In June 2026, the Central Bank of Ireland (Central Bank) published its 2026 Report on Implementation of Recommendations (the Report), confirming that it has implemented all twelve recommendations arising from the independent review of the Fitness and Probity (F&P) approval process, conducted by Andrea Enria in 2024.
The review was commissioned following the Irish Financial Services Appeals Tribunal (IFSAT) finding in respect of the Central Bank’s handling of a pre-approval controlled function (PCF) application. While Mr Enria concluded that the Irish F&P regime was broadly aligned with international peers, he identified enhancements that could be made to improve fairness, transparency, and efficiency in the F&P approval process. The resulting Report contained twelve key recommendations, all of which were endorsed by the Governor of the Central Bank. For further background, see our previous article, Recommendations to reform the fitness and probity approval process here.
The Central Bank published an interim implementation update in April 2025 alongside Consultation Paper 160 (CP160) on amendments to the F&P regime. For further information, see our previous article, The Central Bank Consults on the Fitness and Probity Regime (CP160) here.
The Report marks the final implementation update from the Central Bank and confirms that all recommendations have now been embedded into the Central Bank’s supervisory processes and governance framework.
Key Developments
The Central Bank groups its implementation efforts under three key review areas:
- clarity of supervisory expectations;
- internal governance; and
- fairness, efficiency and transparency.
Building on the progress outlined in the Central Bank’s 2025 implementation update, the Report notes that the focus has now shifted from implementing the recommendations to embedding them into the day-to-day operation of the F&P framework.
Under the theme of clarity of supervisory expectations, the Central Bank has consolidated guidance materials and published updated Fitness and Probity Standards Guidance following consultation with industry.
In respect of internal governance, the Central Bank has completed significant structural reforms, including the establishment of a F&P Unit to centralise sectoral gatekeeping responsibilities, and a Gatekeeping Decisions Committee (see below).
The Report also highlights measures designed to enhance fairness, efficiency, and transparency, including improvements to stakeholder engagement, process guidance, complaints handling, and assessment timeframes.
The Twelve Recommendations – Where Are We Now?
The following are each of the 12 recommendations issued by Mr Enria in his Report, along with a high level review of the Central Bank’s implementation of each.
1. Strengthening the industry’s F&P gatekeeping role
Mr Enria recommended that firms be provided with clearer guidance regarding their role in assessing candidates before submitting PCF applications to the Central Bank. The Central Bank has sought to address this through publication of the Gatekeeping Process Manual, the establishment of the F&P Unit, extensive industry engagement initiatives, workshops and stakeholder feedback surveys.
2. Enhancing F&P standards and guidance
The Central Bank has consolidated and updated its F&P guidance, following public consultation through CP160. The revised guidance (published in November 2025) is intended to provide greater certainty regarding regulatory expectations for senior role holders.
3. Governance reforms and review of PCF roles
The F&P Unit was established on 1 January 2025 and centralises gatekeeping responsibilities across all sectors and is intended to promote consistency in assessments. Further updates to the PCF list are expected later this year in line with the Central Bank’s 3-year review of the Senior Executive Accountability Regime (SEAR).
4. Decision-making enhancements
The Central Bank established the Gatekeeping Decisions Committee on 1 March 2025. The Gatekeeping Decisions Committee provides an independent decision-making layer for cases involving potential refusals.
5. Improved communication and stakeholder engagement
In response to recommendations concerning engagement and transparency, the Central Bank has committed to annual information sessions, ongoing workshops, and structured feedback channels. The Report notes that industry feedback on these initiatives has generally been positive.
6, 7 and 8. Interview procedures and withdrawals
The Enria review identified a need for greater fairness and consistency during the interview phase. The Fitness and Probity Gatekeeping Process Manual now provides clarity regarding interview notices, interview duration, feedback processes, and withdrawals.
9.Enhanced management information
The Central Bank has expanded the information shared publicly through its annual Authorisations and Gatekeeping Report. The latest report indicates that 97% of F&P applications were completed within 90 days, while average approval times reduced to 50 calendar days during 2025, compared with 52 days in 2024.
10. Quality assurance framework
Periodic reviews will be undertaken by the F&P Unit to identify opportunities for process improvements and refinements.
11. Dedicated complaints procedure
The Central Bank has introduced a specific complaints process for F&P gatekeeping assessments. The Report notes that no complaints have been made under the procedure to date.
12. Comprehensive training programme
Finally, the Central Bank has implemented enhanced training programmes for staff involved in F&P assessments, with a particular focus on interviews and decision-making processes.
Looking Ahead
Although the Central Bank has confirmed implementation of all twelve recommendations, it emphasises that the work is ongoing. In particular, the review of roles requiring prior approval remains a key focus area and proposed changes to the PCF list are expected later in 2026, with F&P materials to be updated following this review as well as the Central Bank’s review of SEAR in 2027. The Central Bank has also committed to ongoing refinement of its processes, continued stakeholder engagement, and maintaining a focus on quality assurance and effectiveness.
The Report represents the culmination of a significant programme of reform following the Enria review. Firms and proposed PCF applicants are likely to welcome the increased emphasis on transparency and procedural fairness in the F&P gatekeeping process.
For further information on this topic, please contact a member of our Insurance department or your usual William Fry contact.
Contributed by: Anastasia McCarthy
