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Central Bank of Ireland’s Authorisations and Gatekeeping Report 2024
On 1 May 2025, the Central Bank of Ireland (CBI) published the second edition of the Authorisations and Gatekeeping report, which describes the authorisations and gatekeeping performance of the CBI for the full 2024 calendar year. The report contains information related to the preparation of submissions for authorisations, the Markets in Crypto Assets Regulation ((EU) 2023/1114) (MiCAR), the timelines for authorisations in 2024 for each sector, and information related to the CBI’s fitness and probity gatekeeping process. The report also contains a chapter setting out the CBI’s authorisation expectations.
European Union (Payment Services) (Amendment) Regulations 2025
On 8 May 2025, the Minister for Finance, Paschal Donohoe, enacted the European Union (Payment Services) (Amendment) Regulations 2025 (S.I. No. 169 of 2025), which amend the principal Regulations, the European Union (Payment Services) Regulations 2018 (S.I. No. 6 of 2018). The main amendments under the Regulations relate to:
Forms for payment institutions
On 12 May 2025, the CBI updated the available forms for payment institutions on its website. The new forms are:
CCR lender FAQs
On 15 May 2025, the CBI updated the frequently asked questions (FAQs) section of the CBI’s Central Credit Register (CCR) website. The updated FAQs set out information relevant to lenders, relating to key areas such as the scope of the Credit Reporting Act 2013 (Number 45 of 2013), qualifying credit applications or qualifying credit agreements, obligations, costs of making an enquiry and access to the lender area.
Speech by Gerry Cross, Director, Capital Markets and Funds, CBI at Blockchain Ireland Summit 2025
On 27 May 2025, Gerry Cross, Director of the Capital Markets and Funds division of the CBI spoke at the 2025 Blockchain Ireland Summit on the topic of technology, innovation and regulation. Director Cross noted the role of the CBI in serving the public interest by maintaining monetary and financial stability whilst ensuring that the financial system operates in the interest of consumers and the wider economy.
On the topic of MiCAR, Director Cross noted that the CBI is at an important cross-roads in its implementation where they are receiving the first waves of authorisation ‘key facts documents’ and formal crypto-asset service provider applications. With regard to relevant developments at EU level, Director Cross noted that they are closely following the European Banking Authority’s work on clarifying the interplay of the Payment Services Directive ((EU) 2015/2366) (PSD2) on payment services in the internal market and MiCAR.
Director Cross then provided an update on the CBI’s Innovation Sandbox Programme, noting that this was successfully launched in 2024 and aims to provide regulatory advice and support to inform the early-stage development of select initiatives that promote better outcomes for consumers and the financial system. The CBI’s Innovation Hub assists innovators in developing financial services with new technologies to navigate the regulatory landscape. The Innovation Hub’s 2024 report will be soon released.
Finally, Director Cross noted that the CBI’s role in fostering innovation includes ensuring that there are no unintended regulatory impediments to tokenisation. In order to ensure a good outcome, the CBI is seeking to understand the risks and ensure that any changes occur in a safe manner whilst maintaining investor protection, market integrity and financial stability.
European Central Bank opinion on a proposal for a regulation to amend the CRR as regards requirements for securities financing transactions under the net stable funding ratio
On 2 May 2025, the European Central Bank (ECB) adopted an opinion on the proposals of the European Commission (EC) to amend the Capital Requirements Regulation ((EU) 575/2013) (CRR) in the areas affecting the prudential treatment of securities financing transactions with a residual maturity of less than six months undertaken with financial customers under the net stable funding ratio (NSFR) in a targeted manner.
The proposed regulations aim to put the current transitory prudential treatment of short-term securities financing transactions (SFTs), and of unsecured transactions undertaken with financial customers, on a permanent footing. The ECB supports a temporary extension of the current treatment in respect of short-term SFTs backed by collateral in the form of Level 1 assets. With regard to short-term SFTs backed by other assets as well as unsecured transactions, the ECB considers that where the current prudential treatment of those transactions will be extended under the proposed regulations, then this should also only be on a temporary basis. The ECB also sets out drafting amendments to the proposed regulation.
The EBA updates technical standards on resolution planning reporting
On 6 May 2025, the European Banking Authority (EBA) published the final draft implementing technical standards (ITS) on resolution planning reporting. The review seeks to achieve full harmonisation of reporting requirements across the EU and to reduce resolution planning reporting obligation costs by avoiding the duplication of data requests.
The ITS enhance the usability of the collected data by resolution authorities. These ITS will repeal Commission Implementing Regulation (EU) 2018/1624 laying down implementing technical standards with regard to procedures and standard forms and templates for the provision of information for the purposes of resolution plans for credit institutions and investment firms pursuant to the Bank Recovery and Resolution Directive ((EU) 2014/59) (BRRD). During Q4 2025, the EBA will publish a technical package that should be used by institutions to submit their resolution planning information to the relevant resolution authorities.
Securities settlement: member states agree position on shorter settlement cycle
On 7 May 2025, EU Member States’ representatives approved the European Council’s negotiating mandate on the European Commission’s proposal to shorten the settlement period for transactions involving transferable securities. The current T+2 (two business days) settlement cycle on securities trades would be shortened to T+1 (one business day) under the European Commission’s proposals.
The European Council amended the Commission’s proposals by exempting SFTs from the proposed shorter settlement period due to the non-standardised settlement periods that parties to such transactions may need to agree upon. However, such an exemption will only apply to SFTs that are documented as single transactions composed of two linked operations. The proposals have now entered the trilogues with the European Parliament. Once agreed, the new rules will apply from 11 October 2027.
EBA updates the report on the monitoring of the liquidity coverage ratio and net stable funding ratio in the EU
On 14 May 2025, the EBA published its updated report on the monitoring of the liquidity coverage ratio (LCR) and NSFR. These updates were identified as being required in light of the March 2023 banking turmoil, following the failures of Silicon Valley bank and Credit Suisse, which highlighted the need for increased supervision of various liquidity aspects. The EBA’s report provides enhanced clarity for the LCR calculation of LCRT inflows from open reverse repos without a maturity date within 30 days. The report also looks at the experience of some banks that experienced an increase in operational deposits but a decrease in excess operational deposits.
Amendments to the TARGET guideline
On 15 May 2025, the ECB announced that the proposed amendments to the TARGET guideline, which would allow non-bank payment service providers (PSPs) to participate in TARGET, have been postponed. It is now envisaged that the amendments to the TARGET guideline, as set out in Decision ECB/2025/2 on access by non-bank PSPs to Eurosystem central bank operated payment systems and central bank accounts, will enter into force in October 2025.
EBA repeals guidelines on the specification of types of exposures to be associated with high risk
On 16 May 2025, the EBA repealed the guidelines on specification of types of exposures to be associated with high risk due to the application of the new Capital Requirements Regulation ((EU) 2024/1623) (CRR3). The guidelines were originally mandated to clarify “high risk exposures”, a class which no longer exists in CRR3. The repeal seeks to clarify and provide certainty that these are no longer applicable.
EBA publishes 2024 report of key achievements and activities
On 20 May 2025, the EBA published the first part of its 2024 Annual Report, setting out the key achievements under its Work Programme over the past year. The key takeaways include:
Parts 2-5 of the Report are awaited, which will detail the implementation of the EBA’s work programme, budget, staff policy plan, management and internal control systems.
EBA consults on proposed amendments to Pillar 3 disclosures under CRR3
On 22 May 2025, the EBA launched a public consultation on proposed amendments to the EC Implementing Regulation on Pillar 3 disclosures under CRR3. The proposal sets out increased disclosure requirements in relation to ESG-related risks, equity exposures and aggregate exposure to shadow banking entities. The aim of the proposal is to support transparency and consistency of disclosures. Institutions will be supported through the initial implementation period of the requirements by transitional provisions which have been introduced. An updated mapping tool between Pillar 3 and supervisory reporting provided by the EBA will also assist institutions in their compliance with disclosure requirements. The consultation runs until 22 August 2025 and responses can be sent to the EBA until this deadline.
EBA publishes onboarding plan to implement the Pillar 3 data hub
On 22 May 2025, the EBA published a Pillar 3 Data Hub Institutions’ onboarding plan (the plan). The implementation is mandated under CRR3 and Capital Requirements Directive ((EU) 2024/1619) and serves as a milestone in the process of the EBA’s commitment to promote market discipline and enhance transparency and consistency in Pillar 3 disclosures.
The plan sets out the steps for accessing and submitting information to the new Pillar 3 Data Hub, to ensure timely and accurate submissions of information. It allows institutions access to the single, centralised platform where the data will be submitted, the EBA EUCLID Regulatory Reporting Platform. It also sets out the phased approach and transitional provisions to allow institutions to prepare for the process. The EBA encourages all relevant institutions to familiarise themselves with the process and begin preparing for the implementation of the Pillar 3 Data Hub.
For more information on these topics please contact any member of A&L Goodbody's Financial Regulation Advisory team.
This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.