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In a recently published report, the Central Bank of Ireland (Central Bank) confirmed the successful completion of all twelve recommendations that were set out in the ‘Fitness and Probity Gatekeeping Review’ (Review) conducted by Mr Andrea Enria in 2024 (see details of the Review in our previous client insight).
In its report, the Central Bank confirms the following actions have been taken in response to the recommendations:
Consolidated fragmented guidance into streamlined, user-friendly material through the publication of the revised Guidance on the Standards of Fitness and Probity in November 2025 (Guidance). See our previous client insight on the Guidance.
Eliminated redundant content (such as ‘FAQs’) and refreshed its website to improve navigation.
Established the Fitness and Probity Unit, in January 2025, to centralise gatekeeping responsibilities across all sectors. This has resulted in enhanced consistency of assessments, streamlined operations and high processing standards.
Established the Gatekeeping Decisions Committee, in March 2025, to provide senior leadership and independence in the final decision-making in cases of potential refusal. The Committee is chaired by Deputy Governor McMunn and has seven other members at Head of Division level or above.
Published a Fitness and Probity Gatekeeping Process Manual outlining clear details on what firms and individuals should expect when undergoing the fitness and probity assessment and approval process.
The Central Bank’s list of pre-approval controlled functions (PCFs) was subject to public consultation, with most proposed amendments subject to further consideration by the Central Bank (see the section below for more detail).
Enhanced management information and statistics are shared publicly through the annual Authorisations and Gatekeeping Report. The report for 2025 was recently published – see here.
Delivered consistent performance – 97% of all fitness and probity assessment applications were completed within 90 calendar days, with an average approval time of 50 calendar days.
Established a complaints procedure for fitness and probity assessments with independent third-party reviewer involvement. To date, no fitness and probity complaints have been made through the procedure.
Delivered a training programme to relevant staff with a focus on interviews and decision making.
Periodic deep dives conducted by the Fitness and Probity Unit to assess process adherence and to identify opportunities for improvements or refinements.
Extensive industry engagement conducted via on-site events, online workshops and ad hoc engagement.
Next steps in 2026
During the second half of 2026, the Central Bank will focus on the output from its review of its list of PCFs, which was signposted at the time the Guidance was published. The Central Bank is targeting the end of the year to outline the proposed changes to the PCF list. Relevant fitness and probity material will be updated following the review of the PCF list in 2026 and the review of the Senior Executive Accountability Regime in 2027 to ensure relevance, integration and ease of reference for industry.
For further information on any of the actions taken by the Central Bank or any aspects of the fitness and probity regime, please contact: Dario Dagostino, Partner, Mark Devane, Partner, Chloe Culleton, Partner, Eoin O Connor, Partner, Patrick Brandt, Partner, Eimear O’Brien, Partner, Louise Hogan, Partner, Sarah Lee, Senior Practice Development Lawyer or your usual ALG contact.
Date published: 16 June 2026
