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

Forthcoming annual compliance deadlines

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 Central Bank of Ireland (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 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

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.

2 March 2026 - AIFMD II - CBI fast-track filing process open for UCITS and AIFs documentation updates pursuant to AIFMD II implementation.

12 March 2026 - EU Venture and Growth Capital Funds reform - deadline to respond to European Commission consultation.

24 March 2026 - Consumer Protection Code - the CBI’s revised Consumer Protection Code (incorporating Business Standards Regulations) begins to apply.

25 March 2026 - Fitness & Probity - deadline to respond to the CBI’s consultation on prohibition notices under the Fitness & Probity regime.

6 April 2026 - Commission’s SFDR 2.0 proposals - deadline for stakeholders to submit feedback. For an overview of the SFDR 2.0 proposals, see here.

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

• AIFM’s managing loan originating AIFs must update their AIFM authorisation by this date (see insight).
• 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. 
• Liquidity management tool (LMT) requirements will apply from 16 April 2026. A transitional period of one year is available for AIFs or UCITS constituted before 16 April 2026 to comply with the LMT RTS and guidelines, to enable adaptation to the new regime. Read more here.

6 May 2026 - Shareholder Rights Directive - deadline to respond to European Commission call for evidence and public consultation on the evaluation and review of the SRD. Read more here.

5 June 2026 - DLT & tokenisation - deadline to respond to CBI Discussion Paper 12 on the future role of DLT and tokenisation.

H1 2026 - Fund management company (FMC) delegation - the CBI is due to issue its initial communication in H1 2026 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.

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 opens streamlined AIFMD II/UCITS VI filing process

The CBI has published details of its streamlined filing process to facilitate updates to UCITS and AIF prospectuses, supplements, and constitutional documents arising from the implementation of AIFMD II and amendments to the revised AIF Rulebook and Central Bank UCITS Regulations (once published).

The streamlined filing process applies to all existing UCITS and AIFs and opened on 2 March 2026. There is no fixed closing date. The CBI will give adequate advance notice before closing the process.

Permitted updates

• Updates to fund prospectuses, supplements, and constitutional documents arising from the implementation of AIFMD II and amendments to the revised AIF Rulebook and Central Bank UCITS Regulations (once published).
• Any other updates required as part of a prospectus and/or supplement refresh, subject to the below exclusions.

Updates outside scope

• Changes to the fund’s/sub-fund’s investment objective, policy, or strategy which are material changes will remain subject to full CBI post-authorisation review.
• SFDR reclassifications must be submitted via the CBI’s Portal in line with existing processes.
• Where a new fund or sub-fund application has been filed with the CBI and is currently under review, the disclosures will remain subject to standard review by the fund authorisations team.

Filing/attestation

• Submit revised final dated documents to CBI dedicated mailbox by close of business on the relevant date for automated noting, with documents dated as at the submission date.
• Include an attestation from the UCITS management company/AIFM confirming that amendments do not represent a change to the fund’s/sub-fund’s investment objective, policy, or strategy.
• If further amendments are needed after an umbrella fund/sub-fund has already been submitted through the streamlined process, a subsequent filing can be made.

Sample review

The CBI will carry out a sample review of filings noted via the streamlined process. Changes may be required following that review.

CBI regulatory and supervisory outlook report 2026

On 26 February 2026, the CBI published the third edition of its Regulatory & Supervisory Outlook Report 2026 (RSO), setting out the CBI’s assessment of the risk landscape facing the financial sector and the supervisory work it intends to undertake in response.

On the same day, the CBI issued a Dear CEO letter emphasising that boards and senior leadership should familiarise themselves with the CBI’s current risk outlook, its supervisory expectations and its planned cross sectoral and sectoral supervisory work for the period ahead.

The CBI confirms that governance, risk management and operational resilience will remain priority areas in 2026 and beyond. It highlights a fast-evolving Irish funds environment shaped by geopolitical fragmentation, regulatory change, business model adaptation, growing product complexity and accelerating digitalisation. The CBI expects the Irish funds industry to play a pivotal role in supporting EU competitiveness and simplification and the broader EU’s Savings and Investments Union agenda.

Across the wider financial system, the CBI notes that operational risks remain at a very elevated level, alongside increased asset valuation and market risks and rising data, model and AI related risks.

The CBI’s supervisory activities across the funds sector will be undertaken at firm level for those subject to close and continuous supervision and sectoral level for others supplemented by firm specific work as appropriate. Planned supervisory activities for the funds sector, including thematic reviews, cover seven focus areas, as follows:

1. Governance and risk management

• review of delegation in fund management companies (FMCs) (initial communication in H1 2026)
• review of outsourcing effectiveness by fund administrators and depositaries (H1-H2 2026)
• review of governance and board effectiveness in fund administrators and depositaries (H2 2026-H2 2027)
• review of compliance functions across fund administrators and depositaries (H1 2026)
• ESMA Common Supervisory Action (subject to be confirmed) (H1 2026-H2 2027)
• support for AIFMD II transition (H1 2026-H2 2027)

2. Operational and cyber resilience

• DORA implementation, including threat‑led penetration testing (survey issued H1) (H1-H2 2026)
• enhanced AML/CFT risk evaluation questionnaire (H1-H2 2026)
• thematic inspection of transaction monitoring and STR reporting (H2 2026-H2 2027)
• engagement on CRD6 restructuring plans for depositaries (H2 2026-H2 2027)

3. Asset valuation and market risks

• responsive supervision of operating processes and arrangements changes (H1 2026-H2 2027)
• review of investment restriction monitoring and reporting of regulatory breaches (H2 2026-H2 2027)
• UCITS value at risk (VaR) model review and depositary oversight (H1-H2 2026)
• enhancement of the CBI’s fund data and risk models (H1 2026-2027)
• valuation oversight review focused on hard to value assets and depositary oversight (H1-H2 2026)

4. Liquidity and leverage risks

• liquidity risk management review in bond funds (H1 2026-H2 2027)
• progress assessment on leverage reduction and maintenance plans across property funds (H1 2026-H2 2027)
• property funds questionnaire issued in Q1 2026, with assessment and follow up engagement through H2 2026 (H1 2026-H2 2027)

5. Product costs and disclosures

• engagement with firms and with ESMA on costs and fees and value for money, with follow up where issues arise (H1 2026-H2 2027)
• gatekeeping assessments of costs, disclosures and transparency (H1 2026-H2 2027)
• assessment of implementation of Consumer Protection Code (H1 2026-H2 2027)

6. Data and AI

• enhancement and use by CBI of fund data and risk models (2026–2027)
• continued engagement on firms’ approach to AI and model governance (H1 2026–H2 2027)

7. Climate and ESG risk

• continued use of CBI’s ESG dashboard tool to assess SFDR compliance (H1 202-H2 2027)
• compliance with fund naming guidelines at both the gate and through data-led supervisory reviews (H1-H2 2026)

The report also highlights a busy regulatory pipeline for 2026, including developments relating to the EU Retail Investment Strategy, SFDR amendments, AIFMD II, the UCITS Regulations, tokenisation and the Markets Integration and Supervision Package.

Read more here, and for an overview of the CBI’s industry wide overarching priorities and sector specific priorities, including MiFID supervisory activities, please refer to our Financial Regulation advisory here.  

CBI discussion paper on DLT and tokenisation in financial services

The CBI published discussion paper 12 DLT and Tokenisation in Financial Services, opening a wide-ranging consultation on the potential future role of distributed ledger technology (DLT) and tokenisation within Irish and EU financial services.

The CBI invites written responses to the DP by 5 June 2026 via its online submission form and intends to publish a feedback statement addressing issues raised. The DP will support engagement with domestic and international stakeholders and will inform the CBI’s assessment of whether existing policy and regulatory approaches remain fit for purpose.

The DP places significant emphasis on the funds sector, with a particular focus on use cases for exchange-traded funds (ETFs) and money market funds (MMFs). It also addresses tokenisation across the broader financial market infrastructure, including tokenised securities, portfolio‑level tokenisation and applications in money and payments. It concludes by outlining risks including disintermediation, concentration, technology and operational risks, transition risks, and risks to supervision and regulation.

The CBI is seeking stakeholder feedback not only on risks and proposed use cases but also on the enablers required for safe and effective adoption, such as legal and regulatory clarity, interoperability and standardisation, settlement, operational resilience, digital identify and verification, and transparent governance.

Read more here.

CBI Markets Update

The CBI published Issue 2 of its Markets Update, covering:

• updated authorisation process for AIFMs managing loan originating AIFs and finalised filing process for updated documentation of existing UCITS & AIFs
• Statutory Instruments implementing ESAP framework in Ireland signed
• updated Central Bank Guidance on Transparency Regulatory Framework

The CBI published Issue 3 of its Markets Update, covering:

• the EBA decision on arrangements for the International Swaps and Derivatives Association Standard Initial Margin Model (ISDA SIMM) validation
• publication of the Amendment Regulations (S.I. No. 81 of 2026), containing amendments to MiFID client asset provisions
• Discussion Paper 12 - Distributed Ledger Technology (DLT) & Tokenisation in Financial Services

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

Date published: 31 March 2026