The Central Bank of Ireland (Central Bank) issued several updates regarding (re)insurance intermediaries in November.

These included the publication of the second edition of the Investment Firm and Intermediary Newsletter for 2025 (the Newsletter) and hosting of the Annual Retail Intermediaries Roadshow (the Roadshow) which included an address delivered by Gerry Cross, Director of Capital Markets and Funds.

These events highlight several topical areas of interest for (re)insurance intermediaries, including:

Thematic Review of Limited vs Fair Analysis of the Market

In October 2025, the Central Bank published the findings of its Thematic Review of Limited vs Fair Analysis of the Market (the Review). The Newsletter reiterates the key takeaways of the Review, noting that overall results were positive. The majority of in-scope firms were found to be effectively informing consumers about the nature of the services provided and accurately disclosing remuneration arrangements with product providers.

However, the Review identified that a small number of firms were incorrectly describing their services as ‘independent’ or using similar terms such as ‘impartial’ or ‘unbiased’ while receiving commission payments from a product provider.

The Newsletter reminds firms that such practices are not compliant with the Consumer Protection Code (CPC) and advises those in receipt of commission payments to remove these terms from relevant disclosures and marketing materials immediately. Moving forward, intermediaries are expected to pay attention to ‘areas of improvement’ and ‘good practices’ outlined in the Review and to incorporate them accordingly.

The Roadshow provided additional insights by highlighting both good practices identified by the Central Bank and areas requiring improvement. Key areas identified for enhancement included:

• Outdated Terms of Business and/or Commission Statements;
• Absence of a formal, documented process for periodic review of key documentation;
• Terms of Business and Commission Statements containing generic, high-level information rather than firm-specific details;
• Failure to review regulatory updates, resulting in missed updates to documents and processes;
• Use of third-party templates without sufficient adaptation to reflect to the specifics of their firm.

Online Application Form Update and Webinar

The Newsletter flags that, effective 1 January 2026, Word-document application forms for ‘A Form’ applicants will no longer be accepted. From this date, all applications (i.e. A Form and B Form) must be submitted online via the Central Bank’s Portal. The Central Bank’s website provides detailed guidance on accessing and using the Portal.

Updates on the Consumer Protection Code for 2026

The Newsletter emphasises the importance of preparing for the implementation of the revised CPC, which will take effect in March 2026. Firms’ readiness for the revised CPC will remain a key focus of ongoing supervisory engagements between the Central Bank and firms. The revised CPC was also a topic at the Roadshow and the Central Bank highlighted the importance of firms ‘securing customers interests’ and noted areas which require particular attention, including:

• Digitalisation;
• Informing effectively;
• Mortgages and Switching;
• Climate;
• Unregulated activities;
• Fraud and Scams; and
• Vulnerable consumers.

Core Expectations for (Re)insurance Intermediaries in 2026

At the Roadshow, the Central Bank outlined its core expectations for intermediaries for 2026, highlighting that firms must:

• be financially resilient;
• embed consumer interests within business strategy and culture;
• ensure access to financial services; and
• prepare for the implementation of the revised CPC.

Other topics

In addition to the above key takeaways, the Newsletter and the Roadshow also considered the following:

• the Central Bank’s thematic assessment of Operational Resilience in MiFID investment firms;
• detail on the revised Fitness and Probity guidance and the outcome of the CP160 consultation (see our article here); and
• the appointment of Colm Kincaid as Deputy Governor of Consumer & Investor Protection.

Conclusion:

The Newsletter, and the Roadshow collectively underpin the Central Bank’s focus on resilience, accountability and consumer protection entering 2026. Re(insurance) Intermediaries are expected not only to comply with regulatory requirements but to actively embed best practices into their governance, culture and customer engagement. The emphasis on cyber and operational resilience, securing customers’ interests and preparing for the revised CPC were common themes throughout each and signal to (re)insurance Intermediaries to be proactive rather than reactive in addressing regulatory change.

For more information, please contact Eoin Caulfield, Ian Murray, Niall Campbell or any member of the Insurance department or your usual William Fry contact.

Contributed by Caitlin Lenihan and Molly Ryan