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Deadlines
Domestic
Related areas
Key dates
CBI thematic assessment of fitness and probity in the MiFID investment firm sector
The CBI has published findings from its thematic assessment of MiFID firms’ implementation of key aspects of the fitness and probity (F&P) regime. The assessment evaluated firms’ approaches to F&P policies and procedures, due diligence and annual certification documentation, implementation of the Individual Accountability Framework (IAF), and records of compliance with the Minimum Competency Code (MCC), where applicable.
Many firms had sufficiently detailed policies and procedures, which were clearly implemented in practice in several cases. Good practices included firms demonstrating that they had considered the outputs of the annual certification process, issuing PCF role holders with certificates confirming compliance with the F&P standards and annually reviewing continuous professional development records.
However, some firms could not provide sufficient evidence of due diligence completed when onboarding PCF role holders and/or for annual certification. Their policies and procedures did not provide sufficient detail on how the firm would satisfy itself that CF or PCF role holders meet the F&P standards. Common gaps included:
The CBI emphasised that annual certification is a key control as a PCF role holder’s circumstances may change during their tenure.
Most firms had taken effective steps to embed the IAF although some policy documents lacked specific details on how firms tailored their approach to the IAF or the actions the firm had taken to embed the new framework. Good practices included developing a reasonable steps framework to help employees understand their roles and responsibilities and quarterly compliance function attestations that the Management Responsibility Map (MRM) remained up to date.
For firms within SEAR, a small number of MRMs did not meet prescribed standards, with key information missing such as the omission of “inherent” or “other” responsibilities and the absence of clear reporting lines to management and/or committees of the board. In one case there were shared responsibilities across two PCF role holders outside the limited permitted circumstances permitted in the IAF guidance. There were no significant adverse findings in relation to how firms demonstrated compliance with the MCC requirements.
All MiFID investment firms should review their arrangements against the findings, prioritising F&P policies, due diligence and annual certification, embedding IAF, and SEAR responsibility allocation and mapping.
Although the communication is addressed to MiFID investment firms and not more broadly to UCITS management companies or AIFMs, those entities should nevertheless consider the findings as useful, given the CBI’s wider F&P and governance expectations for regulated firms.
Read more here.
Taxation of retail investment: a new path forward for Ireland
The Department of Finance has published Taxation of Retail Investment: A New Path Forward for Ireland, a roadmap setting out a pathway for work to simplify and adapt the tax framework for retail investment in Ireland. The publication identifies areas for consideration over the term of the current government, though decisions can only be made as relevant analysis is completed and with regard to annual budgetary parameters.
Investment Account — Impact on Fund Managers and Product Providers
The roadmap confirms the introduction of a new investment account, with the legislative framework to be included in Finance (No. 2) Bill 2026 and accounts available from 2027. Qualifying products will include a range of investment funds suitable for retail investors, including listed shares, listed bonds, financial instruments traded on a regulated market and a range of investment funds suitable for retail investors, including ETFs. Qualifying providers will include regulated fund managers, MiFID-authorised service providers, and insurers. Non-Irish, EEA-authorised providers will also be eligible. The current taxation regime for retail investment, including the deemed disposal rule, will not apply to investments held within the new account.
Wider reform of retail investment taxation
The roadmap identifies three key levers for reform of the existing taxation regime, to be considered in the context of budget 2028 and beyond:
Timelines
The legislative framework for the investment account is expected in Finance (No. 2) Bill 2026, with accounts available during 2027. Broader reforms to the existing taxation regime are to be considered over future budgets, from budget 2028 onwards.
CBI strategy 2028–2032 survey
The CBI has launched a public engagement process to inform its next five-year strategy, citing significant changes in the financial landscape including new technology, climate risks and evolving banking practices. The new strategy will build on its current strategy (running to end of 2027), under which it has advanced work on consumer protection, digital payments, climate risk, and regulatory and supervisory frameworks.
The strategy is expected to be approved by the CBI's Commission in May 2027 and presented to the Minister for Finance in September 2027. The online survey is open for feedback until 16 October 2026.
Government legislation programme – Autumn 2026: Items relevant to the funds sector
The Government published its Autumn 2026 legislation programme on 10 September 2026. Key items for the asset management sector include:
Finance (No. 2) Bill
The Finance (No. 2) Bill is listed as a priority publication. It will give legislative form to taxation proposals in budget 2027 and will also contain provisions consequential on the budget measures and other changes to the taxation code. As discussed above in the retail investment taxation section, the roadmap confirms that the legislative framework for the new investment account will be included in this Bill. Status: Heads in preparation.
Asset Covered Securities (Amendment) Bill
The Asset Covered Securities (Amendment) Bill is listed as priority drafting. It will amend the Asset Covered Securities Act 2001 to facilitate the issuance of asset covered securities (covered bonds) either by specialist covered bond subsidiary entities under a specialist banking model or by non-specialist credit institutions operating under a universal banking model, together with related matters. Status: Heads of Bill approved June 2026.
Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill
The Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill is listed as priority drafting. It will transpose into Irish law those aspects of the EU’s 6th Anti–Money Laundering package that require primary legislation. Status: Heads in preparation.
Miscellaneous Provisions (Registration of Limited Partnerships and Business Names) Bill
The Miscellaneous Provisions (Registration of Limited Partnerships and Business Names) Bill is listed under All Other Legislation. It will reform the Limited Partnerships Act 1907 and the Registration of Business Names Act 1963, strengthening Ireland’s regulatory framework and the transparency of limited partnerships. Status: Work is ongoing.
Finance (Tax Appeals and Fiscal Responsibility) Bill
The Finance (Tax Appeals and Fiscal Responsibility) Bill is listed as Priority Drafting. It will amend the Finance (Tax Appeals) Act 2015, provide for different grades of Appeal Commissioners, revise the law concerning appeals in taxation matters, and amend the Fiscal Responsibility Act 2012. Status: Heads of Bill approved September 2025.
Restrictive Measures Bill
The Restrictive Measures Bill is listed under All Other Legislation. It will create a mechanism requiring persons to adhere to the asset-freezing requirements of certain UN Security Council Sanctions Resolutions during the period before those requirements are incorporated into an EU legislative act. This bridging measure is intended to meet Ireland’s international obligations and prevent sanctions evasion. Status: Heads in preparation.
For more information on these topics please contact any member of A&L Goodbody's Asset Management & Investment Funds team.
Date published: 29 September 2026