Niall Esler
Partner
Ireland
Key Takeaways
These changes follow the publication of a report by Mr. Andrea Enria, former Chair of ECB Supervisory Board (Enria Report) which contains a package of 12 recommendations published in 2024 as part of a review of the F&P gatekeeping framework.
The Central Bank has published the following documents as part of the proposed changes to the F&P regime:
The Draft F&P Guidance consolidates all the guidance into a single document and introduces a number of enhancements to its existing Guidance on the F&P Standards.
Specifically, the Central Bank proposes to ensure industry understanding of the F&P assessment process by providing enhanced guidance in the following areas:
The F&P Gatekeeper Process Manual clarifies the stages of the F&P process, including the process that existing regulated entities and those seeking authorisation can expect from the Central Bank. In particular, the F&P Gatekeeper Process Manual provides for detailed information regarding the F&P interview process, including:
The Implementation Report outlines the actions taken by the Central Bank to date in strengthening the F&P gatekeeping process against the recommendations in the Enria Report.
The consultation will remain open until 10 July 2025. The Central Bank will host an industry stakeholder meeting on F&P gatekeeping in Q2 2025 alongside ad hoc sectoral engagements, when required.
Throughout 2025 and 2026, the Central Bank will carry out a more substantive review of the PCF list to be coordinated with the planned three-year review of SEAR in 2027.
For further information please speak with your usual contact or any of the contacts listed on this page.
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