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Asset Management in Ireland in 2026: A Year in Preview
Against the backdrop of a wide range of EU simplification reforms and rising geopolitical tensions, AIFMD & UCITS reforms taking effect in April, an expected growth of Irish ETFs and ETF share classes within non-listed Irish funds as well as the enhancement of the Irish private assets funds offering in light of significant changes being made to the Central Bank of Ireland's (Central Bank) AIF Rulebook in early 2026, it is shaping up to be another busy year for Irish fund management companies and their funds.
In this briefing we provide an overview of some key dates which should be appearing in the compliance calendars of Irish funds and their management companies1 for 2026 as well as a synopsis of some of the legal and regulatory developments we can expect in the next twelve months2, 3
Key Dates
| Date | Matter | Suggested action to be taken |
|---|---|---|
| 1 January 2026 | Revised framework under the EU Benchmarks Regulation (BMR) begins to apply with the scope of the existing regime being significantly reduced so that only those fund management companies and corporate funds which use (i) benchmarks deemed "critical" or "significant" under the new framework, (ii) EU Paris-aligned benchmarks and EU Climate Transition benchmarks and (iii) certain commodity benchmarks will be subject to obligations thereunder. |
Assess use of benchmarks to determine whether the BMR framework applies in light of the benchmarks used by funds under management. If the fund management company determines that a fund is using an in-scope benchmark within the meaning of the BMR, an appropriate governance framework should be implemented to ensure compliance with the BMR. All fund management companies which "use" any benchmarks within the meaning of the BMR should implement a process to ensure that the ESMA register is periodically checked to confirm that benchmark administrators of in-scope benchmarks used by funds under management appear on that register |
| 31 January 2026 | Deadline for all Irish UCITS management companies and AIFMs to file annual confirmation of ownership with the Central Bank. | Filing of confirmation of ownership to be made with the Central Bank by the deadline. |
| 20 February 2026 | All UCITS which continue to prepare a UCITS KIID must file updated KIIDS which contain updated performance data for the period ended 31 December 2025 and which incorporate any other required revisions with the Central Bank no later than 20 February 2026. | Ensure that all UCITS KIIDs are updated and filed with the Central Bank by the applicable deadline. |
| 28 February 2026 | Deadline for filing the annual fitness and probity (F&P) PCF confirmation and CF certifications for both Irish authorised UCITS management companies/AIFMs and Irish authorised investment funds with the Central Bank under its Fitness & Probity regime. | Ensure that all UCITS KIIDs are updated and filed with the Central Bank by the applicable deadline. |
| 28 February 2026 | Deadline for Irish fund management companies to submit outsourcing registers for record date 31 December 2025. | F&P PCF and CF annual assessments to be carried out, taking account of the revised F&P guidance published by the Central Bank in November 2025. PCF confirmations and CF certifications to be filed with the Central Bank by the applicable deadline. |
| 12 March 2026 | Deadline for responding to the European Commission's Consultation on EU Venture Capital and Growth Capital Reforms. | Irish fund management companies should ensure that their outsourcing registers are completed and submitted to the Central Bank by the applicable deadline. |
| 24 March 2026 | The Central Bank's revised Consumer Protection Code 2025, which includes Standards for Business Regulations and related guidance, begins to apply. | If desired, submit a response to the European Commission by the applicable deadline. |
| 31 March 2026 | Deadline for Irish fund management companies to submit their completed "Registers of Information" on all contractual arrangements with ICT third party service providers to the Central Bank. | Irish fund management companies should ensure that their "Registers of Information" are completed in accordance with applicable EU delegated acts and submitted to the Central Bank by the applicable deadline. |
| March 20264 | Feedback to the European Commission's proposal to reform SFDR5 can be provided here. See "Sustainable Finance" below for further details. | If desired, submit a response to the European Commission by the applicable deadline. |
| Quarter 1 2026 | Central Bank is expected to publish a discussion paper on tokenization. | Those fund management companies and fund promoters who are considering the establishment of tokenized funds or tokenized share classes should provide feedback to the Central Bank's discussion paper once published. |
| 16 April 2026 | Revised Irish UCITS and AIFMD frameworks take effect. See "Implementation of revised Irish UCITS and AIFMD frameworks" below for further details. | Irish fund management companies and Irish domiciled funds should carry out a gap analysis to determine required changes to fund documentation, policies and procedures and operational arrangements to comply with the revised Irish UCITS and AIFMD frameworks. |
| 31 May 2026 | Deadline for filing the fund profile return for all Irish authorised sub-funds with the Central Bank. | Fund profile return to be prepared and filed with the Central Bank by the applicable deadline. |
| 5 June 2026 | Changes made to the EU market abuse framework introduced under the EU Listing Act6 begin to apply. | Funds whose shares are listed or traded on an EU regulated market, multi-lateral trading facility or organised trading facility as well as their management companies and investment managers should assess the changes being introduced to the existing EU market abuse framework and implement any necessary changes to existing policies and procedures to ensure compliance by the applicable deadline. |
| 30 June 2026 | Deadline for any fund falling within the scope of the European Union (Gender Balance on Boards of Certain Companies) Regulations 2025 (Gender Balance Regulations) to ensure that at least 40% of its non-executive directors are members of the underrepresented sex, whether the underrepresented sex is male or female. | Assess whether any fund structured as a PLC under Irish law whose shares are admitted to trading on at least one EU regulated market Member State falls within scope of the Gender Balance Regulations and if in scope, take any necessary steps to ensure compliance by the applicable deadline. |
| 30 June 2026 | Fund management companies which (i) are obliged due to their size; or (ii) which have chosen to report on the principal adverse impacts of investment decisions on sustainability factors under Article 4 of the SFDR must publish a full PAI statement on their website on or before this date. | Relevant PAI statement should be prepared and published by in-scope fund management companies on their website by the applicable deadline. Regard should be had to best practices identified in the most recent ESA report on entity-level PAI reporting published in September 2025. |
| H1 2026 | Central Bank to launch a comprehensive review of the Irish fund service providers (including Irish fund management companies) addressing topics including delegation, outsourcing and governance. | Irish fund management companies are encouraged to monitor this review closely. |
| 2 July 2026 | The new framework under the EU ESG Ratings Regulation7 which amends the SFDR begins to apply. Under the new regime, marketing communications referencing an ESG rating issued by the fund management company or a delegate will be required to include a weblink to detailed information relating to that ESG rating. | Fund management companies should carry out a scoping exercise to establish whether they fall within the scope of the ESG Ratings Regulation by virtue of them issuing proprietary ESG ratings and referencing same in marketing communications. If currently in scope, relevant marketing documentation should (i) be updated to include a link to a website where certain prescribed information on the ESG rating can be accessed or (ii) alternatively revised to remove references to such ESG ratings. |
| 2 August 2026 | The majority of the provisions of the EU AI Act8 begin to apply, including transparency requirements, rules relating to GPAI models and penalties applicable to providers of GPAI models. | Fund management companies using AI models should assess implications of applicable provisions of the EU AI Act and ensure compliance with any such requirements ahead of the applicable deadline. |
Footnotes
1. References to "management companies" or "fund management companies" in this briefing include Irish UCITS management companies, AIFMs, self-managed UCITS funds and internally managed AIF funds unless otherwise indicated.
2. This briefing does not include filing requirements in respect of any filing where the filing date is determined with reference to the relevant entity's annual accounting date (such as the filing of annual and semi-annual financial statements with the Central Bank) nor does it address any tax-related deadlines to which funds and fund management companies may be subject. Periodic reviews of matters such as the content of PRIIPS key investor documents or the risk management framework, business plan and policies and procedures of fund management com panies as well as any other actions required to be taken under the Irish Funds Corporate Governance Code are also excluded from the remit of this briefing. In addition, it does not address other matters where a set date for compliance has not been applied, including for example (i) the obligation imposed on fund management companies which have chosen to implement a shareholder engagement policy under SRD II to pro vide shareholders with information on their website on how that policy has been implemented in the previous 12 months or (ii) the obligation imposed on Irish UCITS management companies (and Irish UCITS SMIC) by the Central Bank to carry out a viability and suitability assessment of each Irish-domiciled UCITS under management when assessing the investment manager's annual presentation.
3. In each case, the dates for filing of returns with the Central Bank are estimated only and may vary from firm to firm. Clients should therefore refer to the details made available on the Central Bank's portal for the specific filing date imposed by the Central Bank for each return.
4. As at the date of this briefing, the closing date for providing feedback to the European Commission has not yet been set as the adopted proposal is not yet available in all EU languages. The feedback period will remain open for 8 weeks after the proposal is made available in all EU languages.
5. Regulation (EU) 2019/2088 as amended
6. Regulation (EU) 2024/2809
7. Regulation (EU) 2024/3005
8. Regulation (EU) 2024/1689
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