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Noeleen Ruddy
Partner
Ireland
This update is brought to you by our Finance & Capital Markets practice group in Ireland.
Our aim is to keep you informed of the fast-evolving legal landscape, from new legislation and guidance to significant case law and observations.
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Securities and markets
ELG and CIFS Schemes revoked
16 December 2025 – The Credit Institutions (Financial Support) Scheme 2008 and Credit Institutions (Eligible Liabilities Guarantee) Scheme 2009 were introduced to allow covered banks to issue State-guaranteed debt during the financial crisis. These measures were revoked by Credit Institutions (Financial Support) (Revocation) Scheme 2025 and the Credit Institutions (Eligible Liabilities Guarantee) (Revocation) Scheme 2025, respectively.
Selection procedure for CTP
5 January 2026 – The European Securities and Markets Authority (ESMA) launched its first selection procedure for a consolidated tape provider (CTP) for over-the-counter (OTC) derivatives under the Markets in Financial Instruments Regulation (EU) 600/2014. The deadline for tenders is 11 February 2026 with a reasoned decision on the selected applicant to expected be adopted in July 2026.
Euronext Derivatives Markets: Trading procedures updated
7 January 2026 – Euronext updated the annexes to its Notice 5-01 Euronext Derivatives Markets: Trading Procedures. The latest version includes the following, all of which apply from 2 February 2026.
- Updated Annex 1 (Trading arrangements).
- New Annex 4 (Special provisions applicable in respect of order management and trade registration).
- New Annex 5 (Special provisions for Power Futures contracts).
ESMA-SCA MoU on supervision of CRAs
15 January 2026 – ESMA and the Securities and Commodities Authority (SCA) of the United Arab Emirates have entered into a Memorandum of Understanding regarding arrangements for the cooperation and exchange of information related to credit rating agencies whose cross-border activities may subject them to regulation and supervision by both ESMA and SCA.
EESC opinion on amendments to securitisation framework
16 January 2026 – The European Economic and Social Committee (EESC) published a second opinion (Opinion) on the European Commission's (the Commission) legislative package to revive the EU securitisation market. The Opinion recommends, amongst other things, the following.
- Inclusion of standardised ESG information in securitisation reporting templates.
- That the Commission and Council of the EU (the Council) support harmonised supervision of securitisations pending introduction of more centralised supervision.
- An assessment system for supervisors to track the application of "'reed-up capital' generated by the proposed amendments to funding EU companies, households and SMEs.
- Ensuring that making risk weight floors risk-sensitive does not lead to modelling risk or arbitrage.
- Reversing the proposed risk retention waiver where a first loss tranche is guaranteed by a public entity.
ECB guidelines on Eurosystem operations amended ICMA paper on stablecoins in capital markets
20 January 2026 – The International Capital Markets Association (ICMA) published a paper examining whether stablecoins represent a credible development for capital markets infrastructure.
ESMA-BRB MoU on CCPs
27 January 2026 – ESMA and the Reserve Bank of India (RBI) entered into a Memorandum of Understanding to facilitate cooperation and exchange of information for the recognition of central clearing counterparties (CCPs) established in India and supervised by RBI. This ended a two-year impasse over access for EU clearing members to Indian CCPs. It will also allow the Clearing Corporation of India to reapply to ESMA for recognition as a CCP under the European Markets Infrastructure Regulation (EU) 648/2012) (EMIR).
DLT-based assets eligible as Eurosystem collateral
27 January 2026 – The European Central Bank (the ECB) announced that from 30 March 2026, the Eurosystem will accept marketable assets issued in central securities depositories (CSDs) using distributed ledger technology (DLT) as eligible assets for Eurosystem credit operations. Such assets must comply with the Eurosystem's standard collateral eligibility criteria and collateral management requirements.
27 January 2026 – The ECB published draft guidelines relation to Eurosystem credit operations as follows.
29 January 2026 – The Central Bank of Ireland (the CBI) has published its first Markets Update of 2026. This publication describes the CBI's new authorisation process for alternative investment fund managers (AIFMs) managing loan-originating alternative investment funds (AIFs).
Sustainability
Taxonomy regulation delegated acts amended
8 January 2026 – Commission Delegated Regulation (EU) 2026/73 (the Amending Act), which was adopted by the Commission in July 2025, has been published in the Official Journal of the EU. The Amending Act seeks to support the application the EU Taxonomy across the EU by reducing administrative burdens and simplifying reporting obligations. To this end, it amends three delegated acts made under the Taxonomy Regulation: (i) the Disclosures Delegated Act (Commission Delegated Regulation (EU) 2021/2178); (ii) the Taxonomy Climate Delegated Act (Commission Delegated Regulation (EU) 2021/2139); (iii) Taxonomy Environmental Delegated Act (Commission Delegated Regulation (EU) 2023/2486).
The Amending Act entered into force on 28 January 2026 but applies from 1 January 2026. In-scope undertakings can apply the amended reporting regime for the financial year 1 January – 31 December 2025.
ESAs joint guidelines on ESG stress testing
8 January 2026 – The European Supervisory Authorities (being ESMA, European Banking Authority (the EBA) and the European Insurance and Occupational Pensions Authority) have now published joint Guidelines (the Guidelines) on environmental, social, and governance (ESG) stress testing. The Guidelines apply to competent authorities that supervise financial entities subject to the Capital Requirements Directive (2013/36/EU) or the Solvency II Directive (2009/138/EC) and seek to ensure that ESG risks are integrated by such competent authorities into their national stress testing activities on a consistent basis. They do not create a new requirement to conduct ESG supervisory stress tests. The Guidelines follow a public consultation in Q3 2025 and will be apply on a "comply or explain" basis.
Updated sustainable finance implementation timeline
13 January 2026 – ESMA published an updated version of its sustainable finance implementation timeline, to reflect, amongst other things, the impact of the Stop-the-Clock Directive (EU) 2025/794 on reporting obligations under the Corporate Sustainability Reporting Directive (EU) 2022/2464 and the Corporate Sustainability Due Diligence Directive (EU) 2024/1760.
Prudential & supervision
Draft RTS on TCB booking arrangements – CRD VI
9 January 2026 – The EBA has published its Final Report on draft regulatory technical standards (RTS) on booking arrangements for third-country branches (TCB) under Article 48h of Directive 2013/36/EU (CRD IV) as inserted by Directive (EU) 2024/1619 (CRD VI). The RTS specify the following.
- Accounting framework to be used by TCBs.
- Bookkeeping requirement to identify and record all assets and liabilities booked or originated and off-balance sheet items.
- Minimum information to be recorded to provide a comprehensive overview of those assets and liabilities.
- Information to be maintained on the risks stemming from the activities of the TCB and their management.
- The transposition date for CRD VI is 10 January 2026, with the TCB regime applying from 11 January 2026. Work is ongoing in Ireland in relation to the implementation of CRD VI.
Updated guidance on Schedule 2 registration form
15 January 2026 – The CBI published an updated version of its Guidance for Completion of the Schedule 2 Anti-Money Laundering/ Countering the Financing of Terrorism Registration Form. The notes on completion now include requirements to confirm (i) Section 110 status; and (ii) whether the registering firm is currently reporting statistical data to the CBI under Section 18 of the Central Bank Act 1971.
Work programme of Joint Bank Reporting Committee for 2026
19 January 2026 – The Joint Bank Reporting Committee of the ECB has published its Work Programme for 2026. Its main priorities include the following.
- Continued prioritisation of tasks related to developing an integrated reporting system.
- Preparatory work on a common data dictionary.
- Investigation of options for achieving proportionality in reporting requirements without impairing data quality.
EBA consultation – amendments to guidelines on systemic risk buffer
29 January 2026 – The EBA launched a public Consultation on draft amendments to its guideline (EBA/GL/2020/13) on the appropriate subsets of sectoral exposures to which competent or designated authorities may apply a systemic risk buffer (SyRB). The proposed amendments are intended to: (i) facilitate the application of SyRB measures to exposures subject to climate risk; and (ii) improve the design, monitoring and reciprocation of SyRB measures by incorporating "lessons learned" by national authorities that have previously applied SyRB measures. The deadline for responses is 30 April 2026.General
Bulgaria introduces euro1 January 2026 – Bulgaria introduced the Euro on 1 January 2026, becoming the 21st euro area member. The Bulgarian National Bank simultaneously joined the Eurosystem and became a full member of The Single Supervisory Mechanism. This follows the Decision of the ECB made on 8 July 2025, which announced the official conversion rate of 1.95583 Bulgarian lev per 1 euro.
Accessions to Hague Convention on Choice of Court Agreements
2 January 2026 – The Choice of Court (Hague Convention) Act 2015 (Section 2) (Amendment) Order 2025 (the 2025 Order) has amended the Choice of Court (Hague Convention) Act 2015 (Section 2) Order 2022 to update the list of states which are bound by the Hague Convention on Choice of Court Agreements 2005, to include Albania, Bahrain, North Macedonia, Republic of Moldova, Switzerland and Ukraine.
ESMA tips for finfluencers
8 January 2026 – ESMA published six tips for finfluencers on the responsible promotion of financial products. In short: influence responsibly, label promos, check facts, cite reliable sources, mention risks alongside rocket emojis and don't pretend to be an expert.
Government legislation programme – Spring 2026
13 January 2026 – The Department of the Taoiseach has published the Government Legislation Programme for Spring 2026.
Legislation listed for priority publication includes the Conclusion of IBRC Special Liquidation and Dissolution of NAMA Bill. This measure would effect the conclusion Irish Bank Resolution Corporation's special resolution, the dissolution of the National Asset Management Agency and implement arrangements to manage any residual activities of these entities.
Legislation listed for priority drafting includes the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill, to transpose elements of the EU's sixth anti-money laundering package; and the Civil Reform Bill which would reform the judicial review mechanism and streamline other key courts processes,.
Speech by FSB Secretary General John Schindler
28 January 2026 – Financial Stability Board Secretary General John Schindler delivered a speech at a seminar hosted by the Volatility and Risk Institute and Center for Global Economy and Business of Stern School of Business at New York University. Mr Schindler shared his thoughts on: (i) the importance of not misusing the term "nonbank"; (ii) the growing significance of nonbanks in the financial system and their role in recent periods of market turmoil; and (iii) how the sector should be regulated.
Speech by ESMA Chair Verena Ross
28 January 2026 – ESMA Chair Verena Ross delivered a speech entitled The Vital Need for Growth & the Role of Capital Markets in Europe's Strategic Renewal at the European Banking Summit. She discussed, amongst other things: (i) the unused potential of capital markets in driving growth; (ii) the SIU strategy as a roadmap for capital markets reform; and (iii) the EU's recently announced market integration package.
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