Domestic

CBI publishes Protected Disclosures Report for 2025

The Central Bank of Ireland (CBI) published its 2025 Protected Disclosures Report, disclosing that it received 384 whistleblowing reports, comprising 412 individual allegations of wrongdoing in the financial services sector. Of these, 169 allegations progressed to investigation, with 41 contributing to supervisory and enforcement outcomes. A further 11 cases were referred to other agencies, including five relating to suspected criminal offences.

CBI publishes report on ‘trusted flagger’ activities under the Digital Services Act

On 1 April 2026, the CBI published its first report on its activities as a ‘trusted flagger’ under the EU Digital Services Act, covering the period from 2 April 2025 to 31 December 2025. The CBI’s designated area of expertise relates to financial scams and the unauthorised provision of financial services.

During the reporting period, all notices received related to suspected unauthorised financial services or products, with a total of 333 URLs reported. The report provides an overview of the action taken by platforms and reflects the CBI’s role in identifying and disrupting online financial fraud and unauthorised activity.

Government publishes its Summer 2026 Legislation Programme

On 14 April 2026, the Government published its Summer 2026 Legislation Programme, setting out key financial regulation‑related Bills at various stages of development.

Priority legislation includes the National Asset Management Agency (Dissolution) Bill, which will provide for the conclusion of the Irish Bank Resolution Corporation special liquidation and the dissolution of NAMA, including the establishment of a new Resolution Unit within the NTMA, and the Criminal Justice (Violation of Restrictive Measures) Bill to transpose EU Directive 2024/1226 on sanctions offences.

European

ESAs publish guidelines on ESG stress testing methodologies

The European Supervisory Authorities (ESAs) published joint guidelines which aim to ensure that consistency, long-term considerations and common standards for assessment methodologies are integrated into the stress testing of ESG risks pursuant to Article 100(4) of the Capital Requirements Directive (Directive 2013/36/EU) (CRD IV) and Article 304c(3) of Solvency II (Directive 2009/138/EC). The ESAs state that competent authorities should apply the guidelines when conducting supervisory stress tests on ESG risks, including as part of regular frameworks or on an ad hoc basis, where relevant under sectoral legislation.

AMLA consults on business-wide risk assessment and group-wide requirements

On 16 April 2026, the Anti‑Money Laundering Authority (AMLA) launched two consultations under Regulation (EU) 2024/1624 (AML Regulation).

AMLA is consulting on draft guidelines on business‑wide risk assessments (BWRA) under Article 10(4) of the AML Regulation, which will apply to obliged entities across financial and non‑financial sectors. The draft guidelines set out minimum requirements for the content of BWRAs and additional sources of information to be considered when assessing risks arising from business models, customers, products, transactions and geographical exposure. The consultation closes on 15 July 2026.

AMLA is also consulting on draft regulatory technical standards (RTS) on group‑wide AML requirements and measures for third‑country branches and subsidiaries under Articles 16(4) and 17(3) of the AML Regulation. These include minimum requirements for group-wide policies, procedures and controls, information sharing standards, and measures to be taken where third‑country laws prevent compliance with EU AML rules, as well as potential supervisory responses. The consultation closed on 15 June 2026.

AMLA will consider feedback before finalising the guidelines (expected Q4 2026) and submitting the RTS to the European Commission by 30 September 2026.

ECB opinion on Digital Omnibus proposal under the AI Act

On 15 April 2026, the European Central Bank (ECB) issued an opinion on the Commission’s proposed Digital Omnibus Regulation aimed at simplifying and addressing implementation issues under Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (AI Act). The ECB supports reducing regulatory burden and promoting innovation, noting the increasing use of both high‑risk and general‑purpose AI systems by credit institutions and the need for alignment with Union banking law.

The ECB emphasises that supervision and enforcement should remain with market surveillance authorities but highlights the need for close coordination and information sharing with prudential supervisors, including a clear legal basis for such exchange. It also calls for greater clarity on the scope and classification of AI systems, particularly for credit scoring and internal models, warning that overlaps with prudential requirements could lead to inconsistent supervisory outcomes.

ESMA statement on end of MiCAR transitional period

On 17 April 2026, the European Securities and Markets Authority (ESMA) published a statement on the end of the transitional period under the Markets in Crypto‑Assets Regulation (MiCAR), which ended on 1 July 2026. From this date, any entity providing crypto asset services to EU clients without a MiCAR authorisation will be in breach of MiCAR and must cease offering such services. The statement also sets out expectations for crypto asset service providers (CASPs) on wind‑down and client migration, expectations for national competent authorities and a warning to consumers to verify the status of crypto providers.

Commission proposes plan to simplify and strengthen EU lawmaking

On 28 April 2026, the European Commission published a communication document about a plan to simplify EU rules, reduce gold‑plating and improve enforcement. It calls on the European Parliament and the Council of the EU to apply these principles in co‑legislation to reduce overlaps, strengthen the single market and enhance legal certainty.

Date published: 30 April 2026

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.