knowledge 18 February 2026 |

Further Amendments Made to Central Bank of Ireland’s Pre-Approval Controlled Functions List

There have been recent changes to the Central Bank of Ireland’s (“CBI”) Fitness and Probity Regime (“F&P Regime”). The F&P Regime seeks to ensure that individuals in key positions within regulated financial service providers are competent, capable, honest, ethical, of integrity and financially sound.

Reform

In its April 2025 “Consultation Paper - Amendments to the Fitness and Probity Regime” (“CP160”), the CBI consulted on revising its F&P Regime¹. The CBI proposed a two-stage review of its list of PCFs: an initial targeted revision and a substantive review in 2027. In its Feedback Statement published following CP160², the CBI noted that stakeholders expressed a preference for a once-off revision to avoid the burden of assessing two sets of changes. The CBI therefore proceeded with a small number of essential changes, reserving the substantive consultation and revision to coincide with a review of the Senior Executive Accountability Regime (SEAR) in 2027.

On 28 January 2026, the Governor of the CBI, Gabriel Makhlouf, signed the Regulations, which came into operation on 10 February 2026. The Regulations amend the list of PCFs with PCF-24 – “Head of Traded Markets” and PCF-25 – “Head of International Primary Markets” being deleted. Two new PCFs are added. PCF-56 – “Head of Safeguarding” is created in respect of a Payment Institution (“PI”) authorised or required to be authorised under the European Communities (Payment Services) Regulations 2009 or an Electronic Money Institution (“EMI”) within the meaning of the European Communities (Electronic Money) Regulations 2011. PCF-57 – “Head of Safeguarding” is created in respect of a Crypto-Asset Service Provider (“CASP”) within the meaning of Regulation (EU) 2023/1114 (Markets in Crypto-Assets Regulation (MiCAR)).

Practical Considerations

These new PCF roles are relevant to entities authorised or seeking authorisation as PIs/EMIs and as CASPs. Such entities are required to identify a senior individual for overseeing safeguarding frameworks and outcomes. Entities seeking authorisation as PIs/EMIs or CASPs will now need to identity a specific individual to perform the safeguarding role and receive CBI approval before appointment. Firms will also have to ensure that there is ongoing compliance with the F&P Regime. Firms that are already authorised should take steps to identify relevant individuals. Where such firms identify an individual who is deemed to be already performing the PCF-56 or PCF-57 role prior to 10 February 2026, an Individual Questionnaire is not required to be submitted to the CBI.

In practical terms, safeguarding is no longer capable of being diffused across compliance, finance, or operations functions. Safeguarding accountability must sit with a named, CBI-approved senior individual. This elevates safeguarding to a senior-level issue, strengthens governance expectations, increases individual regulatory exposure, and embeds safeguarding oversight as a central consideration in both ongoing supervision and the authorisation process.

How McCann FitzGerald LLP Can Help:

McCann FitzGerald LLP is a premier law firm in Ireland with deep expertise in relation to financial regulation. We can provide a full range of legal and compliance support services in connection with the CBI’s F&P Regime. Please contact us for further support.