Horizon Scanner Finance July 2026 - Irish Developments

AMLD6

Directive (EU) 2024/1640 of the European Parliament and of the Council of 31 May 2024 on the mechanisms to be put in place by Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Directive (EU) 2019/1937, and amending and repealing Directive (EU) 2015/849 (AMLD6) entered into force on 9 July 2024.

Member States are required to adopt transposing measures to implement Articles 11, 12, 13 and 15 of AMLD6 by 10 July 2026. These articles relate to access to beneficial ownership registers, in particular the rules permitting natural or legal persons that can demonstrate a legitimate interest in the prevention and combating of money laundering and terrorist financing access to a more limited subset of the information stored on the relevant register.

Ireland’s three beneficial ownership registers are the Central Register of Beneficial Ownership of Companies and Industrial & Provident Societies (RBO), administered by the Companies Registration Office, the Central Register of Beneficial Ownership of Trusts (CRBOT), administered by the Revenue Commissioners, and the Beneficial Ownership Register of Certain Financial Vehicles, administered by the Central Bank of Ireland (the CBI).

Member States are required to notify to the European Commission (the Commission) of the following information by the 10 July 2026 deadline:

• the list of public authorities that are entitled to consult beneficial ownership information pursuant to Article 12(2)(f) – (i) of AMLD6; and
• any additional category of persons who have been found to have a legitimate interest to access beneficial ownership information.

The Commission will make the above information available to the other Member States.

Ireland has yet to publish its transposing measures in relation to the above.

Credit Review Act

The Credit Review Act 2026 (Commencement) Order 2026 (S.I. No. 277 of 2026) (PDF 138 KB) (the Commencement Order) was published on 17 June 2026. The Commencement Order sets out the relevant commencement dates for the Credit Review Act 2026 (the Act), these being:

• 24 June 2026 for Part 1 (other than section 6), and sections 8, 25, 28 and 29
• 1 July 2026 for the remainder of the Act

The Credit Review Act establishes An tSeirbhís um Athbhreithniú Creidmheasa (the Credit Review Service) as an independent statutory body which will review declined credit applications for small and medium-sized enterprises and farms. The Credit Review Service is also charged with reviewing the lending practices, activities and policies of participating banks and publishing informative materials on credit markets for the benefit of borrowers.

New Merger Control Thresholds

From 1 July 2026, a transaction requires notification to the Competition and Consumer Protection Commission (CCPC) under the Competition Act 2002 (as amended) where the following thresholds apply:

• the aggregate turnover in the Republic of Ireland of the undertakings involved is at least €100 million (previously €60 million); and
• the turnover in the Republic of Ireland of each of at least two undertakings is at least €15 million (previously €10 million).

Transactions meeting these mandatory notification thresholds must be notified prior to implementation and cannot be completed until cleared. As there are no transitional provisions, transactions will be assessed against the revised thresholds from 1 July 2026.

The increase in thresholds reflects a clear policy objective focusing merger reviews on transactions with a higher likelihood of raising substantive competition concerns. The reform is also intended to reduce the regulatory burden and transaction costs associated with smaller and non‑problematic transactions.