The Central Bank of Ireland (Central Bank) published its annual Authorisations and Gatekeeping Report 2025 on 4 June 2026 (the Report).
The Report provides a comprehensive overview of regulatory authorisation activity and gatekeeping functions across Ireland’s financial services sector in 2025. It details the Central Bank’s authorisation expectations, application trends, performance metrics by sector, and also contains a dedicated chapter on Fitness and Probity (F&P) activity last year.
In this article, we highlight the key takeaways for the insurance sector from the Report, including authorisation activity, post-authorisation processing times and developments in the Central Bank’s F&P regime.
Insurance Sector Overview
New Authorisations
In 2025, the Central Bank received 8 insurance-related applications and the same number were authorised. This included two (re)insurers (advised by the William Fry Insurance Team), three Solvency II Special Purpose Vehicles (SPVs) and three SPV arrangements. The average processing times for (re)insurer applications were 208 calendar days. This represents the total period from receipt of the original incomplete application to the Central Bank’s issuance of the certificate of authorisation.
The Report emphasises that applicant readiness remains the key driver of timelines, with the overall timeframe from initial submission to final authorisation being largely dependent on:
- the quality and completeness of the application;
- the complexity of the business model; and
- the applicant’s responsiveness to regulatory queries.
Post-Authorisation Changes
The Central Bank reported the following average processing times for insurance-related post-authorisation applications in 2025:
- acquiring transactions – 57 days;
- portfolio transfers – 196 days;
- changes to business plans – 74 days;
- extensions of insurance classes – 36 days;
- Branch applications (outwards) – 32 days
- Revocation of authorisation – 24 days
Compared with 2024, the 2025 data shows some variation across post-authorisation application categories. Average processing times were lower for outward branch applications, changes to business plans and revocations of authorisation, while processing times increased for qualifying holding acquisitions, extensions of insurance classes and portfolio transfers. The increase in the average processing time for portfolio transfers, from 77 days in 2024 to 196 days in 2025, is particularly notable given the importance of such transactions in business reorganisations, legacy portfolio management and M&A activity.
Overall, the figures indicate differing processing timelines across the various post-authorisation categories. For insurers contemplating transactions requiring Central Bank approval, the data provides a useful reference point for regulatory planning and transaction timetables, particularly for portfolio transfers, business restructurings, and ownership changes.
Fitness and Probity
The Report highlights key recent developments to the Central Bank’s Fitness and Probity framework, including the establishment of a centralised F&P Unit in January 2025 and the Gatekeeping Decisions Committee (GDC) in March 2025. The reforms are intended to support greater consistency, efficiency and transparency in decision-making.
Since its establishment, the GDC has considered three referrals. Two resulted in refusals of authorisation, while the third resulted in the involuntary revocation of a firm’s registration and authorisation.
Regarding enforcement, on 17 April 2026, the Irish High Court (the Court) refused to confirm a one-year Prohibition Notice issued by the Central Bank in February 2022. The Court found the Central Bank failed to observe the respondent’s entitlement to natural and constitutional justice as well as basic fairness of procedures. To read more on this, please see our article on the decision here.
PCF Application Activity
The Report notes that the Central Bank received 3,032 Pre-Approval Controlled Function (PCF) applications in 2025, broadly in line with 3,060 applications in 2024. A total of 2,684 applications were approved, while withdrawals increased slightly year-on-year. The Central Bank reported a 97% compliance rate with its service standard for PCF applications in 2025, with an average approval time of 50 days.
Incomplete applications continue to be a common cause of delays. The most frequently cited issues were:
- the proposer being invalid or unauthorised;
- insufficient evidence of minimum competency compliance being provided;
- selecting an incorrect company structure.
PCF Interviews
The number of PCF interviews fell significantly, decreasing from 47 interviews in 2024 to 26 in 2025. The Report attributes this reduction, in part, to the Central Bank’s post-Enria Review approach of conducting a single comprehensive interview where required, replacing the previous two-stage interview process, as well as increased reliance on other information-gathering tools.
Within the insurance sector, only two interviews were conducted from approximately 120 PCF applications, indicating that interviews remain reserved for a relatively small number of cases.
Conclusion
Overall, the Report continues to provide a useful benchmark for insurers engaging with the Central Bank on authorisation, post-authorisation and Fitness and Probity matters. The data reinforces the value of early planning, high-quality submissions and proactive engagement with the regulator, particularly for more complex transactions and organisational changes.
Should you wish to discuss this topic, please contact Eoin Caulfield, Ian Murray, Niall Campbell, or any member of the Insurance Department or your usual William Fry contact.
Contributed by: Adam Malone & Martha Ní Dhochartaigh
