The Central Bank of Ireland's Strategic Plan 2019-2021 sets out five key themes for the next three years, and highlights Brexit, and implementing a new approach to regulating financial conduct, as key focus areas.

The last three years have seen the establishment of the Central Bank as "the effective steward of the Irish financial system" as one of its key priorities. For 2019- 2021, while the Central Bank is focused on consolidating the policy framework that it implemented in recent years in response to the financial crisis, it also sees two of its biggest challenges as Brexit, and implementing a new approach to the regulation of financial conduct.


The five strategic themes identified by the Central Bank for 2019-2021 are:

  • Brexit
  • Strengthening Consumer Protection
  • Strengthening Resilience
  • Engaging and Influencing
  • Enhancing Organisational Capability

Regarding Brexit, the Central Bank is focused on ensuring that the authorisation process for all firms is "robust and effective", while ensuring that the entities it regulates are prepared for Brexit and are protecting the best interests of their customers. One of its key priorities continues to be the mitigation of the immediate and longer- term risks posed by Brexit.

Regarding consumer protection, "robust" enforcement action, together with "intrusive and targeted" assessments of both regulated entities and their products, will continue to be a key focus area. Both culture and individual accountability are mentioned, echoing the comments made by the Central Bank's Director of Enforcement and Money Laundering, Seana Cunningham in August 2018 regarding the Central Bank's proposal to the Minister for Finance for both an accountability regime for senior executives, and enhancements to its existing 'fitness and probity' regime. The continued work to combat market abuse, money laundering, terrorist financing, and the provision of unauthorised financial services is also highlighted.

Regarding resilience, addressing mortgage arrears and non-performing loans continues to be a key theme, as is effective supervision and the management of failing firms.

Other key takeaways from the Strategic Plan are the Central Bank's continuing emphasis on having effective crisis management arrangements in place to address any potential future financial crisis, and identifying the opportunities and risks posed by FinTech.

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.