Ireland: Insurance Laws and Products

The key provisions introducing Ireland’s statutory “right to be forgotten” regime for cancer survivors are due to come into operation on 15 October 2026, following the making of the relevant commencement order by the Irish Government.

The Central Bank of Ireland resumes domestic collection of outsourcing registers in February 2027 after a two-year pause, while publishing findings from its thematic assessment of fitness and probity frameworks in MiFID investment firms. New regulatory developments include the commencement of 'Right to be Forgotten' insurance legislation, EBA consultation on operational risk management standards, and EIOPA's technical advice on harmonizing insurance guarantee schemes across the EU.

The Insurance (Disregard of Certain Medical History and Miscellaneous Provisions) Act 2026 introduces sweeping changes to the Central Bank of Ireland's regulatory powers over insurers and reinsurers. Beyond the widely discussed "right to be forgotten" provisions for cancer survivors seeking mortgage protection, the legislation fundamentally expands the grounds on which the Central Bank can petition for winding-up orders and extends these powers to cover reinsurers for the first time.

The Central Bank of Ireland has published its first Investment Firm and Intermediary Newsletter for 2026, revealing critical regulatory updates and supervisory priorities for Irish (re)insurance intermediaries. The newsletter addresses sector mapping initiatives, commission disclosure practices, complaints handling procedures, and significant changes to intermediary authorisation requirements that firms must navigate.

The Central Bank of Ireland has completed implementation of all twelve recommendations from Andrea Enria's independent review of the Fitness and Probity approval process, following a 2024 IFSAT finding. These reforms introduce significant structural changes including a new F&P Unit, enhanced guidance materials, and improved transparency measures designed to strengthen fairness and efficiency in regulatory assessments of senior financial services appointments.

The Central Bank of Ireland's 2025 Authorisations and Gatekeeping Report reveals significant insights into regulatory processing times, fitness and probity reforms, and authorisation trends across Ireland's insurance sector. Notable developments include the establishment of a centralised F&P Unit, variations in post-authorisation processing times, and a High Court decision on prohibition notices that underscores the importance of procedural fairness in regulatory enforcement.

The Central Bank of Ireland updates its supervisory framework, the ECB releases its financial stability review highlighting geopolitical risks, and the Basel Committee examines ICT risk management...

On 25 March 2026, the Financial Services and Pensions Ombudsman (“FSPO”) published its Overview of Complaints for 2025 (“Overview”). The Overview provides a summary of the complaints made to the FSPO and reports the trends and patterns in complaints made.

On 12 March 2026, the Central Bank of Ireland (Central Bank) published its first Insurance Quarterly newsletter (Newsletter) of the year. The Newsletter contains several supervisory updates of interest to Irish (re)insurers.