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Related areas
Some annual compliance deadlines
31 December 2025 - 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 2025 - Corporate Governance - 2025 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 2025 - 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 2026 - Fitness & Probity - The annual PCF confirmation return submission facility will likely be available on the Central Bank of Ireland (CBI) portal from 1 January 2026. PCF annual confirmation and CF certification guidance was last updated in December 2024. CP160 - Consultation Paper on Amendments to the Fitness and Probity Regime has yet to be finalised. Further details and updated guidance will be published by the CBI in due course.
31 January 2026 - UCITS ManCo, AIFM ownership confirmation - UCITS mancos and AIFMs must file their annual ownership confirmation by 31 January 2026, as discussed here for UCITS mancos and and here for AIFMs.
17 February 2026 - UCITS KIID/ PRIIPs KID - All UCITS made available to "retail investors" in the EEA are required to provide such investors with a PRIIPs KID prior to their investment. A UCITS which is not made available to retail investors in the EEA is not obliged to provide a PRIIPs KID and may continue to produce a UCITS KID. A UCITS producing a UCITS KIID must update its KIID on an annual basis for each sub-fund/ standalone fund within 35 business days of the end of each calendar year. The annual update of the UCITS KIID must be filed with the CBI. Unlike the UCITS KIID, there is no annual refresh deadline for the PRIIPs KID. The PRIIPs KID must be reviewed regularly and revised when there is a significant change, and at least annually. PRIIPs KIDs (and PRIIPs KID updates) must also be filed with the CBI.
28 February 2026 (expected deadline) - Fund profile return - The annual 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 an anticipated submission deadline of 28 February 2026. The CBI updated its Guidance for Fund Profile Return Vol 2.3 May 2025 in May 2025.
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
The above list does not cover all compliance deadlines. Reporting obligations may vary on a firm-by-firm basis.
Other key dates
Q3 2025 - EU blueprint for savings and investment accounts and products - The European Commission is expected to finalise its recommendation on establishing savings and investment accounts aimed at improving retail participation in EU capital markets under the savings and investments union strategy.
5 November 2025 - CBI consultations on AIF and UCITS rules and guidance - Deadline to respond to the CBI’s consultations on proposed amendments to the AIF Rulebook (CP162) and UCITS Regulations and performance fee guidance (CP161) addressing AIFMD II implementation and other proposals. Read more below.
Q4 2025 - SFDR - The European Commission is expected to publish its proposal to reform the SFDR regime in Q4 2025.
Q4 2025 - Cross-border distribution and reduction of operational barriers - The European Commission is expected to make proposals to remove barriers to the cross-border distribution of EU-authorised funds across the EU and to reduce operational barriers affecting cross-border groups.
Q4 2025 - Supervisory capacity at EU level - The European Commission is expected to make legislative proposals to strengthen supervisory convergence and to transfer certain supervisory tasks to EU level.
1 January 2026 - EU Benchmarks Regulation - Regulation (EU) 2025/914 amending the Benchmarks Regulation applies. The scope of the existing regime will be significantly reduced so that only those fund management companies and corporate funds which use benchmarks deemed “critical” or “significant” under the new framework, EU Paris-aligned benchmarks, EU Climate Transition benchmarks and certain commodity benchmarks will be in-scope. Fund management companies and corporate funds which “use” (as defined) benchmarks will need to review their use of benchmarks (including ensuring that any relevant benchmark is officially approved for use by checking the ESMA Register), decide whether any updates are required to prospectus disclosures and ensure that contingency plans are up to date.
24 March 2026 - Consumer Protection Code - The CBI’s revised Consumer Protection Code (incorporating Business Standards Regulations) begins to apply.
April 2026 - AIFMD II - 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.
16 April 2026 - AIFMD II - Deadline for the transposition of the majority of AIFMD II provisions into national law.
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 review of the AIF Rulebook CBI (CP 162)
The CBI has launched Consultation Paper 162 (CP162), containing proposals to overhaul the Alternative Investment Fund Rulebook (AIF Rulebook) in advance of the revised Alternative Investment Fund Managers Directive (AIFMD) entering into force. The consultation marks the first comprehensive rewrite of the domestic framework since the AIF Rulebook was first published as part of the CBI’s implementation of the AIFMD in 2013.
Running to more than 180 pages, the proposals are designed to align domestic rules with the revised AIFMD, reinforce investor safeguards and streamline the establishment of private-asset funds in Ireland. Submissions are invited until 5 November 2025. Read more here.
CBI review of UCITS Regulations and performance fee guidance (CP 161)
The CBI has launched Consultation Paper 161 (CP161), containing proposals to update the CBI UCITS Regulations which supplement the general UCITS Regulations in Ireland. They also propose to update CBI Guidance on performance fees for UCITS and certain types of Retail Investor AIFs.
The proposals are designed to update the CBI’s own requirements in light of Q&As and other guidance issued for UCITS funds as well as proposed changes that will come into force as a result of changes to the UCITS Regulations included in AIFMD II. Submissions are invited until 5 November 2025. Read more here.
ELTIF Authorisation Process - Updated application form and website guidance
The CBI updated its ELTIF application form to clarify certain requirements relating to:
Information relating to the authorisation process for ELTIFs has also been updated on the website.
CBI Markets Update
CBI issued markets update 5 of 2025 covering:
For more information on these topics please contact any member of A&L Goodbody's Asset Management & Investment Funds team.
Date published: 28 September 2025