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Welcome to the September 2025 edition of our Asset Management & Investment Funds Update.
In this month's edition we look at:
- Dates & Deadlines: Q3 2025 / Q4 2025
Stay ahead of upcoming deadlines and key dates with our legal & regulatory tracker. - Central Bank of Ireland AIF Rulebook
consultation
The Central Bank of Ireland issued a consultation on the AIF Rulebook on 9 September. There is a significant volume of changes consulted on. The changes proposed to the AIF Rulebook are to align with the themes in the EU's Savings and Investment Union (SIU) initiative, to better support the establishment of private asset funds in Ireland and to remove or update out-dated provisions in the AIF Rulebook that have become out-of-date through passage of time or because of legislative or regulatory developments since last publication of the AIF Rulebook. - Central Bank of Ireland UCITS
consultations
The CBI issued a consultation on both the CBI UCITS Regulations and the CBI Guidance on performance fees for UCITS and certain types of Retail Investor AIFs on 9 September. The proposed amendments update the domestic regulatory framework applicable to UCITS and take account of policy developments since the current CBI UCITS Regulations were published. - Additions to ESAs Q&A on SFDR
The joint European Supervisory Authorities (ESAs) introduced 4 new Q&As to the consolidated Q&A on SFDR in August 2025. - European Commission: Defence spending &
finance
In August 2025, as part of its Defence Readiness Omnibus published in June 2025, the European Commission issued a formal Notice clarifying how the EU sustainable finance framework applies to the defence sector. It specifically covers SFDR, EU Taxonomy, the Benchmark Regulation and MiFID II. Notably, it includes a proposed legislative change to the definition of controversial weapons in Delegated Regulation (EU) 2020/1818, which governs EU Paris-aligned Benchmarks and EU Climate Transition Benchmarks. - Central Bank of Ireland Operational Resilience
guidelines
In July 2025, the CBI published its updated Cross-Industry Guidance on Operational Resilience (Revised Guidance). This update reflects the maturing of operational resilience frameworks within regulated financial services firms and incorporates insights from recent developments, including the implementation of the Digital Operational Resilience Act (DORA) and ongoing industry engagement.
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