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

Some annual compliance deadlines

31 December 2026 - Individual Accountability Framework - RFSPs should provide appropriate training on an ongoing basis to ensure that individuals are clear on their obligations in respect of the conduct standards and specifically what is expected of them in the context of their role. Firms should evidence that individuals have completed the relevant training and maintain up to date records.

31 December 2026 - Corporate Governance - 2026 reviews of board and individual director performance and matters reserved to the board should be completed by year end. Once every three years a formal documented review and a review of the chairperson must take place. Director time commitments and confirmation of other directorships as well as compliance with procedures for dealing with conflicts of interest and terms of reference of any board committees should be reviewed at least on an annual basis.

31 December 2026 - Anti-money laundering/combatting the financing of terrorism - Designated persons should offer training to their boards on the law relating to AML/CFT on an annual basis (and at such other times as may be appropriate). The annual review of AML/CFT policies, including AML/CFT business risk assessments should be completed and an AML/CFT report considered.

1 January 2027 - Fitness & Probity - The annual PCF confirmation return submission facility will likely be available on the CBI portal from 1 January 2027. PCF annual confirmation and CF certification guidance was last updated in December 2024. Revised CBI Fitness and Probity Guidance came into effect on 20 November 2025.

31 January 2027 - UCITS ManCo and AIFM ownership confirmation - UCITS ManCos and AIFMs must file their annual ownership confirmation by 31 January 2027.

22 February 2027 - UCITS KIID annual update - UCITS made available to retail investors in the EEA must provide those investors with a PRIIPs KID prior to investment. The PRIIPs KID must be reviewed regularly and revised when there is a change that significantly affects or is likely to significantly affect the information contained in the KID, and at least annually. PRIIPs KIDs (and PRIIPs KID updates) must be filed with the CBI. UCITS not made available to EEA retail investors may continue to produce a UCITS KIID. The UCITS KIID must be updated for each sub-fund/standalone fund on an annual basis within 35 business days of the end of each calendar year and filed with the CBI (22 February 2027).

31 March 2027 - ICCL Report - For the purposes of the Investor Compensation Company DAC’s compensation scheme, UCITS management companies and AIFMs 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

H2 2026 - The Central Bank of Ireland (CBI) will carry out a review of governance arrangements in fund management companies, including the Fund Management Company Guidance which applies to UCITS management companies and AIFMs and is expected to consult on changes in early 2027.

Q4 2026 - CBI expected to consult on changes to the PCF list, with the introduction of revisions in mid-2027.

3 December 2026 - Deadline to respond to CBI consultation on new cross sector guidance for managers and outsourcing risk (CP173).

7 December 2026 - New allocation and confirmation requirements relevant to the EU T+1 transition begin to apply ahead of the move to T+1 settlement on 11 October 2027.

31 December 2026 - Fund management companies should, with board input, assess their delegation arrangements against the CBI’s supervisory expectation and observations set out in its feedback report and put in place a time bound remediation plan by year-end 2026. Read more here.

8 January 2027 - Deadline to respond to CBI’s consultation on Industry Funding Levy proposals (CP172).

15 January 2027 - Feedback is due on ESMA’s call for evidence on tokenised collateral in CCPs.

Q1 2027 - European Commission expected to consult on the UCITS Eligible Assets Directive.

16 April 2027 - Existing UCITS and open-ended AIFs must comply with the revised liquidity management tools framework under AIFMD II, including the applicable ESMA guidelines and regulatory technical standards. Funds established before 16 April 2026 benefit from a 12-month transitional period, while new funds have been subject to the framework since 16 April 2026.

16 April 2027 - The revised supervisory reporting requirements under AIFMD II for AIFMs and UCITS Fund ManCos are due to apply.

8 June 2027 - Irish UCITS marketed to UK retail investors under the Overseas Funds Regime must use the new UK product summary instead of the UCITS KIID for UK disclosure purposes.

10 July 2027 - The AMLR will apply generally from 10 July 2027 while most provisions of AMLD6 must be transposed into national law by the same date.

2026 - 2028 - Irish Fund ManCos selected for the CBI’s risk management function review submitted questionnaire responses by 25 September 2026. The CBI will now undertake its desk-based analysis, with its report to ESMA expected in September 2027. ESMA is expected to publish the results of the EU-wide common supervisory action (CSA) in Q1 2028, following which the CBI is expected to publish its Irish findings.

11 October 2027 - T+1 transition in Europe.

CBI consults on new cross sector guidance for managing third party and outsourcing risk

The CBI has published Consultation Paper CP173. It proposes new Guidance on Good Practices for the Sound Management of Third-Party Risks to replace the 2021 Cross-Industry Guidance on Outsourcing in full. Final guidance is expected in Q1 2027, and it is proposed that it will apply from publication.

Key changes from the 2021 guidance in the proposals:

• Broader scope: the guidance now covers all material third-party arrangements creating reliance or dependency, not only traditional outsourcing, including cloud services, partnerships, joint ventures, technology vendors and data processors.
• Proportionate and risk based: it is split into foundational and supporting practices and focuses on critical or important arrangements. Smaller firms may take simpler approaches but proportionality “does not mean that third-party risks may be disregarded”. The CBI may also ask firms to show how they have considered the guidance. The guidance remains advisory, using "should" to denote recommended practice rather than legal obligation, save where a firm's own sectoral rules already require it.
• Outcomes based structure: five lifecycle-based outcome areas (governance, due diligence, contracting, ongoing risk management and incident/termination management) replace the 2021 guidance's itemised "Central Bank expects" lists, distinguishing foundational from supporting good practices.
• Classification and risk assessment: the fund-specific text in the 2021 guidance has not been carried forward. That includes the view that administrative or technical tasks are unlikely to be critical. Firms must justify how they classify each delegation using their own methodology. They should carry out tailored risk assessments before entering an arrangement and refresh them periodically. 
• Simplified criticality test: firms now self-determine what is "critical or important" to their business, replacing the EBA-derived definition and sector-specific criteria previously set out in Appendix 2 of the 2021 guidance.
• Register/return templates: move to the CBI's website rather than sitting within the guidance itself.
• Offshoring and substance: the draft guidance treats offshoring risk in general terms, instructing firms to assess country risk and avoid arrangements that impede supervision, but its own text is comparatively light on specific notification obligations. CP173's accompanying commentary is more explicit as it restates the "empty shell" expectation (that firms relying on group support must maintain sufficient local substance and oversight) and confirms firms should notify the CBI in advance of circumstances where supervisability issues may arise before committing to offshoring arrangements for critical or important functions.
• Funds and fund service providers: in 2021, the CBI said (via the related CP138 feedback statement) that the guidance applies to regulated firms, not to funds themselves. It added that boards of externally managed investment companies should support ManCo’s compliance. Neither the draft guidance or CP173 repeats this.
• Weaknesses identified through supervisory activities: these include underdeveloped oversight, weak due diligence, contractual controls and monitoring, concentration on providers that are hard to replace, limited oversight of sub-outsourcing and inadequate exit planning.

Next steps

Consultation responses are due by 3 December 2026. The CBI is seeking evidence on costs, scope, proportionality and transition. It also plans an industry workshop and offers bilateral meetings.

CBI deadlines for pre-Christmas/year-end applications 2026

The CBI issued details of its deadlines for receipt of applications that have pre-Christmas or pre year-end approval deadlines for:

• QIAIF/professional and qualified ELTIF authorisations, approvals and notings (normal timeframes apply until 22 December): from 3pm on 22 December for 23/24 December, 3pm on 23 December for 29 December, 3pm on 29 December for 30/31 December and 5pm on 30 December for 4 January 2027
• UCITS, RIAIF and retail ELTIF authorisations, approvals and notings (authorisation/approval/noting on 23, 24 or 29, 30 and/or 31 December): executed documentation by close of business on 21 December
• QIAIF change of service provider filings (effective 24 December 2026 – 4 January 2027): 5pm on 18 December
• ICAV registration/conversion/migration applications (effective 23-31 December): 5pm on 11 December
• revocation applications (effective end December), including payment of the funding levy: 5pm on 15 December
• fund service provider authorisations: firms intending to submit an acquiring transaction notification between 29 and 31 December (inclusive) should engage with the CBI’s fund service provider authorisation team before 23 December.

Monday 4 January 2027 is the first day of 2027 on which funds may be authorised/approved or post-authorisation updates noted. Executed documentation for that date must be received by close of business on Wednesday 30 December (5pm for QIAIFs/professional and qualified ELTIFs). For UCITS, RIAIF and retail ELTIF applications, 24 and 29-31 December 2026 and 4-8 January 2027 will not count towards the CBI's timeframes for issuing comments. Read more here.

CBI speech: Opportunity and trust - Europe’s capital market and the Irish funds sector

On 1 October 2026, CBI Governor Gabriel Makhlouf addressed the Irish Funds Annual Global Funds Conference on the role of deeper European capital markets and the importance of maintaining trust as the funds industry develops.

He identified two significant opportunities: distributed ledger technology (DLT), fund tokenisation and related innovations, which, with appropriate safeguards and robust risk management, could deliver settlement efficiency, transparency and access to capital markets; and greater retail participation, supported by appropriate products, clear information, robust regulation and improved financial literacy, advancing Europe’s Savings and Investment Union.

The Governor called on the funds industry to focus on three resilience priorities:

• Resilience to shocks: firms should apply lessons from recent market stresses, particularly regarding liquidity management, valuation practices and contingency planning.
• Operational resilience: firms should understand their dependencies on technology and third-party service providers, maintain tested exit strategies and ensure board-level understanding of dependencies.
• Governance: delegation must be supported by genuine substance, including real decision-making capacity, effective oversight of delegates and senior management with the authority and expertise to challenge or override delegate decisions where necessary.

Notably, the Governor indicated that the CBI will consult on changes to the governance of fund management companies in early 2027. He concluded that the industry’s sustainable growth depends on maintaining high standards of governance, investor protection and risk management observing that “capital goes where the opportunity is, and it stays where it is trusted.

AML and beneficial ownership - new register access rules

Earlier this year Ireland implemented the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) (Amendment) Regulations 2026 (S.I. No. 406/2026), giving effect to Articles 11,12,13, and 15 of AMLD6 (Directive (EU) 2024/1640) and amending the rules governing access to beneficial ownership information held on Ireland’s corporate beneficial ownership register.

S.I. No. 406/2026 replaces the access test in the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019 (S.I. No. 110/2019) with the AMLD6 legitimate interest framework. Applicants must show a legitimate interest in preventing and combating money laundering, its predicate offences or terrorist financing. Certain categories are deemed to have that interest, including qualifying journalists, civil society organisations and members of academia, persons likely to enter into transactions with a relevant entity, certain third-country AML/CFT obliged entities needing access for customer due diligence, third-country counterparts of EU AML/CFT competent authorities acting in a specific case, specified public bodies and certain AML/CFT product providers.

From 10 November 2026, the registrar must generally respond to legitimate interest access applications within 12 working days. This period may be extended where there is a sudden high volume of requests or where further information is required, but the total response period cannot exceed 43 working days. If satisfied, the registrar issues a certificate permitting inspection for up to three years, subject to earlier revocation.

For ICAVs and unit trusts, S.I. No. 233/2020 applies the 2019 Corporate Entities Regulations, subject to specified modifications.

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

Date published: 29 October 2026