Domestic

D&I board effectiveness review: CBI thematic review of fund management companies

On 21 April 2026, the Central Bank of Ireland (CBI) published its feedback report on a thematic review of board effectiveness in the fund management company sector, assessed through a diversity and inclusion (D&I) lens. The CBI emphasises that its findings are relevant across all regulated firms and reiterates that effective governance and D&I are key components of board effectiveness. The report examines areas including board composition, evaluation processes, decision‑making and succession planning, and sets out expectations for firms to review the findings, assess their governance frameworks and take steps to address any identified gaps or weaknesses.

CBI thematic review of outsourcing risk for fund administrators and depositaries

The CBI published a “Dear CEO” letter setting out the findings of its thematic inspection of outsourcing risk management by fund administrators and depositaries. The inspection assessed the outsourcing oversight frameworks established by fund administrators and depositaries taking into consideration the good practices for the effective management of outsourcing risk outlined in the CBI’s Cross-Industry Guidance on Outsourcing. For fund administrators, the review also considered the ‘Outsourcing Regulations’ in Part 4 Chapter 2 of the Investment Firms Regulations 2023 and the CBI’s related guidance. The CBI requires the letter to be brought to the attention of the board or management body. Fund administrators and depositaries should review their existing outsourcing frameworks against the good practices identified and consider what enhancements may be required.

Fitness and Probity

In April 2026, the High Court published its written judgment relating to the CBI’s application under the fitness and probity regime to confirm a one-year prohibition issued to a senior executive concerning the individual’s role in a regulated firm in the investment fund and asset management sector. The High Court refused the application. Under the fitness and probity regime, the CBI is required to apply to the High Court to confirm a prohibition if the individual concerned does not agree to comply with a prohibition notice imposed by the CBI. The High Court found that the senior executive’s entitlement to natural and constitutional justice and basic fairness of procedures was not observed by the CBI during its investigation into the individual’s fitness and probity.

European

European Commission adopts RTS under EU Ratings Regulation

The European Commission adopted two draft Delegated Regulations supplementing the ESG Ratings Regulation.

• Draft Delegated Regulation with regard to Regulatory Technical Standards (RTS) specifying the measures and safeguards to be implemented by ESG rating providers to separate their ESG rating activities from their other activities.
• Draft Delegated Regulation with regard to RTS specifying the elements of ESG rating products to be disclosed to the public and to users of ESG ratings, rated items and issuers of rated items.

The Commission also adopted draft Delegated Regulations on fees to be charged by the European Securities and Markets Authority (ESMA) to ESG rating providers and on rules of procedure on fines and periodic penalty payments imposed by ESMA on ESG rating providers.

Delegated Regulations on disclosures and trading under MAR

The European Commission adopted the following Delegated Regulations:

1. Delegated Regulation supplementing the Market Abuse Regulation (MAR) as regards disclosure of inside information in protracted processes and delay of disclosure. The amendments introduced by the Listing Act exclude intermediate steps in protracted processes from the disclosure obligation and clarify when delayed disclosure is permitted.
2. Delegated Regulation amending Delegated Regulation (EU) 2016/522 as regards the permission for trading during closed periods, the list of designated trading venues that have a significant cross-border dimension in the supervision of market abuse, and the indicators of market manipulation.

ESMA call for evidence on restricted subscription and private credit ratings

ESMA launched a call for evidence to gather stakeholder views on the purposes, market practices, needs and risks associated with restricted subscription and private credit ratings. ESMA is encouraging all interested stakeholders to share views, data and analysis.

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.