knowledge 19 January 2026 |

The CBI’s Roadmap for Simplifying Regulation and Supervision: An Effective and Efficient Approach

The CBI’s Approach to Simplification

Following the CBI’s commitment to engagement and openness¹, the CBI has transformed its regulatory and supervisory approach in an effort to enhance the agility, adaptability and risk sensitivity of its supervisory framework. The CBI’s simplification work seeks to produce the same outcomes in simpler and increasingly efficient ways, including by:

• improving the clarity, consistency, coherence and predictability of rules;
• reducing unnecessary burdens and complexities without compromising the effectiveness of the rules;
• ensuring that the frameworks and engagements are risk based, proportionate and clear; and
• preserving protections and resilience.

Guardrails

Whilst the CBI is carrying out ongoing international and domestic work in alignment with the European simplification agenda, the CBI is clear that it has guardrails in place for reaching determinations regarding the simplification of its frameworks, as follows:

1. Mission first

Whilst acknowledging that the simplification of rules and requirements will inevitably involve trade-offs, the CBI specifies that simplification should not undermine the delivery of its mission and the safeguarding outcomes regarding the protection of consumers and investors and the resilience, stability and integrity of the financial system.

2. Proportionality and Materiality

In accordance with the CBI’s focus on risk-based supervision, regulatory burdens should correspond with the scale, complexity and the materiality of the associated risks.

3. Evidence-Based Change

The simplification proposals should, where possible, emanate from data, supervisory insight and cost-benefit analysis.

4. European Harmonisation and Convergence

Domestic rules should, where possible, enhance coherence within the Single Market, and divergence should be justified in light of variances in the risk landscapes and statutory requirements.

5. Implementation Before Legislation

In order to reduce uncertainty and improve the efficiency of delivery, the CBI prioritises the simplification of the application and supervision of existing rules prior to subsequent amendments to legislation.

6. Clarity and Transparency

The CBI seeks to ensure that stakeholders can identify and understand the changes to the rules, and the justification for such changes, to bolster predictability and certainty.

7. Adaptability and Supervisory Judgement

The CBI will adapt regulation and supervision as markets evolve, explicitly managing key trade-offs (e.g., simplicity–precision, efficiency–insight, flexibility–certainty, proportionality–consistency, speed–due process) to ensure measures deliver benefits by reducing unnecessary burdens while preserving resilience, protections, and supervisory insight.

The CBI’s Plan

The report outlines a multi‑year domestic workplan between 2026 and 2028 and the CBI’s contribution to EU reforms, with an emphasis on clarity, predictability and supervisory convergence. The report details the CBI’s plans for work in the following four areas:

1. Supervision

Following the introduction of its new supervisory approach in 2025, the CBI intends to continue work on this front, including enhancements to its engagement with firms, being clearer in supervisory communications, and building on its risk-based and proportionate supervisory approach, all the while maintaining financial stability, consumer and investor protection, safety and soundness of supervised entities and the integrity of the financial system.

2. Regulation

In terms of regulatory goals, the CBI notes that any simplification initiatives must be proportionate, clear, and predictable and that it has or will seek to implement its simplification objectives through several regulatory initiatives including the following:

Insurance

• reviewing Ireland’s insurance rulebook for compatibility, including to eliminate duplicative domestic instruments, in light of the upcoming Solvency II reforms;
• reviewing the 2021 Recovery Planning Regulations in light of the upcoming application of the EU Insurance Recovery and Resolution Directive (IRRD) in 2027;

Banking

• reviewing the national banking regulatory framework in light of updated EU standards for capital requirements (including the Code of Practice on Lending to Related Parties, the Policy on the Management of Country Risk by Credit Institutions, the Impairment Provisions for Credit Exposures);
• enhancements to the Section 149 process for approving new/changes to bank fees and charges;
• ongoing updates to the Credit Union Handbook and associated guidance; and
• updates to the resolution framework.

Capital Markets and Funds

• introducing changes to the AIF rulebook and UCITS regulation in alignment with the updated EU funds framework;
• launching a comprehensive review of the Fund Service Provider (FSP) Framework; and
• consolidating its Q&As and guidance into an organised framework.

Cross-sectoral initiatives:

Simplification initiatives which apply cross-sectorally include:

(a) the upcoming review of the Corporate Governance Codes in 2026;

(b) updates to the Cross-Industry Guidance on Outsourcing in 2026;

(c) the three-year review of the Senior Executive Accountability Regime (SEAR) in 2027;

(d) continued withdrawal and consolidation of Ireland’s anti-money laundering/ countering the financing of terrorism (AML/CFT) frameworks (Dear CEO letters, Q&As and legacy artefacts) in light of the new EU AML Regulation; and

(e) consulting on a new Regulatory Impact Assessment (RIA) Framework in 2026.

3. Gatekeeping

The CBI views gatekeeping as an area which can be enhanced in order to achieve its streamlined regulatory and supervisory regime. The CBI has made, and continues to make, improvements in this area including by:

• improving its guidance, expectations and engagement, including through the Authorisations and Gatekeeping report², and the recently published consolidated Fitness & Probity (“F&P”) Guidance³;
• improving the F&P system, including through the recently established dedicated F&P unit, to accelerate the processing of individual questionaries (IQs),
• establishing a Gatekeeping Division within the F&P unit,
• updating authorisation and change of business requirements for the insurance sector;
• reviewing the Pre-Approval Control Function framework in 2026, to coincide with the SEAR review in 2027;
• further work on standardising and clarifying authorisation processes for funds, intermediaries, prospectuses and market participants; and
• enhancing transparency on timelines and expectations.

4. Reporting and Data

Owing to the fact that having high-quality data is key to risk-based supervision, the CBI is seeking to improve data collections and use, including by consolidating data reporting requests and undertaking a detailed review of its data collection methods, to align with initiatives taken by the ECB and EBA to integrate and simplify reporting.

Conclusion

While entities can expect continued updates and changes in the CBI’s approach to regulation and supervision between now and 2028 to create a more streamlined approach where possible, the CBI notes that its focus on simplification does not prevent the introduction of new rules and requirements considering the complex nature of the financial sector and the evolving risk landscape. The CBI emphasises the importance of complexity that is necessary and purposeful as the regulatory framework must not be overly simplistic or stagnant, with the protection of consumers and the financial system being a key focus.