On 4 June 2026, the Central Bank of Ireland (the Central Bank) published the first edition of the Investment Firm and Intermediary Newsletter for 2026 (the Newsletter).

The Newsletter contains a number of important regulatory updates for Irish (re)insurance intermediaries and provides insight into the Central Bank’s current supervisory priorities. Key themes include sector mapping, commission disclosures, complaints handling, and updates to intermediary authorisation requirements.

Mapping and Profile Review of the Retail Intermediary Sector

The Central Bank has commenced a sector-wide mapping and profiling exercise to gain a more comprehensive understanding of the retail intermediary sector and to support future supervisory strategies.

The exercise will gather information on firms’ ownership and organisational structures, business models and product offerings, governance arrangements, and operational and outsourcing activities. The information collected will help the Central Bank build an enhanced profile of the sector, identify emerging trends and areas of supervisory focus, and better understand how firms operate and compare across the market.

Review of Commission Disclosures

The Newsletter sets out the findings of the Central Bank’s review of how retail intermediaries disclose commission arrangements to customers.

While firms were generally found to be complying with existing requirements, the review identified notable differences in the quality and accessibility of disclosures. Some firms adopted a more consumer-focused approach, presenting information in a clearer and more accessible manner.

The review was undertaken against the backdrop of the Central Bank’s 2026 Regulatory and Supervisory Outlook Report (RSO Report), which identified ineffective consumer disclosures as a key source of consumer risk.

The Central Bank reminds firms that the Consumer Protection Code 2025 (CPC 2025) requires information to be presented in a manner that effectively informs customers. Firms should therefore ensure that:

• Commission arrangements are clearly explained and prominently displayed in customer documentation;
• Customers are informed of both the percentage and monetary amount of any commission, as appropriate;
• Information in customer documentation is consistent with information available on their websites.

The Central Bank also encourages firms to maintain user-friendly websites containing clear and up-to-date information on commission arrangements. It noted that the use of plain English, commission tables and illustrative examples can help customers better understand how commissions operate.

Customer Experience and Complaints Handling

Complaints handling remains a key supervisory focus for the Central Bank, particularly in light of increasing complaint volumes and the high number of complaints referred to the Financial Services and Pensions Ombudsman (FSPO).

A recent review of customer experience identified ongoing weaknesses in how some firms identify, manage and resolve complaints. The Central Bank noted that many firms fail to sufficiently analyse the root causes of complaints, increasing the likelihood of recurring issues and escalation to the FSPO.

The Newsletter highlights firms’ obligations under CPC 2025, including requirements to:

• Accept complaints through a range of channels.
• Acknowledge complaints within five working days.
• Investigate and resolve complaints within prescribed timeframes.
• Keep consumers informed of progress.
• Communicate the outcome of investigations clearly.

Firms are also expected to maintain robust governance arrangements around complaint handling, including regular analysis of complaint trends and root causes. The Central Bank emphasises that early engagement and effective complaint resolution can improve outcomes for both consumers and firms.

Authorisation Application Update

The Newsletter highlights various updates made to the intermediary authorisation application forms in light of the introduction of CPC 2025. The changes are intended to ensure that the information required from applicants remains aligned with evolving regulatory requirements and the Central Bank’s supervisory expectations.

Of particular interest are updates to Application Form B and the accompanying guidance. New sections have been added that address the applicant’s use of artificial intelligence and digitalisation, the operation of third-country branches, and the firms’ obligations under the Digital Operational Resilience Act (DORA).

The updated forms and guidance are available on the Central Bank’s website. Applicants using Form B must use the revised documentation for applications submitted on or after 1 May 2026.

Other topics

The Newsletter also contains updates on a number of other topics relevant to (re)insurance intermediaries, including:

• Key supervisory priorities identified in the RSO Report (see our article here).
• The Central Bank’s review of diversity and inclusion and board effectiveness in fund management companies and lessons for other regulated firms (see our article here).
• The treatment and safeguarding of client funds.
• Developments relating to the Retail Investment Strategy and the new EU AML/CFT single rulebook.
• Consumer consent requirements for the automatic renewal of certain insurance products.

Should you wish to discuss the above topics, please contact Eoin Caulfield, Ian Murray, Niall Campbell or any member of the Insurance department or your usual William Fry contact.

Contributed by: Anastasia McCarthy