On 13 June 2025, the Central Bank of Ireland (Central Bank) published its second insurance newsletter of 2025 (Newsletter).

The Newsletter features a range of articles that will be of interest to insurers and (re)insurers. This includes updates on the Digital Operational Resilience Act (DORA), the protected disclosures regime, the EU Anti-Money Laundering package (AML Package) and the Insurance Recovery & Resolution Directive (IRRD).

DORA

DORA took effect on 17 January 2025, requiring financial entities, including (re)insurance undertakings, to enhance their ability to withstand, respond to and recover from information and communication technology (ICT) disruptions.

Firms subject to DORA must submit registers of information in relation to all contractual arrangements on the use of ICT services provided by third-party service providers. However, the Central Bank has announced that (re) insurance firms will not need to submit their outsourcing registers in 2025 due to the heavy compliance workload involved with DORA.

AI Updates

The Central Bank has launched a data-gathering initiative on AI usage within the (re)insurance sector. This includes a survey, distributed to selected firms in May 2025, to understand firms’ current and planned use of AI. This concerns Generative AI, related governance and risk management practices.

Protected Disclosures

The protected disclosures regime is a key tool for the public and employees in regulated financial firms to report suspected wrongdoings to the Central Bank confidentially. This regime is critical in contributing to the supervisory outcomes and enforcement actions.

Under the Central Bank (Supervision and Enforcement) Act 2013, pre-approval controlled function (PCF) holders are legally obliged to report breaches of financial service legislation, which are treated as protected disclosures by the Central Bank.

In the Newsletter, the Central Bank gives a timely reminder of the importance of protected disclosures, acknowledging the difficulty in making them. It encourages individuals to come forward and provides guidance on the most useful information, such as details of the parties involved, the nature and timing of the wrongdoing, its impact, and any supporting evidence.

It is noted in the Newsletter that the Central Bank received an average of over 200 protected disclosures annually from 2019 to 2024, covering a wide range of firms and sectors.

EU AMLA Package and the Anti-Money Laundering Authority

In June 2024, the European Commission published a comprehensive anti-money laundering package (AML Package) to strengthen the EU’s framework for combating money laundering and terrorist financing.

The package comprises:

• The Anti-Money Laundering Regulation (AMLR) sets harmonised AML/CFT obligations for obliged entities across the EU. The AMLR will apply from July 2027;
• The sixth AML Directive (6AMLD) contains obligations for Member States, national supervisors (NCAs), and Financial Intelligence Units (FIUs). The 6AMLD includes provisions on the powers and responsibilities of NCAs and FIUs. Member States must transpose the 6AMLD into national law by July 2027; and
• AMLA Regulation (AMLAR) establishes the anti-money laundering authority (AMLA).

AMLA’s primary responsibility is to oversee the implementation of the harmonised AML/CFT rules. It will also control the direct supervision of 40 of the highest cross-border obliged entities. AMLA will commence its supervisory powers over the highest-risk obliged entities in January 2028.

AMLA is currently working with NCAs and FIUs to draft the necessary regulatory standards, implementing standards and guidance under the AML Package to ensure obliged entities understand their obligations before the implementation deadline of 2027. The Central Bank encourages obliged entities to familiarise themselves with the AMLR so that they are in a position of compliance by the implementation date.

Other Topics

In addition to the above key takeaways, the Newsletter contains the following articles:

• insight on the upcoming consultation on the Insurance Recovery Resolution Directive (IRRD);
• the Central Bank’s publication of the Financial Services and Pensions Ombudsman’s 2024 Overview on Complaints Report;
• the Central Bank’s 2024 Annual Report and Performance Statement; and
• an update on the Central Bank’s intention to collect auditors’ statutory duty confirmation returns through its online Portal.

Please click here to view the full Newsletter.

If you have a query about any item covered in the Newsletter, please contact a member of our Insurance team or your usual William Fry contact.