ARTICLE
7 April 2026

Looking Ahead: Irish Developments

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Arthur Cox

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Arthur Cox is one of Ireland’s leading law firms. For almost 100 years, we have been at the forefront of developments in the legal profession in Ireland. Our practice encompasses all aspects of corporate and business law. The firm has offices in Dublin, Belfast, London, New York and Silicon Valley.
The Central Bank of Ireland (CBI) has published its Regulatory & Supervisory Outlook Report for 2026, setting out the key risks identified across the financial sector and its supervisory priorities for the year ahead.
Ireland Finance and Banking
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Central Bank of Ireland's Regulatory & Supervisory Outlook Report

The Central Bank of Ireland (CBI) has published its Regulatory & Supervisory Outlook Report for 2026, setting out the key risks identified across the financial sector and its supervisory priorities for the year ahead. The report is published against a backdrop of significant geopolitical, macroeconomic and technological change, and sends a clear message to firms of the importance of resilience, adaptability, and trustworthiness.

SUPERVISORY PRIORITIES FOR 2026

  1. Geopolitical and macro-financial resilience: Firms must demonstrate they can withstand a volatile external environment.
  2. Consumer and investor protection: Acting in the best interests of customers remains a core expectation.
  3. Technology-driven transformation: AI, digital money, tokenisation and crypto-asset service providers (CASPs) under MiCA are under heightened scrutiny.
  4. Environmental and societal transitions: Climate risk supervision is expanding in scope.
  5. Enhanced regulation and supervision: The CBI itself is evolving how it regulates and supervises firms.

For more information on the report, including sector specific insights, read our insights post here: Central Bank Regulatory & Supervisory Outlook 2026: Focus areas for the year ahead

For an analysis on how the report relates to the Funds sector, please see our insights post here: Central Bank’s Regulatory & Supervisory Outlook 2026: Funds Sector Impact

AIFMD II - Loan-originating AIFs

April marks a key milestone for alternative investment fund managers (AIFs) as the provisions of the Alternative Investment Fund Managers Directive II (AIFMD II) will apply from 16 April 2026. Of particular significance for our clients operating or structuring loan-originating AIFs will be the new dedicated requirements for loan-originating AIFs including the imposition of leverage limits designed to manage systemic risk and a 5% risk-retention obligation applying to originated loans that are subsequently sold to third parties.

For more information on the main changes, actions required, and timelines for compliance, read our Asset Management and Investment Funds briefing here: AIFMD II loan origination rules: What’s new?

Deposit Guarantee Scheme: Contribution methodology

The Central Bank of Ireland’s (CBI) consultation on the methodology for calculating contributions to the Deposit Guarantee Scheme (DGS) closes on 17 April 2026.

The CBI is proposing to change the method used to calculate annual contributions to the DGS from the current “flow‑based” approach to a “stock‑based” approach, to take effect from Q3 2026.

The driver behind this proposed change is twofold:

  • Updated European Banking Authority (EBA) Guidelines: The EBA issued new Guidelines in 2023, applicable from 3 July 2024, which introduced several amendments to the calculation methodology, including adjustments to formula components and a requirement to regularly review and calibrate calculation methods. These updated guidelines also detailed the application of an alternative stock-based approach to calculating contributions, which takes account of member institutions’ past contributions - something not available under the original 2016 EBA guidelines.
  • DGS Fund reaching its target: The Irish DGS Fund reached its required target level (0.8% of covered deposits) in July 2024, prompting the Central Bank to review its approach to the calculation of DGS contributions.

In changing to a stock-based approach, each member institution’s cumulative past contributions will be considered when deciding whether further contributions are required. This also introduces the possibility that a member institution’s past contributions could place it in credit against future contributions.

The overall aim of this proposed change is one of increased proportionality. Importantly, the DGS Fund target remains unchanged and the depositors' protection by the DGS is unaffected.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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