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

At a glance: key dates

2026 - ESMA CSA on MiFID II conflicts of interest requirements - the European Securities and Markets Authority (ESMA) (and NCAs) will carry out a CSA on MiFID II conflicts of interest in the distribution of financial instruments in 2026.

2026 - IREF consultation (Funds Sector 2030) - the Department of Finance is expected to launch a public consultation on the simplification of the IREF regime, with legislative changes being implemented in the Finance Act 2026.

30 June 2026 - SFDR PAI statement - fund management companies that are either in scope due to their size or that have opted into Article 4 SFDR reporting must publish their full PAI statement on their website, including year on year comparisons with the previous PAI report.

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.

June/July 2026 - CBI - UCITS framework (CP161) - Central Bank of Ireland (CBI) feedback on CP161 and updated Central Bank UCITS Regulations are expected to be published.

July 2026 - Fund management company (FMC) delegation - the CBI is due to issue its initial communication following its review of delegation practices of Irish authorised FMCs.

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.

2026 - Hedge funds deep dive - CBI report, following its review of hedge fund firms, is expected to issue in 2026.

H1 2026 - Liquidity management tool thematic review - CBI communication, following its liquidity management tool thematic review, is expected H1 2026.

2 July 2026 - ESG ratings - 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.

7 July 2026 - ESMA T+1 consultation - deadline for responses to ESMA’s consultation on revised CSDR guidelines on allocations and confirmations to support the transition to T+1 settlement.

15 July 2026 - AMLA consultation on draft guidelines on business-wide risk assessment - deadline to respond to consultation.

2 August 2026 - EU AI Act - core EU AI Act high-risk AI systems obligations and transparency rules apply.

3 September 2026 - AMLA consultation on draft guidelines on ongoing monitoring of a business relationship - deadline to respond.

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.

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

CBI consultation on guidance for money market fund weekly liquid asset levels

The CBI has published Consultation Paper 168 (CP168) proposing guidance on weekly liquid asset (WLA) levels for money market funds (MMFs).

The proposed guidance sets out the CBI’s expectations for MMFs to align their liquidity risk frameworks and WLA with the market resilience levels identified in the European Commission’s 2026 report on the adequacy of the Money Market Funds Regulation (MMFR) (and related FAQ), supported by increased supervisory scrutiny and engagement where a fund’s WLA falls below those levels for a prolonged period of time. It is intended to implement aspects of the recommendations by the Financial Stability Board (FSB), the International Organization of Securities Commissions (IOSCO), the European Systemic Risk Board (ESRB) and ESMA to increase the liquidity that MMFs hold and use in times of market stress.

Key aspects of the CP168 proposals include:

WLA market resilience levels (supervisory benchmarks that sit above the existing MMFR minimums of 15% WLA for VNAV and 30% WLA for Public Debt CNAV/LVNAV MMFs, however daily liquid asset expectations are unchanged) of:

• 20% WLA for VNAV MMFs
• 40% WLA for Public Debt CNAV and LVNAV MMFs

Liquidity risk management expectations

• Integration of market resilience levels into internal liquidity risk management systems, including within stress testing programmes under Article 28 of the MMFR.
• Enhanced vigilance where WLA levels approach or fall below the market resilience levels.
• Escalation and notification requirements, with notification to the CBI required where a fund falls below the levels for a period exceeding 10 business days, or where the manager expects a prolonged and/or substantial deviation.

Increased supervisory scrutiny and engagement

• Enhanced supervisory engagement by the CBI where an MMF’s WLA falls below the market resilience levels for a prolonged period.
• Potential for more frequent reporting including daily reporting of key risk indicators such as NAV, net subscriptions, WAM, WAL, daily and weekly liquidity buffers, and the difference in basis points between constant NAV and mark-to-market NAV at the onset of stressed market conditions.

The CBI’s proposed guidance has been developed in close coordination with the European Commission, the French AMF and the Luxembourg CSSF.

Responses to the consultation should be submitted by stakeholders by 3 August 2026.

CBI consultation on regulatory impact assessments and its approach to consultations

The CBI has published Consultation Paper 170 (CP170) seeking stakeholder views on its proposed approach to Regulatory Impact Assessments (RIA) and public consultation. The paper does not introduce new regulatory requirements or amend existing rules but focuses on the frameworks and processes that support regulatory policy development and communication.

Key points:

• RIA framework: The CBI proposes a structured, proportionate approach to assessing regulatory interventions, including identifying problems, considering options and evaluating potential impacts on consumers, firms and the wider financial system.
• Scope: The RIA approach will apply where the CBI exercises meaningful domestic discretion in developing regulatory policy interventions of general application, particularly where it introduces new obligations, materially amends existing requirements, or otherwise alters the regulatory framework in a way that may have significant effects.
• Consultation timelines: Consultation periods will generally be 12 weeks, with shorter or longer periods depending on the nature, complexity, and timing of the proposal; where a shorter period applies, the CBI would generally expect no less than 8 weeks unless specific circumstances require otherwise.
• RIA and consultation: These are treated as connected but distinct tools with consultation informing the RIA evidence base and RIA supporting the development and evaluation of policy options.

The deadline for submissions is 30 September 2026. The CBI intends to publish a formal consultation policy and a feedback statement in due course.

Press release here.

CBI publishes third Authorisations and Gatekeeping report

The CBI published the third edition of its Authorisations and Gatekeeping Report providing a comprehensive overview of authorisation and gatekeeping activity across all regulated sectors in 2025. The CBI reiterates that the timeline from a firm’s initial application to authorisation is strongly influenced by:

• complexity of the proposed application/business model
• completeness and quality of the application, as well as changes made during the process
• applicant’s timeliness in responding to queries

Fund authorisations

• 40% increase in UCITS, RIAIFs and retail ELTIFs
• 32% increase in QIAIFS and professional ELTIFs
• average authorisation timeline 91 calendar days

Fitness and probity

• 3,032 PCF applications received
• 97% completed within 90 day F&P service standard, with a 50 day average for PCF approvals being issued across all PCF applications
• planned 2026 enhancements include the removal of employer references for most sectors, extension of Garda vetting validity to twelve months, and broadened access to a streamlined assessment process

CBI speech on navigating and responding to change - resilience, innovation and regulation in the funds sector

In a June 2026 address to the IOB Funds and Asset Management Forum, Deputy Governor McMunn highlighted a number of areas of supervisory focus which are consistent with CBI workstreams:

Resilience

• emphasis on resilience beyond managing liquidity and leverage related risks, including governance, stress testing, the robustness of operational arrangements and the capacity of boards and senior management to make sound decisions under pressure (aligning with MMF CP168)

Delegation

• confirming that the CBI’s review of delegation practices in fund management companies has been completed with findings expected shortly

Tokenisation and AI

• examples of benefits of AI across the funds sector with important questions about AI explainability, accountability, bias and operational resilience
• firms deploying AI must be able to explain how their models work, who is accountable for their outputs, and how they are governed with human oversight remaining paramount and boards and senior management responsible for understanding and governing the activities of the firms they lead
• developments in tokenisation

CBI speech on its approach to tokenised finance

In a speech on the CBI’s approach to tokenised finance, Deputy Governor Madouros reiterated the CBI’s broadly supportive stance on tokenisation noting its potential to improve efficiency, transparency and market access and the increasing role of DLT within financial market infrastructure, balanced by the need for clear governance, regulatory certainty and investor protection.

Key takeaways:

• The Eurosystem is progressing a project to enable settlement of DLT-based transactions in central bank money, with an initial launch phase later this year. In addition, the CBI will be supporting the Department of Finance as they lead negotiations to progress the Digital Euro legislation during Ireland's presidency of the Council of the EU.
• The Eurosystem has begun accepting DLT-based assets as eligible collateral in monetary policy operations.
• Supervision and regulation continues to be responsive to finance innovation, including the CBI's role as National Competent Authority for MiCAR and the use of its Innovation Sandbox. The Deputy Governor noted the CBI's March 2026 Discussion Paper on tokenisation, asking whether specific elements of the current Irish or EU regulatory or legal frameworks need to evolve.
• The CBI is acting as a catalyst for the system to co-ordinate towards better outcomes, including through the Eurosystem's work on a European tokenised financial ecosystem.

CBI markets update

The CBI published Issue 7 of its markets update, covering:

• ESMA call for evidence on the structure of European equity markets
• The Central Bank publishes a notice of intention in relation to the application of the ESMA Guidelines on stress test scenarios under the Money Market Fund (MMF) Regulation

The CBI published Issue 8 of its markets update, covering:

• CP168 - Guidance on Money Market Fund Weekly Liquid Asset levels
• Publication of IOSCO AI Supervisory Toolkit and Industry Practices Review survey

The CBI published Issue 9 of its markets update, covering:

• EU T+1 Industry Committee readiness surveys open until 11 June 2026

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

Date published: 2 July 2026