Central Bank Of Ireland Report On Fund Management Company Delegation

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The Central Bank of Ireland has published its findings and expectations following a review of delegation in the Irish funds sector.

Overview

Delegation is a subject of ongoing supervisory focus at both EU and domestic level. Increased reporting relating to delegation arrangements is due to apply from April 2027 for both UCITS and alternative investment funds (“AIFs”) under the revised Alternative Investment Fund Managers Directive (“AIFMD 2.0”). Under the EU’s Market Integration and Supervision Package (“MISP”), the European Commission has proposed that arrangements where management companies / AIFMs rely on EU group entities to perform functions do not qualify as delegation and are not therefore subject to delegation requirements.

Reflecting this ongoing focus at EU level, the Central Bank of Ireland (“Central Bank“) launched a review of delegation practices in 2025 within the Irish funds sector, examining fund management companies (“FMCs“) authorised in Ireland, with a particular focus on governance, oversight arrangements and the effectiveness of control frameworks in managing delegated activities. The review forms part of the Central Bank’s ongoing supervisory engagement with the sector and builds on its earlier thematic work on the effectiveness of FMCs and their operational frameworks. On 23 July 2026, the Central Bank published its feedback report setting out its findings and expectations.

The review encompassed a desk-based review of approximately 40 FMCs covering around 4,600 investment funds, together with on-site inspections of 21 FMCs providing coverage of 40% of assets under management across approximately 3,000 investment funds.

Overall finding: broadly positive

The report acknowledges the important role of delegation in supporting the optimal functioning of European capital markets and in enabling firms to access specialised expertise, global investment capabilities and operational efficiencies.

The review found that, in general, FMCs operating a delegation model have good governance frameworks, controls, oversight processes and data capabilities in place, reflecting important progress made in recent years, including in the implementation of the Central Bank’s Fund Management Companies Guidance.

The thematic review found that FMCs are in compliance with regulatory requirements and largely meet supervisory expectations. However, a small number of FMCs fell materially short of supervisory expectations and are now subject to appropriate, time-bound risk mitigation programmes to remediate identified deficiencies. The review identified a number of FMCs which require certain elements of their governance arrangements and operating models to be improved, listing board independence, over-reliance on group level committees, resourcing concerns, lack of contingency planning and limitations with data access as areas for enhancement.

Key themes and findings

Theme	Key findings	Expectations
Governance	Quality of governance arrangements was good across the sector, with appropriately diverse boards demonstrating appropriate levels of oversight and challenge. Areas requiring improvement include: insufficient board independence, particularly where group influence was excessive or directors served beyond best-practice tenure limits; resource gaps where designated persons were not sufficiently senior or held too many roles; over-reliance on group-level committees where local representatives had limited ability to challenge delegate decisions independently; and some FMCs operate with informal governance practices, lacking documented policies and procedures including entity-specific risk statements.	FMCs must have sound governance frameworks, fit for purpose for their business and operating model. The FMC board must ensure the firm has not delegated its functions to such an extent that it is unable to effectively manage the fund or exercise sufficient authority over decision-making. Robust governance and control frameworks are critical.
Portfolio management	Where portfolio management activities are delegated, oversight was robust and generally well executed, with firms implementing structured monitoring, comprehensive reporting and clear escalation pathways. Weaknesses identified included: limited autonomy in oversight and decision-making at some FMCs; unstructured approaches, lacking documented procedures, performance standards and regular monitoring; and insufficient attention to establishing wind-down or transition procedures where a third-party portfolio manager is unable to continue its mandate.	FMCs must ensure effective oversight and control frameworks are in place for portfolio management activities. FMCs must clearly demonstrate their active decision-making responsibility through documented governance processes and decisions for both delegated and retained portfolio management.
Risk management	Risk management activity is largely retained by FMCs, with frameworks generally well-established and underpinned by clear policies and procedures. FMCs demonstrated independent verification of delegated risk activities, including shadow checks with real-time data access and pre-trade compliance controls. Weaknesses identified included: gaps in risk management resourcing; and inability to demonstrate robust independent challenge or access to real-time data, relying instead on delegate reporting – with timely and accurate data access emerging as a material differentiator in framework effectiveness.	Each FMC must implement effective risk management frameworks reflecting its operating model, the complexity of the investment strategy, and the nature of the underlying portfolio, clearly distinguishing between activities retained and those that are delegated. Where aspects are delegated, appropriate depth of verification of delegate outputs must be retained. There must be a well-considered balance between portfolio management and risk management delegation so that the overall degree of delegation is not disproportionate.
Delegate oversight	Delegate oversight frameworks were in place across the sector, with FMCs demonstrating effective delegate accountability, compliance and performance management supported by clear monitoring procedures and regular performance assessment. Weaknesses identified included: instances of FMCs relying on group processes for delegate due diligence rather than conducting their own direct assessment; and insufficient involvement of designated persons and operational risk functions in delegate oversight.	FMCs must retain clear decision-making authority and control over all delegated activities, underpinned by a robust, documented oversight framework. A consistent due diligence methodology must be applied across all delegates, including sub-delegates, with appropriate on-site engagement. FMCs should not rely solely on due diligence questionnaires or self-reporting by the delegate.
Data capabilities	For the most part, FMCs recognised the importance of robust data management practices supported by clear governance frameworks and quality standards. An increasing awareness and use of data as a strategic asset was observed, with reliance on automated reporting and business intelligence tools rising. Weaknesses identified included: a fragmented approach to data integration, with disparate systems resulting in manual reconciliation; engaging delegates for pre / post trade controls and elements of investment and borrowing restriction monitoring, including instances of overriding internal risk limits; and inadequate contingency arrangements to manage potential data loss or interruption.	FMCs must ensure appropriate data delivery and data management practices are in place to facilitate access to timely and accurate data to support effective decision-making and oversight of delegates. FMCs should address any gaps in strategy, integration, data governance and data reporting effectiveness that could impact execution of their fund management responsibilities.

Action required

All FMCs are expected to consider the contents of the report with input from the FMC board, conduct a gap analysis against the supervisory expectations set out therein, and put in place a time-bound plan by year end to address any deficiencies identified in their operational, resourcing and governance arrangements in respect of delegation.

Upcoming regulatory developments

The Central Bank has announced that it will engage in a review of governance arrangements for FMCs this year, including enhancements to the current framework as regards delegation, taking account of the changing nature, scale and complexity of the sector, the risk environment and the findings from the Central Bank’s supervisory work. Areas in scope include simplifying existing guidance, reinforcing the pre-approval controlled function (“PCF”) framework for FMCs, enhancing governance requirements, and considering the proportionate application of the Individual Accountability Framework (“IAF“) / Senior Executive Accountability Regime (“SEAR“) to the funds sector.

Comment

It is positive to see regulators recognising the important role of delegation in enhancing investor outcomes by allowing FMCs to leverage experienced portfolio managers and service providers across jurisdictions, facilitating diversified investment opportunities and efficient capital allocation. Robust governance and oversight arrangements are clearly critical in ensuring the ongoing effectiveness and positive role of delegation in supporting the optimal functioning of EU capital markets.

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