - Exchange traded funds (ETFs) - Management companies of ETFs should review the actions outlined in the CBI letter on the primary and secondary market trading arrangements of ETFs (discussed here) and, where appropriate, incorporate the necessary changes to their frameworks and practices by the end of Q2 2025.

28 June 2025 - The European Union (Accessibility Requirements of Products and Services) Regulations 2023 - These regulations implement the European Accessibility Act ((EU) 2019/882) which aims to provide greater accessibility for people with disabilities, to a wide range of consumer products and services including websites, ATMs, smartphones, consumer banking services, e-books, and telecommunications. The regulations come into effect on 28 June 2025 and may impact on asset / fund managers providing relevant MiFID services to consumers.

30 June 2025 - Sustainability disclosures - ESMA to issue its report on the outcome of the common supervisory action on sustainability disclosures.

July 2025 - NBFI leverage policy recommendations - The FSB’s 2025 Work Programme notes publication of their final report on NBFI leverage policy recommendations in July.

10 July 2025 - CBI CP160 consultation on Fitness and Probity regime - Firms have a deadline until 10 July 2025 to respond to CP 160. 

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.

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.

Irish Funds AML/CFT/FS sectoral guidelines

Irish Funds issued updated Anti-Money Laundering, Countering the Financing of Terrorism and Financial Sanctions (AML/CFT/FS) sectoral guidelines. The purpose of these guidelines is not to summarise or replicate law or guidance but to provide specific guidance on particular points of practice which arise in the context of the Irish funds industry, with a focus on investors in Irish regulated investment funds.

These guidelines should be seen as supplementary to the CBI’s Anti-Money Laundering and Countering the Financing of Terrorism Guidelines for the Financial Sector.

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