Domestic

CBI notice of intention on amendments to MCC regarding knowledge and competence requirements under MiCAR

In March 2026, the Central Bank of Ireland (CBI) published a notice of intention confirming that it will amend the Minimum Competency Code 2017 (MCC) to incorporate the knowledge and competency requirements for staff of crypto-asset service providers (CASPs) who provide information or advice on crypto-assets or crypto-asset services under the Markets in Crypto Assets Regulation (MiCAR). The amendments will reflect the European Securities and Markets Authority (ESMA) guidelines on knowledge and competency assessment criteria for MiCAR, published in January 2026.

The proposed amendments will be implemented by way of an addendum to the MCC and will apply from 28 July 2026. The CBI will also consider whether any consequential amendments are required to the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) Minimum Competency Regulations 2017.

CBI publishes discussion paper on DLT and tokenisation in financial services

On 5 March 2026, the CBI published Discussion Paper 12 examining the potential role of distributed ledger technology (DLT) and tokenisation across the financial services sector. The paper seeks stakeholder input on how these technologies could transform financial market infrastructure, products and service delivery, while remaining consistent with monetary and financial stability, consumer protection and market integrity objectives. Submissions are invited until 5 June 2026, after which the CBI intends to publish a feedback statement.

The discussion paper covers tokenisation across capital markets, investment funds, money and payments, and focuses on assessing opportunities, risks and key enablers, including legal and regulatory clarity, operational resilience, scalability and interoperability. Deputy Governor Vasileios Madouros, commenting on the publication, emphasised that while tokenisation could support the EU’s Savings and Investments Union agenda, technology alone is insufficient and central bank money must remain at the heart of a future tokenised financial system.

Revised Consumer Protection Code enters into force

On 24 March 2026, the CBI's revised Consumer Protection Code (CPC) entered into force following a 12-month implementation period. The revised CPC modernises and consolidates the previous CPC 2012, the Code of Conduct on Mortgage Arrears 2013 and other standalone consumer protection codes into a single, updated framework. It comprises two statutory instruments: the Standards for Business Regulations 2025 and the Consumer Protection Regulations 2025.

The revised CPC introduces new requirements in several areas including digitalisation, the protection of consumers in vulnerable circumstances, and the prevention of financial abuse (including fraud and scams). It also raises the definition of "consumer" to include corporate entities with annual turnover of less than €5m, increased from the previous €3m threshold.

FSPO publishes overview of complaints for 2025

On 25 March 2026, the Financial Services and Pensions Ombudsman (FSPO) published its overview of complaints for 2025. A record 7,004 complaints were received during the year, representing a 13% increase on 2024 and a 46% increase since 2022. The FSPO also closed a record 6,282 complaints, with outcomes totalling €6.2m.

The banking sector remained the most complained‑about sector, accounting for 54% of complaints (up 12% year‑on‑year), followed by insurance at 31% (an 18% increase on 2024) and the investment sector at 7%. Growth in complaints was driven primarily by motor insurance‑related issues and an ongoing increase in banking complaints concerning disputed transactions. Customer service was the most frequently cited conduct issue, featuring in 19% of complaints.

Tracker mortgage‑related complaints continued to decline, with 11 new complaints received in 2025 and 143 closed. Of the 115 legally binding decisions issued in tracker cases, 111 were not upheld. The average time to close complaints in 2025 was 8.3 months.

European

AMLA publishes final draft RTS on risk assessment and selection for direct supervision

In March 2026, the Anti‑Money Laundering Authority (AMLA) published two final reports containing draft regulatory technical standards (RTS) under the EU AML legislative package. The RTS address:

• the assessment of inherent and residual risk profiles of obliged entities pursuant to Article 40(2) of the sixth Anti-Money Laundering Directive
• the risk‑based methodology for selecting financial institutions for AMLA direct supervision under Article 12(7) of the AML Regulation

The RTS set out the criteria and indicators AMLA will use to assess ML/TF risks across obliged entities and to determine which institutions will fall within AMLA’s direct supervisory remit.

Date published: 23 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.